Participation by 16-19 year olds in education and training - Education Contents


2  Raising the age of participation

The policy aim

6. Participation in education is presently compulsory up until the last Friday in June of the school year in which a pupil reaches the age of 16.[5] The ambition to treat the age of 16 as the school leaving age dates back to the Education Act 1944, although that ambition was only realised in September 1972.

7. The Department does not publish statistics for the percentage of children of compulsory school age who are in education, whether in school or out of school. However, it does collect data for absenteeism: 1.4% of pupils at state-funded primary schools, 4.4% of pupils at state-funded secondary schools and 10.5% of pupils at special schools were persistent absentees (defined as pupils who have missed 64 or more sessions[6] during the year) in 2009/10: on average this works out as 2.9% of pupils of compulsory school age in maintained schools (including Academies) and non-maintained special schools.[7]

The Education and Skills Act 2008

8. The Labour Government in the last Parliament brought forward legislation to increase the age of compulsory participation in education or training. In popular parlance, the Education and Skills Act 2008 is said to raise the age of compulsory participation to 17 in 2013 and 18 in 2015. More precisely, sections 1 and 2 of the Education and Skills Act 2008 specify that the requirement to be in "appropriate full-time education or training" shall apply to anyone who has ceased to be of compulsory school age but who has not yet reached the age of 18, and who has not attained a Level 3 qualification. The Act also specifies that the Secretary of State should stagger the raising of the age of compulsory participation, by requiring him or her to apply the participation requirement from 2013 to young people who have not reached the first anniversary of the date on which they ceased to be of compulsory school age, before the full provisions come into force in 2015.[8]

9. In practice, the effect of the 2008 Act is that all 16 year olds will have to participate from 2013 onwards, as well as those who start the school year aged 16 but turn 17 during the course of the year. The effect of further raising the compulsory participation age in 2015 will be merely to extend the requirement to all 17 year olds, and it is therefore somewhat misleading to talk about raising the participation age to 18.

10. The hours of training or education required to satisfy the duty under the 2008 Act must amount to at least 280 hours of "guided learning": direct instruction, immediate guidance or supervision, and excluding unsupervised preparation or study. Each local authority is required to "ensure that its functions are ... exercised so as to promote the effective participation" of the young people in its area. Governing bodies of institutions are similarly required to promote participation through regular attendance of relevant learners.[9]

11. The rationale for raising the age of participation was set out by the previous Government in a Green Paper in 2007: Raising Expectations: staying in education and training post-16.[10] The gist is in paragraph 2 of the Executive Summary:

    It is no longer a sensible option for a young person to leave education for good at 16 in order to seek work. The great majority of young people already do stay on beyond 16 and there is a risk that it will only be the more vulnerable and lower-achieving who drop out at 16. Yet they are precisely the group who have the greatest need to stay on—so that they can achieve useful skills which will prepare them for life. The time has come to consider whether society is letting these young people down by allowing them to leave education and training for good at 16, knowing that they are not adequately prepared for life.

12. Although not mentioned in the Coalition Agreement published in May 2010,[11] the Coalition Government has confirmed that it will proceed with the policy of raising the age of compulsory participation. The Spending Review 2010 remarked that

    For 16 to 19 learning, the Spending Review will support further increases in participation, while moving towards raising the participation age to 18 by 2015. This will reduce the proportion of young people not in education, employment or training and ensure more young people from all backgrounds have the support they need to fulfil their potential in the labour market and improve social mobility.[12]

Existing levels of participation

13. There has been a steady increase in participation in education and training by 16 year olds in England in recent years, and most are now already participating. The proportion of 17 year olds in education or training, which hovered around 80% for many years, has risen steeply since 2006, when it stood at 80.9%. Latest figures are set out below:

Table 1: Participation by 16-18 year olds in education, training and employment

Source: DfE Statistical First Release SFR 15/2011: Participation in education, training and employment by 16-18 year olds in England. Figures for 2010 are provisional.

The following figures illustrate where 16-18 year olds in full-time education are learning:

Table 2: 16-18 year olds in full-time education in 2010, by place of learning


Source: DfE Statistical First Release SFR 15/2011: Participation in education, training and employment by 16-18 year olds in England. Figures are provisional.

14. Internationally, the United Kingdom as a whole appears to perform poorly in rates of participation in education and training beyond the age of 15. The OECD measures participation rates in member and partner countries and produces comparative tables. Although any such data are dogged by differences in terminology and classification, the percentage of the population aged 15 to 19 in the UK studying at institutions in 2008 was calculated by the OECD to be 73%, compared to an average among OECD member countries of 82%. Among OECD member and partner countries, only Turkey, Israel and Mexico had lower percentages; and major European economic competitors such as France and Germany scored 86% and 89% respectively.[13] It should be noted, however, that in most OECD countries, formal schooling begins later than in the UK.

15. Given the increasing value of skills in the labour market, it might be assumed that the UK's poor relative performance in participation at 15-19 under OECD measures would be reflected in a comparatively high rate of youth unemployment. In fact, the OECD's figure for youth unemployment in the UK is just below the OECD average, alongside the United States, and is higher than Germany, Japan, Australia and the Netherlands (lowest of all, at around 7%), but lower than France, Finland, Italy and Sweden.[14]

Impact on young people

16. The young people principally affected by the new provisions on compulsory participation in England will be those shown in Table 1 as being in employment without training[15] and those who are not in education, employment or training (NEET). The latter group is considerably larger and more problematic. We look at the characteristics of young people not in education, employment or training in some detail below, and we take this sketch as a general indication of the circumstances and characteristics of perhaps the majority of those 16 and 17 year olds who, in a few years' time, will be in education and training not because that is what they would have chosen but because it has become compulsory.

