Q1. Do you welcome the intention to update all qualifications at Access, Higher and Advanced Higher in line with Curriculum for Excellence? Please comment on any implications to be considered.

The Question is clearly loaded and requires an assumption to be made as regards "updating". The requirement for articulation is obvious and accepted. The retention of Higher as a "Gold Standard" is welcomed.

Progression and coherence between courses are essential. There are substantial resource implications for any new National Qualification structure. This latter point has been given insufficient attention.

Q2 Early consultation has identified the 'best' features of Standard Grade and Intermediate qualifications as:

• the 'inclusive' approach to certification contained in Standard Grade; and
• the 'unit based' structure of Intermediate qualifications

Are there any other features in the present Standard Grade and Intermediate qualifications which should be included in the new qualification at SCQF levels 4 and 5? There is an assumption that the best features have been accurately identified. There has from the outset been an assumption that the best features (whatever they are) can in fact be amalgamated.

There is a requirement to completely redraft current unit based assessments (NABs) to create a better consistency across the Curriculum. There will have to be extensive work done by practitioners in this area. As a consequence there are significant resource implications, in particular with regard to the release of staff. Q3 One of the proposals is to grade units. Do you agree that units should be graded A - C rather than pass/fail?

NO. The use of graded units would totally change the nature of unit assessment. Practical issues include absenteeism, administration problem, pressure regarding resits and more. Q4 Do you want graded units to count towards the final award?

The question again makes an assumption that the answer to the previous question is "yes". Such practices might call into question the impartiality of the consultation exercise. Q5 Which option for introducing compensatory arrangements would you most support?

Option A - Extend the range of grading in course awards to grade E.

Option B - Recognise unit passes only.

Option C - Compensatory award at the level of the course studied with no grade awarded.

Option D - Compensatory grade C award at the level of course below that studied

Option E - Compensatory grade A award at the level of course below that studied.

Retain the status quo whereby positive achievement is recognized on the Certificate. Q6 The proposed name for the new award is General (SCQF 4) and Advanced General (SCQF 5). Please indicate if you are content with this suggestion. If not please offer an alternative and explain your choice.

NO. The Proposal for the name is particularly unwelcome. The use of the word "General" (a term used in the current arrangements) can only cause confusion.

There is a clear tautology which teachers find displeasing. Further thought is required.

Q7 Do you agree with the proposal to offer literacy and numeracy awards at a range of SCQF levels (3 to 5)? If not please offer an alternative.

The question again makes the assumption that the proposal for literacy and numeracy awards is acceptable.

It is impossible to support any proposal which might ever label any young person as illiterate or innumerate. This concept cuts totally across the inclusive nature of a modern curriculum.

Q8 National Qualifications at Access 3 (SCQF level 3) do not have an external examination. Do you agree that any new awards in literacy and numeracy at SCQF level 3 should have an external examination?

There requires to be further investigation and thought given to the question "Why assess?" The "level" discussion is irrelevant. We have embedded core skills across the curriculum: these suffice. Q9 Should the weighting between the internal and external assessments for the literary and numeracy awards be equal? If not should more weight be attached to the internal or external assessment? Please explain.

· Option A - Equal weight

· Option B - More weight to internal assessment

· Option C- More weight to external assessment

Irrelevant in the light of earlier responses Q10 When should young people be assessed for literacy and numeracy awards? Please select one option.

Option A - At the end of S3 as part of the summer diet of examinations

Option B - In the December of S4 as part of a winter diet of examinations

Option C - At the end of S4 as part of the summer diet of examinations

Irrelevant in the light of earlier responses.

We would favour a form of formative assessment to allow pupil support needs to be addressed at an earlier stage. Q11 Do you agree with the proposal to allow the study of Highers and Advanced Highers over 12 months, 18 months and 2 years? NO. The proposal is not feasible. It would be unworkable in even the best resourced schools. Q12 Do you agree with the proposal to introduce a winter diet of examinations? NO. The proposal is hopefully optimistic betraying a significant lack of appreciation of the problem inherent in such a suggestion. Q13 If you agree with the proposal to introduce a winter diet of examinations, what subjects and levels of qualifications might first be offered?

Irrelevant in the light of the previous response. Q14 Would you agree with changes to the system which allowed the most able students to bypass qualifications at lower levels and begin study for Highers from S4 onwards? NO. Any such suggestion fails to address how the "most able" are identified. The risks are enormous. Education is not simply the passing of examinations. The development of skills and maturity within our young people is of great importance. There is a total lack of a "safety net" for candidates. They will be under enormous pressure to succeed. It should be noted that the proposed arrangement has been available for 20 years and more and has never gained any form of acceptance.

It is noted again that the proposal is the cheap option. Q15 Do you have any other ideas for increasing flexibility within the senior phase (S4 to S6)?

More teachers, more funding and more available classes.

Q16 It is intended that planning for the new curriculum should commence in 2008/09, with approaches based on the new curriculum introduced from school year 2009/10. This suggests that the new and revised qualifications and any increased flexibilities would be required from 2012/13 onwards to ensure smooth progression between the curriculum and qualifications. Is this indicative timeline realistic? Please comment on any implications to be considered.

NO. The timeline is totally unrealistic. Given the timescale for the publication of the revised "outcomes and experiences", the lack of timetabling models and the current reduction in CPD opportunities, a delay is absolutely essential.

ANY OTHER COMMENTS The use of internal assessment as the sole measure of achievement has a place for the least able: it lacks the validity of external assessment and should be used only where the pressures of external assessment may be too much for the candidate. The rigor of external assessment is totally necessary.

It is noted that the consultation exercise does both directly refer to the study of only up to 5 subjects at the new middle level. There is total opposition to the proposal to restrict curricular choice. The traditional strength of the middle secondary curriculum is being destroyed at a stroke. The consultation exercise should raise the issue.

There are resource implications for any new National Qualification system. The resources for the development of material and the relevant CPD for new courses do not exist.

Teachers currently work well beyond their contractual obligations. The situation cannot be relied upon in the face of unwelcome proposals.