The Scottish Qualifications Authority is also throwing its weight behind the Garrick committee's recommendation that urgent action is required to sort out confusion between the routes from the new Higher and Advanced Higher to degree courses.
The SQA's submission says Pounds 1,000 flat-rate tuition fees would discriminate against students on higher national courses, more than 40 per cent of whom are part-time, when the Dearing report has strongly supported an expansion in the number of students on subdegree courses such as higher national certificates and diplomas.
The further education sector, which is expected to carry the burden of expansion recommended in the Dearing and Garrick reports, has complained that Pounds 1,000 is only 25 per cent of the cost of the average degree but may represent 40 per cent of the cost of a higher national qualification.
The SQA says that, apart from penalising higher national students unfairly, this would discourage mature or part-time candidates from improving their qualifications and lower the uptake of subdegree vocational qualifications among school leavers.
The SQA states: "No fee, or at worst a significantly reduced fee, should be charged to (higher national) students . . . the SQA has particular concern about the need to encourage adult and part-time learners and to remove barriers to these increasingly important groups."
The authority believes that fees for part-time students, who account for nearly 40 per cent of entrants to higher education courses, should be lower "to take account of part-time students' ineligibility for student loans and the contribution they make through the tax system to the education of full-time students".
The SQA also suggests that the answer to the wider problem of student funding should be an entitlement to support for an agreed number of credits irrespective of mode or length of study. It believes this would not only help part-timers but resolve the contentious issue of the differing impact on three-year and four-year degrees.
Brian Wilson, the Education Minister has already pledged that full-time Scottish higher education students, 70 per cent of whom take a four-year degree compared with the three-year norm south of the border, would not be financially disadvantaged by their longer course. The SQA's solution is that the higher education qualifications framework suggested by the Dearing committee be used to establish funded credits for courses irrespective of their length.
Ministers have been keen to concentrate on the educational arguments about the Scottish four-year honours degree to ensure public discussion is not swayed by purely financial considerations. Mr Wilson made this clear at the launch of the Garrick report in July and recently suggested that the four-year honours course was "leisurely". The SQA's submission pointedly reminds him, however, that four-year degrees are common in other parts of Europe and the United States even if they are not in England.
The examination body, which will be responsible for certificating the Higher Still courses, enters a particular plea for the relationship between the Advanced Higher and university entry to be sorted out, in particular the extent of part-year exemptions from degree courses.
The SQA has been working to compare Advanced Highers with A-levels which it believes will help to develop credits for these qualifications within degree programmes. It adds, however, that this work "will not be without its conceptual and practical difficulties".
* The Association of University Teachers has urged the Scottish Secretary not to disadvantage English students studying four-year degrees in Scotland when the charging regime begins next October. It says they should be treated the same as Scottish students who are likely to have their tuition fee waived in their final honours year.