CHARACTERISTICS OF YOUNG PEOPLE NOT IN EDUCATION, EMPLOYMENT OR TRAINING

17. At the end of 2009, there were 25,200 16 year olds and 49,100 17 year olds who were not in education, employment or training: 74,300 in total, which was 5.7% of the 16-17 age group. If 18 year olds are included (as is the more common practice), the total increases by 116,300 to 190,600, which is 9.6% of the 16-18 age group. However, as explained above, 18 year olds will not be subject to compulsory participation under the provisions of the 2008 Act.[16]

18. Young people who are not in education, employment or training may be so for a huge variety of reasons. Some will have no history of work; some will have moved in and out of short-term employment; some will have opted out of study because of an unhappy school history; some will be in custody; some will be refugees or asylum seekers not yet granted citizenship; and some will have left study because of difficult domestic circumstances. Some will be "NEET" for more positive reasons: for instance, full-time volunteers and young people on gap years fall within the definition used for statistical purposes.[17]

19. The National Audit Office provided our predecessors on the Children, Schools and Families Committee with an analysis of some of the characteristics of young people not in education, employment or training. It found that:

  • A higher proportion of white young people are NEET than is seen among most ethnic minority groups;
  • Young people who are NEET are more likely than their peers to have a disability or longer term health problem;[18]
  • Children in local authority care are much more likely than their peers to be NEET;
  • 16/17 year olds who are NEET are more likely to have engaged in risky behaviours (smoking or vandalism, for example) by age of 13/14; and
  • Disadvantage in its many forms is a more common feature of early life for 16/17 year olds who are NEET.[19]

Haroon Chowdry, a senior research economist at the Institute for Fiscal Studies, told us that academic performance within school was a major predictor of NEET status post-16.[20]

20. As the Children, Schools and Families Committee noted, the question of how to reduce the size of this group has attracted attention from policymakers, thinktanks, the third sector and many others.[21] It is not difficult to see why so much energy has gone into trying to address this issue. The Government noted in its child poverty strategy, published in April 2011, that

    Being NEET between the ages of 16 and 18 years is associated with later negative outcomes, such as unemployment, lower pay, having a criminal record, poor health, teenage parenthood and negative psychological outcomes.[22]

The problems which individuals face cannot be addressed by learning alone; nor can they necessarily re-enter and remain in education or training without some of those problems (such as health and housing) being tackled.[23] However, these are issues which lie outside the scope of this Report.

21. Given their typically fractured school history, many in this group will have comparatively low levels of attainment, skills and aspiration. Some will have an antipathy to any formal learning setting. Dr Thomas Spielhofer, who led a research study by the National Foundation for Educational Research (NFER) on barriers to education and training, told us that 6% of young people surveyed by the study were not interested in participation, and that often this was because they had been put off by their experience of education and training: "they just do not want anything to do with anything that they associate with their previous experience of it".[24]

22. Witnesses held a range of views on whether motivation was an issue for this group. Seyi Obakin, Chief Executive of Centrepoint, told us that he did not think that motivation was a real problem: "When you scratch beneath the surface, all the young people we work with want to do well. They want to attend; they know that if they have qualifications they will do better in life".[25] However, Bob Reitemeier, Chief Executive of the Children's Society, thought that self-motivation was lacking in many who were NEET or not engaged; and he believed that this could be a reaction to other people's perception that they had no potential.[26] A further angle was put to us by Dr Thomas Spielhofer, who told us that

    With some of the young people who don't participate, it is not necessarily an issue about motivation or self-motivation; in many cases, the issue is about resilience ... Often the issue with young people who do not participate is that they have very low resilience, so if anything is a small barrier or if anything goes wrong they drop out or do not even start to participate.[27]

23. We recognise that the seeds of increased participation at the age of 16 and 17 lie much earlier in a child's life and will be rooted in a positive experience at and before school and in their aspirations.[28] Deborah Roseveare, Director of Education and Training at the Organisation for Economic Co-operation and Development (OECD), told us that "the strongest predictor that can be identified of whether someone will drop out of school is the grades achieved at the end of primary school".[29] The Government's memorandum to our inquiry dwelt at some length on the steps being taken to improve opportunities for all children to learn from the outset, whether through investment in early years education for the most disadvantaged 2 year olds, curriculum reform, a closer link between disadvantage and pupil funding (through the pupil premium) or greater recognition of the value of early intervention.[30] Whether or not these policies prove to be successful in increasing subsequent levels of engagement by children in and beyond school, we acknowledge their relevance; but we do not assess their impact in this Report.

ENGAGEMENT DURING SCHOOL YEARS

24. In most schools there are children aged 12 or 13, or sometimes even younger,[31] who show little enthusiasm for "academic" learning and who see school as an irrelevance. Some of these will become persistent absentees and will drop out altogether, showing up in due course as a statistic in figures for young people not in education, employment or training. Improving engagement in learning for these children, while a desirable aim in itself, could also lighten the task (and reduce the cost) of drawing disengaged young people back into education or training once the age of participation is increased.

25. At issue is the way in which children spend their time in learning. The Government has announced a major review of the National Curriculum, which is to be slimmed down "so that it properly reflects the body of essential knowledge which children should learn". The aim is to allow schools the freedom to "develop approaches to learning and study which help us to catch up with high-performing education nations".[32] While the purpose behind the review is clear, and we shall watch with interest the progress of the review, a different approach, more outward-facing and more clearly related to work and financial independence, is needed for children disenchanted with academic learning in a school setting.[33]

Vocational learning at age 14-16

26. Vocational GCSE courses have been taught in schools for some years; but, as Professor Wolf observed in her recent report on vocational education,[34] there has been a rapid expansion in the number of pupils aged 14 and 15 following more vocational, non-GCSE courses. While Professor Wolf had major reservations about the worth of many of these qualifications, the principle of introducing greater variety of opportunities for vocational study during years of compulsory schooling, often through joint working between schools and colleges, has been established. Peter Lauener, Chief Executive of the Young People's Learning Agency, told us that he believed that there was a lot more collaboration between schools and colleges than a few years ago, as well as signs of funding mechanisms being put in place by schools and colleges to pay for "the one or two days per week that young people might be spending out of a school environment in a college environment".[35] We note also the Department's statement in its response to Professor Wolf's review that it wished to see more young people being offered the opportunity to enrol in colleges before they reached the age of 16, and that it would communicate this view to all schools and colleges.[36]

27. However, we received evidence that "reductions in school funding" and changes to performance measurement were leading to a fall in vocational learning in colleges by 14 to 16 year olds, with some colleges reporting a reduction of about 80% from its peak.[37] Martin Doel, Chief Executive of the Association of Colleges, confirmed that numbers of 14 to 16 year olds attending college were in decline.[38]

28. The range of options for more vocationally-weighted learning for 14-16 year olds is expanding, with the introduction of studio schools and University Technical Colleges:

  • In Studio Schools, pupils aged 14 to 19 study the national curriculum through mainstream qualifications (including GCSEs). Part of each week is spent in work placements (paid for 16-19 year olds). The first studio schools opened in September 2010.
  • In University Technical Colleges, formed through partnerships between universities, colleges and businesses, study also begins at 14, recognising that "students who know what they want to do can often become bored at school and so underachieve by the time they are sixteen".[39] Between the ages of 14 and 16, the split of time between general education/bridging core studies and technical studies is 60:40. One University Technical College has opened: at least ten more are being developed, and the 2011 Budget set out a commitment to expand the programme and establish at least 24 new colleges by 2014.[40]

We acknowledge the Government's support for the expansion of University Technical Colleges, which we see as a bold experiment in providing learning opportunities for young people motivated by a more practical curriculum.

