ASCL welcomes the opportunity to contribute to this consultation. We have consulted widely
with our members.

There is much in the consultation that is welcome, however, there are also aspects of the proposals, as set out in the consultation, which concern us.

Our response includes details of the approach we would prefer. This incorporates the proposals in the consultation which we believe are helpful and appropriate, and seeks to address those we feel are problematic. 

Full response to consultation