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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06/11/23 – BSI: BS 8670 Built environment
Consultation title: Built environment – Core criteria for building safety in competence frameworks – Code of practice
Consultating organisation: British Standards Institute (BSI)
Deadline: 6 November 2023 (please provide any response for APM to consider by 31 October 2023)
About this consultation
This British Standard gives recommendations for core criteria for building safety to promote high standards of protection for people in and around buildings. It is applicable to buildings of all types and scales. It is intended to have wide application and relevance in modern construction and property markets throughout the UK and beyond.
Building safety in the context of this British Standard relates to the physical conditions created by new or existing buildings, their immediate surroundings and how these impact on the safety of occupants (including residents) throughout the building life cycle.
Background to inquiry
This British Standard is intended for use by those with responsibility for the development, maintenance or application of sector-specific competence frameworks for roles, functions, activities or tasks undertaken by individuals where these are critical to and directly influence safety in and around buildings. This includes competence frameworks for technical and non-technical roles, and for individuals working under their own authority as well as under the supervision of other competent individuals.
This British Standard might also be relevant to regulated, duty-holding or statutory roles, including:
- Principal Designers;
- Principal Contractors;
- designers;
- contractors;
- building control professionals; and
- persons responsible for buildings in occupation.
Consultation questions
N/A – comments welcome on the whole draft standard at BS 8670 Built environment – Core criteria for building safety in competence frameworks – Code of practice
How to respond
Please email your comments by 30 October 2023, 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 BSI website, deadline for responses there is the 6 November 2023.
06/10/23 – Department for Transport: Freight, logistics and the planning system
Consultation title: Freight and logistics and the planning system: call for evidence
Consultating organisation: UK Government – Department for Transport
Deadline: 6 October 2023 (please provide any response for APM to consider by 1 October 2023)
About this consultation
This call for evidence is on the interaction between freight and logistics and the planning system in England.
The Future of Freight: a long-term plan sets out the objective of a planning system that recognises the needs of the freight and logistics sector – now and in the future – and empowers the relevant authority to plan for them.
The Department for Transport (DfT) and Department for Levelling Up, Housing and Communities (DLUHC) call for evidence seeks views so that the planning needs of the freight and logistics sector can be properly and effectively considered.
Consultation document and response form
Background to inquiry
The evidence received will help underpin any new or amended planning policies that reflect the government’s vision and expectations for local planning authorities in planning for freight. It will also ensure sufficient land is allocated to service the needs of freight and logistics.
In particular, they are seeking evidence in 3 areas: local plan making and land availability, planning decision taking and the applications process, and how the planning system can support specific policy priorities, including: supporting supply chains, decarbonisation of freight, heavy goods vehicle (HGVs) driver parking facilities and welfare strengthening the Union.
Consultation questions
Question 1
In your view, how effective are local plans at identifying development needs, and then allocating sites, for freight and logistics and how could this be improved?
Question 2
How effectively are the policies in the national planning policy (Chapter 6) and associated practice guidance applied by plan makers in supporting the needs of freight and how could this be improved?
Question 3
How effective is engagement between industry and local authorities in the course of local plan making? How can this be improved?
Question 4
How effectively does planning currently support more efficient use of established freight and logistics infrastructure and how could it better support existing infrastructure?
Question 5
How should freight and logistics be factored into statutory local transport plans and sub-national transport strategies?
Question 6
What aspects of the applications and decision taking process work well and what aspects do not work well?
Question 7
How effective is the planning system at addressing the operational needs of the freight and logistics sector and how could this be improved? How could a national freight network be recognised in national planning policy?
Question 8
How can the planning system support our net zero ambition for freight and logistics?
Question 9
What more could local plans and decisions do to facilitate the supply of high-quality HGV parking and driver facilities?
Question 10
How can planning policy in England help to support the freight and logistics sector across the whole of the UK?
How to respond
Please email your comments by 1 October 2023, 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 Department for Transport website, deadline for responses there is the 6 October 2023.
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:
- Improving active travel infrastructure
- Influencing travel choices and behaviours
- Enhancing access to affordable public transport
- Decarbonising transport
- Increasing safety and resilience on the strategic transport network
- 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.