Specialisation

29. Professor Wolf was opposed to any significant specialisation before the age of 16, arguing in favour of a common core of study at Key Stage 4, with vocational specialisation normally confined to 20% of a pupil's timetable. As an example of supporting evidence, she cited a submission to her review from the TUC, which believed that the aim should be to ensure that all young people have both a broad general education and a practical education up to the age of 16, and that "the key point is to avoid making irrevocable decisions too early".[41] It could be argued, however, that the English system in fact delays specialisation by comparison with some other developed countries: educational paths in the Netherlands, for instance, diverge at the age of 12, with a core curriculum supplemented by a large element of school-based vocational education in certain types of school.[42] In evidence to our inquiry, Professor Unwin also questioned whether some of the vocational courses followed in England at Key Stage 4 would be recognised elsewhere as being truly vocational.[43]

30. Professor Wolf developed her argument by noting that:

    Claims are often made that vocational options motivate young people more and therefore lead to them achieving higher grades in their other subjects; and that such options also stop them from dropping out and becoming 'NEET' ... this might suggest that a larger share of time should routinely be allocated to vocational options for some students.

However, she found no indication either in existing research literature or in analyses carried out for her Review that Key Stage 4 students (whether generally or specifically "at risk of disengagement") made substantial improvements in their general attainment as a result of taking more vocational courses. As she herself noted, these findings are "profoundly counter-intuitive for many people involved in high quality vocational provision". [44]

31. Martin Ward, representing the Association of School and College Leaders, agreed that over-specialisation at 14 was "not a good thing"; but he warned that moving away from more vocational courses in the 14-to-16 phase of education "may make it more difficult to motivate and keep engaged some of the young people in that age band". He added that "If they are obliged to do a narrowly defined academic course and nothing else, we may find they reach 16 all the more likely to want to leave".[45] Joanne McAllister, a 16-19 Commissioning Adviser working for Cumbria County Council, agreed that vocational education for 14 to 16 year olds had been "a very useful tool" and that there had been "significant" progression to post-16 courses.[46] The Hull College Group noted that secondary schools "consistently report that attendance and behaviour improves for those pupils who attend off-site education and training that they are fully engaged in".[47]

32. We have not considered in detail the research evidence summarised by Professor Wolf on page 110 of her Report, which underlies her conclusion that vocational study at the age of 14 to 16 has no discernible effect on attainment at the age of 16 or later. However, we make three observations:

  • The location of study during Key Stage 4 may make a difference to subsequent retention and attainment, given some children's antipathy to a school setting, and it is not clear whether the existing research base takes this into account;
  • The quality of teaching (and of the course followed) can be expected to have a bearing on retention and attainment, and Professor Wolf herself was critical of the value of some vocational courses;
  • An absence of any indication that vocational study at the age of 14 to 16 makes an appreciable difference to students' staying-on rates at the age of 16 does not necessarily show a neutral effect: it may represent an improved rate of participation post-16 for those who would have been at risk of "disengagement" had they not followed a more vocationally-weighted curriculum at the age of 14.

33. This is an issue so central to the improvement of participation at and beyond the age of 16 that a comprehensive, solid and up-to-date research base should be established. We recommend that the Government should commission further research to assess the effect of applied learning and vocational study at age 14 to 16 upon participation in education and training at age 16 to 18. That research should take into account the location of study, and experience from a range of vocational courses.

34. While we would not want to encourage over-specialisation at Key Stage 4, we recommend that the Department should consider whether a 40%/60% split between time spent on specifically vocational or technical study and on core academic curriculum would best suit 14 year olds who take up vocational options while at school.

Young Apprenticeships

35. Young Apprenticeships, which have run since 2004 as a pilot scheme, offer motivated and able 14-16 year old pupils the opportunity to take industry-specific vocational or vocationally-related qualifications alongside GCSEs. Pupils study the core curriculum; but two days per week are spent on studying for vocational qualifications, and 50 days over the two years are spent in the workplace. The Department confirmed in March that the pilot would end "due to the high delivery costs which are not justified in the current economic climate".[48] Funding for new starts on Young Apprenticeships ceased in January 2011, although funding for existing Young Apprentices will be available in 2011-12 and 2012-13 (£15.3 million and £4 million respectively).[49]

36. The National Foundation for Educational Research undertook an evaluation of outcomes for students who began the Young Apprenticeship programme in 2006. The Foundation found that:

  • 78 % of all Young Apprenticeship participants had achieved five or more A*-C GCSE grades or equivalent, compared to 64% of all learners nationally
  • Learners who completed Cohort 3 of the programme gained significantly more points in total (94 points more) at the end of Key Stage 4 compared with similar learners in the same schools who had not participated in the programme
  • Of those who had completed the programme and for whom the destination was known, the majority (95%) progressed into further education or training, and 19% had progressed into an Apprenticeship.[50]

37. The programme was praised in evidence to our inquiry. The Merseyside Colleges Association said that it "provides a well-developed, successful model … as part of promoting vocational education, training and as a feeder route to full apprenticeships with exposure to employers and the workplace".[51] The Hertfordshire 14-19 Partnership[52] also supported the pilot, saying that the programme "needs to be fully recognised as a valued and extensive experience of a vocational sector" and that programmes "have provided young people with the opportunity to experience practical learning as a pathway and enable them to have a wide choice of post-16 options".[53] Peter Lauener, Chief Executive of the Young People's Learning Agency, said that the results of the pilot had been "terrific", that it had been popular with young people and that achievement rates were good. He confirmed, however, that it was an expensive programme, as participants were funded on top of their per pupil allocation to schools.[54]

38. We accept that the cost of the Young Apprenticeship programme is currently difficult to fund, despite its impressive results. We acknowledge that there is some evidence of effective joint working between schools and colleges to provide vocational study opportunities for 14 to 16 year olds; but this appears to be in decline, for financial reasons. The success of Young Apprenticeships suggests that high quality vocational training for 14 to 16 year olds can raise engagement and academic achievement, and we urge the Government to consider how best to build on this model.

