Submissions to the consultation, which ends on 1 December, from youth organisations repeatedly criticise the green paper's vagueness on how the reforms will affect the voluntary youth sector.
Children's charity NCH, The Prince's Trust and YMCA England are among the organisations voicing concerns about the position of voluntary youth work in the plans.
Caroline Abrahams, director of public policy at NCH, said: "The children's voluntary sector needs to be used as an agent of change and to be central to the new arrangements."
Leslie Morphy, director of programmes and policy at The Prince's Trust, said: "The voluntary sector is well-placed ideologically to provide the kind of activities that young people respond to. We must not lose them while delivering the essential objective to protect children."
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