Finally managed to put in comments on BIS FE consultation - New Challenges and New Chances. This is what I said:
- Adults considering studying in FE need reliable information before considering entering debt to support their study. This is a potential drag on skills acquisition in the economy.
- Whilst repayment of loans is dependent on salary, what evidence is there that median salaries for adults with FE Level 3 qualifications significantly exceed £21,000 pa? Public investment (in providing loans) may never be recovered whilst debt-averse adults decide not to improve their skills because they fear the debt.
- Adults in FE are already co-funding to 50% on much of Adult Learning provision leading to qualifications. They also pay dramatically escalating fees to awarding organisations (often in the private sector).
- It is reasonable to make loans available to adults studying in FE. However, the HE model with its assumptions around age, length of career, lifetime salaries and attitudes to debt is unlikely to succeed in FE.
- It is quite possible that the introduction of loans will significantly reduce take up of qualifications leading to skills just at the point in the economic cycle when they are most needed.
- The introduction of FE loans on this model to adults over 24 for Access to HE courses will create barriers to debt averse working class adults considering Higher Education. This may lead them to abandon an HE ambition or to enrol inappropriately early to an HE course without taking a valuable access route.
- There will be adults from communities where paying interest on loans is culturally prohibited as usury.