WHAT SORT OF PROVISION WILL YOUNG PEOPLE NEED?

Alternative forms of support

39. It is clear to us that many of those who will be brought into education or training by the 2008 Act will need flexible learning provision, quite possibly in an informal setting.[55] A formal study setting such as a school—or even a college—will have negative connotations for those who did not prosper at school and who may have dropped out. For such people, online or 'distance' learning is likely to have greater appeal. Centrepoint, a national charity working with young homeless people, described for us a proposal for a 'college without walls': this would combine in-college and online learning so that young people would have the flexibility of online modules together with the more intensive support of face-to-face teaching. The 'college without walls' would hold the budget, allowing young people to complete modules at different institutions and at different times.[56]

40. Voluntary sector bodies have proven expertise in offering the sort of intensive—even one-to-one—support which some young people will need in order to regain confidence, develop aspiration and re-enter some form of learning.[57] Joanne McAllister[58] saw a role for the voluntary and community sector in preparing young people for the college environment, supporting them in the first few weeks on a course.[59] Anne-Marie Carrie, Chief Executive of Barnardo's, gave us examples of programmes run by Barnardo's which were designed to address low motivation, for instance by providing travel to and from college.[60] However, this type of support can be expensive,[61] and we were told that although there was potential for the voluntary sector to play a much greater role in this respect, the funding system made it very difficult for voluntary sector providers to do so.[62]

41. The Government intends to review the funding formula for institutions offering courses for 16 to 18 year olds "to see how it can better support the Coalition Government's aims of transparency and fairness" and, in particular, "how targeted support for 16 to 18 year old learners can be aligned with the pupil premium for pre-16s".[63] The forthcoming review of funding for post-16 learning should recognise the higher cost of supporting learning by young people lacking motivation or confidence; and the future funding mechanism should enable all providers, including voluntary sector bodies, to offer the learning opportunities which are required.

Flexible course start dates

42. Flexibility of start dates was clearly an issue for many who were leading disrupted or unsettled lives. Ms Carrie gave as an example a young person released from a young offenders institution being given only 24 hours' notice of the accommodation which they would occupy when released. She added that such people would have to wait until the start of the next term before they could start a college course and said that "there is no flexibility in start and end dates, in terms of when young people can enter individualised programmes".[64]

43. We were told that the "lagged learner funding" model used by the Young People's Learning Agency (YPLA) to fund college provision could deter colleges from offering mid-year starts on courses. The decision to introduce "lagged funding" as a means of calculating allocations to colleges—essentially taking the previous year's learner numbers as a basis—was taken in June 2010, and details were set out in the YPLA's Funding Statement for 2011-12, published in December 2010. Jane Machell, the Principal of Alton College, said that using "lagged learner numbers" allowed "no flexibility to do any January or mid-year starts" and "no flexibility for any additional specific things that you might want to put on for youngsters in the following year".[65]

44. Local authorities also commented on the effects of lagged funding models: the City of York 14-19 team said that raising the participation age required "new strands of provision" but added that "we have no real ability to facilitate immediate changes in the pattern of provision because of the total reliance on lagged numbers as a basis for allocating funded places to providers". It implied that schools and colleges were in a position to be more accommodating:

    "A school or college can "smooth out" the budgetary implications of offering new provision which attracts new learners (it will receive the funding the following year) when funding rates at per learner level are consistent. However, a small voluntary organisation or new training provider able to offer small scale but valuable provision in an RPA context cannot.[66]

LEACAN[67] similarly spoke of "the lack of willingness of providers to expand or amend provision to meet demand when constrained by funding based on historic numbers and historic Standard Learner Number ratios".[68]

45. The Association of Colleges took a more nuanced view. Martin Doel, Chief Executive of the Association, told us that 'lagged funding' was "the least worst system you can come up with": it allowed stability and mitigated peaks and troughs, but it did mean that, for mid-year starts, "you could be waiting for the money for the student you have taken on in January for a full 18 months". He believed that it was a model which was "fundamentally right" but that it needed "some sensible refinements".[69]

46. We note that the Statutory Guidance on Funding Arrangements issued by the Young People's Learning Agency in December 2010 said that recruitment through the 2010-11 academic year and flexible start dates would be taken into account in calculating allocations to colleges for the 2011-12 academic year.[70] The Association of Colleges told us that YPLA officers had in some cases made adjustments to college funding where colleges could show that they had significantly increased the number of in-year enrolments.[71]

47. We are not convinced that the "lagged learner funding" mechanism currently used by the Young People's Learning Agency as a basis for funding learning providers necessarily prevents flexibility in course starts. We welcome the Agency's willingness to adjust funding for colleges in 2011 to reflect significant increases in in-year enrolments. We recommend that the Agency should indicate as soon as possible whether it intends to use lagged student numbers as a basis for calculating allocations to colleges for study in 2012; and we encourage it to confirm at the same time that it will continue to recognise in its funding allocations significant rates of in-year enrolment in individual colleges.

Entitlement funding and its effect on learning provision

48. The complex funding formula for 16-18 year olds has various elements. Besides funding per learner, colleges, schools and training providers receive "entitlement funding" for activities or practices which enhance learning. Entitlement funding may be used to provide tutorials, additional courses, careers support, pastoral support, health advice, and "enrichment" activities such as sport and arts activities.[72] The Young People's Learning Agency (YPLA), in its Funding Statement for 2011/12, announced a reduction in entitlement funding from 114 to 30 guided learning hours per learner. In a question and answer paper accompanying the Funding Statement, the YPLA recognised that "for those with lower prior attainment, the entitlement funding provides valuable tutorial and learning support that persuades them to engage and remain in learning and enables them to progress". However, it then added simply that "30 hours per learner is retained so that this can continue".[73]

49. College principals have registered dismay at the reduction in entitlement funding. Dr Elaine McMahon, Chief Executive and Principal of Hull College Group, told us that "some students have a need for more support. If the entitlement money goes from support areas, we struggle to make those students able to be motivated sufficiently and to meet their needs".[74] In a letter to the Times Educational Supplement in January this year, Asha Khemka, the Principal and Chief Executive of West Nottinghamshire College wrote:

    Tutorials are a fundamental part of colleges' learning programmes and are often the 'glue' that holds the various aspects together. They are integral to teaching and learning, contributing to learner retention, achievement, success and progression. Similarly, enrichment activities such as vocational trips act as incentives for learners, keeping students motivated and interested and preparing them for the world of work and higher education. Reducing these life-enhancing experiences will demotivate students and, at worst, harm their employment chances.[75]

In discussions during oral evidence on engagement and raising the participation age, Martin Ward (Deputy General Secretary of the Association of School and College Leaders) said that

    the last few are much more difficult to engage and retain than the first few, and are much more expensive. The issue becomes one of support, monitoring and mentoring at a much greater and more intense level than may be necessary for some of the other students. That is expensive ... The loss of that enrichment funding will clearly make it that much more difficult for schools and colleges—it may well be colleges in particular—to engage with this group of students.[76]

This statement was echoed by Mr Doel, Chief Executive of the Association of Colleges.[77]

50. The YPLA points out in the Funding Statement that £150 million of the savings from reducing entitlement funding will be redirected through the "disadvantage uplift" element of the funding mechanism, paid in 2011/12 for young people "that live in the most disadvantaged areas of England[78] and those who are disadvantaged by other circumstances".[79] Ministers have justified the reduction in entitlement funding by saying that the Government's first priority was to protect the core education programmes which are offered by schools and colleges and which deliver "the real benefits to all young people" and which enable them to progress into higher education or employment.[80] We note that no formal assessment was made by the Department of the effects of reductions in funding for student support services in colleges and schools.[81]

51. The severe reduction in entitlement funding for colleges will limit provision of tutorials and access to enrichment activities. We acknowledge Ministers' desire to target funding on the most needy and we note that £150 million of the savings will be redistributed through 'disadvantage uplift'; but we do not accept that the activities and services supported by entitlement funding are necessarily needed more by those who benefit from 'disadvantage uplift'; and we are not convinced that they should be targeted to the extent proposed by the Young People's Learning Agency. The quality of the universal offer is likely to decline once entitlement funding is reduced, and student motivation, retention and achievement may suffer.

52. The Government has said in its response to Professor Wolf's report that there is a need for radical change in funding for 16-19 education "to remove perverse incentives for colleges to accumulate qualifications rather than provide sensible, balanced and broad programmes of study".[82] This is a highly complex area and, as the Chief Executive of the Association of Colleges told us, "when you start moving bits around in this formula, the law of unintended consequences applies very quickly".[83] The Department's forthcoming review of the funding formula for 16-19 learning should, in assessing the value of every aspect of provision (including qualifications), consider the case for restoring a higher level of entitlement funding.

Impact on schools and colleges

53. The widely-held expectation among those who submitted evidence to our inquiry was that young people brought into education and training by the introduction of compulsory participation would favour vocational courses or employment-based training above study at school.[84] As Mick Fletcher, an independent consultant and author of a policy paper on the EMA[85] told us, "a selective sixth form or sixth-form college is not going to notice it happening. The issue is concentrated in general further education colleges and among those specialist, independent and voluntary sector providers which work with young people who are not engaged in education".[86] The Training and Development Agency took a different view and suggested that because of "the current recession", young people would be less likely to move into employment or Apprenticeships and would choose instead to remain in education.[87]

54. The Funding Statement for 2011/12 published by the Young People's Learning Agency in December 2010 forecast that there would be 62,000 additional places in learning by 2014/15, compared to the number funded in 2010/11. Given that the YPLA estimates that just under 1.6 million young people were in learning in England in 2010/11, the 62,000 additional places would represent a percentage increase of about 3.9% in learner numbers by 2014/15.

55. Where there is more demand for courses in schools and colleges once the age of compulsory participation is raised, it may be that extra provision will need to be mainly at Level 2 or below. It was suggested to us that in rural areas, where post-16 learning provision is chiefly in school sixth forms, typically studying A levels, schools would need to broaden their offer so as to provide for 16 and 17 year olds of relatively low attainment who were not attracted to study at college because of the long journey time (and possibly expense) involved.[88] Joanne McAllister also indicated that there was a lot of work still to be done in schools to prepare for 16 year olds who were not ready to study courses typically followed in sixth forms.[89]

56. Schools and colleges will also need to be sensitive to the needs of children who have not necessarily followed a mainstream curriculum up to the age of 16, such as children who have been home-educated, or those who have attended alternative provision or are from abroad. Any such children who study at school or college post-16 might not have the qualifications to satisfy the formal entrance requirements, for instance because of difficulties faced in taking exams as private candidates.[90]

57. There is likely to be an impact on staffing requirements and other resources; but we were told that schools showed "very different levels of preparedness".[91] The Training and Development Agency (TDA) also noted "variable" states of readiness, with "little evidence of preparation" in some areas, including a lack of information or understanding of curriculum changes flowing from the English Baccalaureate and the Wolf Review of Vocational Education, changes to school infrastructure, post-16 funding methodology, or teacher supply and demand.[92] The TDA predicts that raising the participation age is likely to increase the demand for qualified teachers both in schools and in the further education sector, but it is says that it is currently not possible to comment on the scale of that increase. It nonetheless expects that there will be greater demand for subject specialists, to meet the needs of expanded sixth form provision, and for teachers with vocational knowledge and competence.

Data transfer

58. Some 16 and 17 year olds who will be newly drawn into education or training from 2013 onwards will have particular educational or behavioural needs; yet we heard that, in the past, colleges had not always received from schools the sort of advance information about individual pupils which would enable them to put in place suitable provision and support. David Wood, Principal and Chief Executive of Lancaster and Morecambe College, said that:

    The second thing for me is understanding the previous education of the young person. When they come to us, I need to know what their needs are based on their performance, what their issues are and whether they have any specific needs which I need to cater for in my own institution. Very little of that information follows the learner currently. I would want to see far better information passed from schools to FE, so that I can make better representation for my young people ... There is no doubt that if we got earlier information we would be able to put the support in earlier to make sure those vulnerable people were picked up much earlier, before we come to September, and guide them into our system.[93]

Jane Machell, Principal of Alton College, made the same point, although she stressed that there was a flow of information from some schools: it depended upon the school's leadership.[94]

59. We raised this issue with Ministers, who agreed to consider it. Lord Hill subsequently told us that there is a statutory requirement for a maintained school or non-maintained special school to transfer a pupil's curricular record to another school or to a further education institution or higher education institution, upon receipt of a written request. However, a parallel statutory requirement to transfer a pupil's Common Transfer File and educational record[95] applies only when a pupil moves from one school to another, not when he or she moves from a school to a further education or higher education institution. Even where schools want to transfer the data and have the consent of the young person to do so, the transfer is complicated by FE and HE institutions' lack of access to the Department's secure school-to-school data transfer system.[96]

60. In our view, there are unjustified inconsistencies in the requirements upon schools to transfer a pupil's Common Transfer File and educational record. We recommend that the regulations on transfer of pupil information be amended, so that further education and higher education institutions are entitled to receive the Common Transfer File and educational record relating to any pupil being admitted. We recognise that colleges do not currently have access to the secure system used for the transfer of such data and that work would need to be done to allow this. In principle, however, security of data transfer considerations should not be allowed to impede the free flow of information on individual pupils' needs from schools to colleges and higher education institutions, where this is to the benefit of the pupil.

Impact on employers and training providers

61. The Green Paper published by the previous Government in 2007, setting out the rationale for raising the age of compulsory participation, included projections for numbers of young people in different forms of learning, running from 2005/06 to 2016/17. In absolute terms, the largest projected increase was in the combined further education and higher education sectors: 48,000 16 and 17 year olds (an increase from 37% to 46% of the total 16-17 population); but in terms of percentage increase from base, the greatest projected rise was in work-based learning: 45,000 16 and 17 year olds (an increase from 7% to 12% of the total 16-17 population).[97] Several of those who gave evidence believed that there would indeed be a preference for work-based learning among 16 and 17 year olds required to participate in education or training.[98] The attraction of this option could stem from an aversion to formal study settings or from an over-riding concern for financial independence, best achieved through employment as an Apprentice or through training clearly related to job opportunities.

62. SEMTA (the sector skills council for the science, engineering and manufacturing technologies) described the Green Paper's projections as "alarming", largely because of the pressure such an increase would place on employers and on the Apprenticeships programme. SEMTA told us that there was a danger that work-based learning was "viewed as a 'dumping ground' for those incapable of appropriate level learning, or unwilling to learn at all". It also reported employers' concerns that programmes which they used and trusted (such as Apprenticeships) "might be compromised if they were changed to accommodate low achievers and the disaffected".[99] We look at Apprenticeships in more detail in Section 4 of this report.

Impact on local authorities

The local authority role

63. Local authorities have a duty under section 41 of the Apprenticeships, Skills, Children and Learning Act 2009 to "secure that enough suitable education and training is provided" to meet the needs of people in their area who are over compulsory school age but under 19. This is complemented by a requirement under section 85 of the Education and Skills Act 2008 to promote co-operation between the authority, its partners and others regarding provision of education and training for 14-19 year olds. A further duty on local education authorities exists under section 10 of the same Act, to ensure that their functions "are exercised so as to promote the effective participation in education or training" of those subject to compulsory education or training. This section has yet to be brought into force.

64. Local authorities have begun to plan how to discharge their responsibilities in preparation for the raising of the participation age. The 14+ Learning and Skills Strategic Team from Devon County Council, for instance, described to us its preparatory work: convening meetings attended by Connexions, representatives of further education institutions and other providers colleagues; sharing NEET figures; exploring "broad engagement issues"; and disseminating best practice.[100] Sixteen local authorities took place in a first phase of trials to develop knowledge and good practice in advance of the raising the participation age, each focusing on one of three specific areas: securing a full offer of information, advice and guidance; identifying and re-engaging 16 and 17 year olds who disengage from learning during the year; and developing area-wide strategies to enable full participation. An evaluation of Phase 1 of the trials has been published;[101] and an evaluation of a second phase is expected shortly.[102]

65. Joanne McAllister, speaking on behalf of Cumbria County Council, thought that the Council's role, for the moment, could only be one of facilitation, influence and persuasion, particularly as it did not control funding;[103] and this view was echoed by others. LEACAN[104] saw their role in co-ordination role as "vital" and listed functions: bringing partners together, co-ordinating data and audits of provision, working with national agencies such as the National Apprenticeship Service, the YPLA and the Skills Funding Agency, developing the market, and providing a leadership role.[105]

66. Peterborough City Council's 8-19 Service described difficulties which it faced in co-ordinating provision. One area of particular frustration flowed from schools' conversion to Academy status: four out of eleven secondary schools in the local authority area are already Academies, with two more potential conversions in the offing. The Council said "it was difficult to maintain a city-wide strategic view if we only have access to data on the local authority-maintained sector". It added that the Academies in the city "almost without exception" provided only Level 3 courses, whereas the city's needs for learners aged 16 or above were predominantly for Level 1, Level 2, and FE provision.[106]

67. Martin Doel, Chief Executive of the Association of Colleges, told us that although the legislation was in place, local authorities "do not have the wherewithal or the mechanisms to do much about it, particularly since more Academies have formed". He saw the local authority role as moving towards one of championing on behalf of local people and their needs, in order to ensure that there is a breadth of provision.[107] Martin Ward, speaking on behalf of the Association of School and College Leaders, told us that schools and colleges felt that they were in the strongest position to make sensible decisions about what learning provision there should be for this group of young people, and they were therefore "very reluctant to see the local authority directing them to do certain types of work". He suggested that local authorities could have a moral leadership in saying "Come on, folk, we have this group of young people who are not being served and somebody has got to do something about that"; but he suspected that institutions' decisions on whether or not to come forward to do something about that would "depend much more on the funding mechanism than upon the moral pressure".[108]

68. Local authorities will continue to be frustrated in the exercise of their role in promoting co-operation in provision of education and training for 14 to 19 year olds if they have no levers to exercise control. The Department's policy, as articulated in The Importance of Teaching, recognises that local authorities "have an indispensable role to play as champions of children and parents, ensuring that the school system works for every family and using their democratic mandate to challenge every school to do the best for their population". In time, the Government expects that local authorities will take on more of a strategic commissioning and oversight role.[109] Further work needs to be done to clarify how this more strategic role would be exercised and when it would start, and what the implications would be for local authorities' activities in support of the increase in the compulsory age of participation. In July 2010, the Secretary of State established a Ministerial advisory group on the role of the local authority in improving the lives of children, young people and families, and how that role might need to change over the next few years.[110] We recommend that the Secretary of State's Ministerial Advisory Group should consider, as a distinct work strand, local authorities' roles in supporting the raising of the participation age, and whether statutory powers are required to enable them to make a meaningful contribution.

Enforcement of the raised participation age

69. The Education and Skills Act 2008 provides a mechanism to enforce the raising of the participation age and, if necessary, punish those who defy the statutory duty. If a local authority concludes that a person subject to the participation requirement and belonging to the local authority area is failing to participate, it can issue an attendance notice naming a course or other placement which that person must attend. The young person can appeal: that appeal is heard and determined by an attendance panel established by the local authority. Failure to comply with an attendance notice not rescinded on appeal is punishable by a fine.

70. The Department for Education has included in the Education Bill now before Parliament a clause which would make it possible for Ministers to delay the commencement of the enforcement mechanism, without disturbing the duty to participate. The Impact Assessment prepared by the Department set out the rationale, saying that "there are concerns that powers given to local authorities ... may be used inappropriately, at least initially ... a vulnerable young person could enter the enforcement system when, in fact, they have a barrier to learning". Any delay would be "until we are sure that the system has the capacity to use the powers appropriately and minimise the costs they will entail".[111]

71. Some local authorities which have responded to the Committee's call for evidence noted the intention to delay the introduction of an enforcement mechanism but questioned what levers there would be, in that case, to ensure participation by those who choose not to engage.[112] The NASUWT feared that unscrupulous employers would take advantage of the lack of an enforcement mechanism to deny 16 and 17 year olds time away from work to attend education or training;[113] and the Association of School and College Leaders, while supporting the removal of penalties, reported that its members believed that the voluntary nature of the new provisions could increase the number of young people not in education, employment or training.[114]

72. Evidence from other developed countries suggests that compulsion is not an essential element of participation.[115] Many, such as Australia, the Czech Republic, Finland, France, Japan and Korea achieve rates of more than 90% participation beyond the age of compulsory participation.[116] However, the OECD Jobs for Youth (UK) study in 2008 cited "international evidence ... that if there are no mechanisms in place to enforce the participation requirement, as has been the case in some US states and in New Brunswick in Canada, the policy only has a small effect".[117]

73. We asked Ministers what plans the Government had for those young people who refused to participate in education and training. Lord Hill told us that the Department was working together with the Department for Business, Innovation and Skills and the Department for Work and Pensions on a participation strategy which would address "the specific NEETs issue". He added that local authorities had duties to "identify, report, target and work with the voluntary sector" in this field, and he was satisfied that local authorities used their powers to do so.[118] The implication, therefore, is that the Government is content to go gently in coaxing young people into education and training.

74. Despite some local authorities' questions about how to achieve compulsory participation in the absence of an enforcement mechanism, the current Government's policy does relieve local authorities, even if only temporarily, of a burden. The Leeds 11-19 Learning and Support Partnership, for instance, said that the local authority (which is represented on the Partnership) was "particularly concerned by the potentially enormous cost of implementing the enforcement duties" as set out under the 2008 Act.[119] The National Association of Head Teachers pointed out that local authority attendance officers would be likely to be involved in any statutory enforcement process, yet there were signs of a "diminution of attendance officer support as budgets come under pressure".[120]

75. We accept that the cost of using powers under the Education and Skills Act 2008 to enforce the increase in the age of participation could turn out to be disproportionate to their effectiveness. We therefore agree with the decision to delay introduction of those powers, but we believe that a formal review should take place as soon as the level of compliance with the duty to participate becomes clear.


5   See section 8 of the Education Act 1996. A child who attains the age of 16 after the last Friday in June also ceases to be of compulsory school age if their 16th birthday occurs before the start of the next school year. Back

6   Half-days Back

7   Pupil absence in schools in England, including pupil characteristics: 2009/10, DfE Statistical First Release 03/2011 Back

8   See Section 173 (10)(b) of the Act Back

9   Sections 8,10 and 11 of the Education and Skills Act 2008 Back

10   Cm 7065 Back

11   The Coalition: our programme for government, May 2010 Back

12   Spending Review 2010, Cm 7942, paragraph 2.4 Back

13   Education at a Glance 2010, OECD, Table C1.2 Back

14   Off to a Good Start? Jobs for Youth, OECD, 2010, page 28. Figures based upon individual countries' labour force surveys, which may not be compatible with each other. Youth was defined as 15-24 except in five countries (including the US and UK) where it was defined as 16-24. Back

15   People in this group received no training while in employment in the four weeks before the survey Back

16   Equivalent figures for 1999 were 40,600 (16 year olds), 42,500 (17 year olds) and 62,400 (18 year olds), totalling 145,500: 7.0% of the 16-17 age cohort and 8.1% of the 16-18 cohort. All figures taken from annual Statistical First Release series, which is regarded as "the primary source of national data on 16-18 year olds NEET": see DfE Statistical Release OSR 10/11, NEET Statistics-Quarterly Brief, May 2011 Back

17   See Young people not in education, employment or training, Eighth Report from the Children, Schools and Families Committee, Session 2009-10, HC 316-1, paragraph 5 Back

18   The Transition Information Network reported Connexions Services data indicating that 12% of 16-18 year olds with learning difficulties and/or disabilities were not in education or employment, compared to 6% of those without learning difficulties and/or disabilities: Ev w72. Back

19   Memorandum from the National Audit Office to the Children, Schools and Families Committee, available at http://www.publications.parliament.uk/pa/cm200809/cmselect/cmchilsch/memo/young%20people/m0101.pdf Back

20   Q 2. See also Q 21 Back

21   Young people not in education, employment or training, Eighth Report from the Children, Schools and Families Committee, Session 2009-10, HC 316-1, paragraph 1 Back

22   A New Approach to Child Poverty: Tackling the Causes of Disadvantage and Transforming Families' Lives, HM Government, Cm 8061, April 2011, paragraph 3.45 Back

23   See memorandum from Barnardo's, Ev 112, paragraph 3.5 Back

24   Q 238 Back

25   Q 238 Back

26   Q 239 Back

27   Q 240 Back

28   See for example memorandum from Peterborough City Council 8-19 Service, Ev w92, paragraph 33; also memorandum from Barnardo's, Ev 112, paragraph 3.4 Back

29   Q 111 Back

30   Ev 84-5 Back

31   See Mr Collis, Q 139 and Jane Connor, Q 159 Back

32   HC Deb 20 January 2011 col 47WS Back

33   See Martin Ward Q 185 Back

34   Review of Vocational Education, Professor Alison Wolf, March 2011, page 47 Back

35   Q 284 Back

36   Wolf Review of Vocational Education-Government Response p 11 Back

37   157 Group of Colleges, Ev w25, paragraph 12 Back

38   Q 186 Back

39   See http://www.utcolleges.org/faqs Back

40   Budget 2011, HC 836 (Session 2010-12), paragraph 1.118.  Back

41   Review of Vocational Education by Professor Wolf, March 2011, pages 111 and 107-8 Back

42   See Professor Unwin Q 119. See also The Education System in the Netherlands 2007, Dutch Eurydice Unit, Ministry of Education, Culture and Science, http://english.minocw.nl/documenten/en_2006_2007.pdf Back

43   Q 131 Back

44   Review of Vocational Education by Professor Wolf, pages 108-9 Back

45   Q 184 Back

46   Q 186 Back

47   Paragraph 3.2, Ev 89. See also memorandum by the NUT, Ev w14 Back

48   http://www.education.gov.uk/16to19/qualificationsandlearning/workexperience/a0013457/young-apprenticeships Back

49   HC Deb 21 March 2011 col. 846W Back

50   Evaluation of the Young Apprenticeships Programme: Outcomes for Cohort 3, NFER, November 2010 Back

51   Ev w51, paragraph 8. See also Bill Sutton Q 173 Back

52   Comprised of representatives from schools, colleges, work-based learning providers, Connexions, the University of Hertfordshire and the local authority Back

53   Ev w55, paragraph 25 Back

54   Q 282 Back

55   See memorandum from Helen Roper, secondary curriculum adviser, Ev w83 Back

56   Further information supplied by Centrepoint [not printed] Back

57   See for example memorandum from Fairbridge/Prince's Trust, Ev w96, section 2 Back

58   A 16-19 Commissioning Adviser working for Cumbria County Council Back

59   Q 192 Back

60   Q 238 Back

61   Devon County Council 14+ Learning and Skills Strategic Team, Ev w37 paragraph 3.1 and 3.2. See also submission from City of York Council 16-19 team, Ev w46, paragraph 13; also London Councils, Ev w40, paragraph 20 Back

62   Leeds 11-19 Learning and Support Partnership, Ev w49 paragraph 33.  Back

63   HL Deb 10 January 2011 col WA 413 Back

64   Q 237 Back

65   Q 36 Back

66   Ev w47, paragraph 19 Back

67   LEACAN describes itself as a national network of inspectors, advisers, officers and consultants employed by local authorities in roles with a specific remit for strategic 14-19 planning and development Back

68   Ev w30, paragraph 24 Back

69   Q 196 Back

70   Statutory Guidance: Funding Arrangements for 16-19 Education and Training, Young People's Learning Agency, December 2010, paragraph 27 Back

71   Further information received from the Association of Colleges [not printed] Back

72   See memorandum from the Catholic Education Service for further examples, Ev w9 Back

73   16-19 Funding Statement Q&A, YPLA, paragraph 19 Back

74   Q 45 Back

75   Times Educational Supplement, 14 January 2011 Back

76   Q 192 Back

77   Q 192. See also memorandum from South Thames College, Ev w121, paragraph 2.2 Back

78   In the 27% most deprived super-output areas of the country, based upon the Index of Multiple Deprivation  Back

79   16-19 Funding Statement, Young People's Learning Agency, December 2010, paragraph 11  Back

80   HC Deb, 1 February 2011, col 835 Back

81   HC Deb 23 May 2011 col 458W Back

82   Wolf Review of Vocational Education-Government Response page 8 Back

83   Q 191 Back

84   See for instance Dr Spielhofer Q 238; A4e Ltd, Ev w22, paragraph 4.3 Back

85   Should we end the Education Maintenance Allowance?, CfBT Education Trust, 2009 Back

86   Q 3. See also memorandum from Hertfordshire 14-19 Partnership, Ev w57, paragraph 38 Back

87   Ev w118, paragraph 3.3 Back

88   Memorandum from Helen Roper, secondary curriculum adviser, Ev w82, paragraph 2.3 Back

89   Q 193 Back

90   See memorandum from Fiona Nicholson, Ev w35, paragraphs 43-45 Back

91   Memorandum from Helen Roper, secondary curriculum adviser, Ev w83 paragraph 2.3 Back

92   Ev w116 Back

93   Q 77-8 Back

94   Q 80 and Q 83 Back

95   These record data about pupil achievement, attendance and needs: see Education (Pupil Information) (England) Regulations 2005 (SI 2005/1437). Back

96   Ev 103 Back

97   Raising Expectations: staying on in education and training post-16, Department for Education and Skills, 2007, Cm 7065, Figures 4.2 and 4.3 Back

98   See for instance Mr Collis Q 151; also memorandum from A4e Ltd, Ev w22, paragraph 4.3 Back

99   Ev 96, paragraphs 5,6 and 12 Back

100   Ev w37, paragraph 2.2 Back

101   http://media.education.gov.uk/assets/files/pdf/r/rpa%20phase%201%20evaluation%20report.pdf Back

102   Ev 87. See also HC Deb 10 June 2011 col 505W Back

103   Q 200 Back

104   LEACAN: a national network of inspectors, advisers, officers and consultants employed by local authorities in roles with a specific remit for strategic 14-19 planning and development  Back

105   Ev w28 Back

106   Ev w91-2, paragraphs 20-24 Back

107   Q 198-9 Back

108   Q 200 Back

109   The Importance of Teaching, DfE White Paper, November 2010, Cm 7980, paragraphs 5.28 and 5.42 Back

110   http://media.education.gov.uk/assets/files/pdf/f/future%20work%20programme.pdf Back

111   Overarching Impact Assessment for the Education Bill 2011, page 37 Back

112   For example Devon County Council, Ev w38, paragraph 3.4; Lincolnshire14-19 Strategic Partnership, Ev w33, paragraph 14; Association of Colleges, Ev 75, paragraph 32. See also Mark Corney, Q 4 Back

113   Ev w79, paragraph 26. See also memorandum from Saint John Fisher Catholic College, Ev w4, paragraph 3(a) Back

114   Ev w19, paragraph 25 Back

115   Deborah Roseveare Q 117 Back

116   Education at a Glance 2010, OECD, Table C1.1 Back

117   Jobs for Youth-United Kingdom, OECD, 2008, page 104 Back

118   Q 314 and 315 Back

119   Ev w49, paragraph 2.6 Back

120   Ev w68, paragraph 18 Back


 
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