Consultation Response Form Consultation closing date: 20 August 2013 Your comments must reach us by that date Reformed GCSE subject content consultation If you would prefer to respond online to this consultation please use the following link: https://www.education.gov.uk/consultations Publication Information you provide in your response to this consultation may be subject to publication or disclosure in accordance with the Freedom of Information Act 2000. Confidentiality Please make it clear if you want all/any part of your response to be treated as confidential and explain why. If a request for disclosure of the information you have provided is received by DfE, your explanation will be taken into account, but no assurance can be given that confidentiality can be maintained. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department. Please tick if you want us to keep your response confidential. Reason for confidentiality: Personal data For the purposes of the Data Protection Act, DfE is the data controller for any personal data you supply in response to this consultation. DfE will process all personal data (such as your name, address and any other identifying information) in accordance with the Data Protection Act 1998. In most circumstances, this means that your personal data will not be disclosed to third parties. Please do not: provide information in comments boxes that might identify you unless you are content for that information to be released into the public domain; or provide information in your response that might lead to the identification of other living individuals Name: Dr Steve Tilling Please tick if you are responding on behalf of your organisation. x Name of Organisation (if applicable): Field Studies Council Address: Preston Montford Montford Bridge Shrewsbury Shropshire SY4 5PU Information sharing The Office of Qualifications and Examinations Regulation (Ofqual) is undertaking a parallel consultation on regulatory conditions for GCSEs. Please tell us if you or your organisation has responded or is intending to respond, to Ofqual’s consultation: Yes x Don’t know No Please only respond to the next statement if you have ticked ‘no’ or ‘don’t know’ above: If you provide comments to us that are relevant to Ofqual’s consultation, we intend to forward your responses to them so they can be considered by Ofqual. If you do not want us to do this then please opt-out by ticking the box below: I do not want DfE to forward my response to this consultation to Ofqual Please mark the box that best describes you as a respondent. Academy and/or Free Comprehensive School School Independent School Special School Subject Association Organisations representing teachers State Selective School Sixth Form Only Parent X Young Person Higher Education Further Education Local Authority Teacher Governor Employer/Business sector Awarding Organisation The Field Studies Council (FSC) is an education charity committed to bringing environmental understanding to all. It currently welcomes 145,000 visitors every year on courses to its national network of 17 Field Centres. These include groups from nearly 3,000 schools, colleges and universities. Established in 1943, FSC has become internationally respected for its national network of education centres and is the UK’s leading provider of curriculum focused field courses. FSC provides informative and enjoyable opportunities for people of all ages and abilities to discover, explore, be inspired by, and understand the natural and built environment. We believe that the more we know about the environment, the more we can appreciate its needs and protect its diversity and beauty for future generations. We feel that fieldwork should be a vital element of an imaginative and contemporary education. www.field-studies-council.org If you have an enquiry which is related to the DfE e-consultation website or the consultation process in general, you can contact the Ministerial and Public Communications Division by e-mail: consultation.unit@education.gsi.gov.uk or by telephone: 0370 000 2288 or via the Department's 'Contact Us' page. Questions 1-6 below ask you to give your views with reference to a specific subject suite: 1. 2. 3. 4. 5. 6. English, Mathematics Sciences Geography History Modern and ancient languages. You do not need to give answers for all the subject suites - please answer only with respect to those subjects on which you have a particular view. Please ensure that you answer questions 7-11 as well – we would like responses from everyone on those. 1. English, including English language and English literature 1a Do the proposed subject content and assessment objectives for English, which includes English language and English literature, cover the appropriate knowledge and understanding for GCSEs in these subjects? Yes Not Sure Comments: No comment. No -insufficiently demanding No- overly demanding 1b Is the relative weighting of the assessment objectives right for English, which includes English literature and English language? Yes No Not Sure Comments: No comment. 1c Has the right practical content for English language been identified to allow students to gain the skills to progress in the subject, beyond the content which can be examined externally and reliably included in the GCSE grade? Yes Comments: No comment. No Not Sure 1d Do the proposed subject content and assessment objectives for English, which includes English literature and English language, provide assurance that essential knowledge taught at the earlier key stages is built upon and represented adequately? Yes No Not Sure Comments: No comment. 1e Will the proposed qualifications in English, which includes English language and English literature, secure sound progression for the purposes of further academic and vocational study? Yes Comments: No comment. No Not Sure 2. Mathematics 2a Do the proposed subject content and assessment objectives for mathematics cover the appropriate knowledge and understanding for GCSEs in this subject? Yes No -insufficiently demanding No- overly demanding Not Sure Comments: No comment. 2b Is the relative weighting of the assessment objectives right for mathematics? Yes No Not Sure Comments: No comment. 2c Has the right content for mathematics been identified for high achievers, including those going on to study A levels in science, technology, engineering and/or mathematics (STEM)? Yes Comments: No comment. No Not Sure 2d Do the proposed subject content and assessment objectives for mathematics provide assurance that essential knowledge taught at the earlier key stages is built upon and represented adequately? Yes No Not Sure Comments: No comment. 2e Will the proposed qualifications in mathematics secure sound progression for the purposes of further academic and vocational study? Yes Comments: No comment. No Not Sure 3. Science, including biology, chemistry, physics and combined science 3a Do the proposed subject content and assessment objectives for science, which includes biology, chemistry, physics and combined science, cover the appropriate knowledge and understanding for GCSEs in these subjects? X Yes No -insufficiently demanding No- overly demanding Not Sure Subject aims and learning outcomes Science connections FSC welcomes: the aim to help students to develop curiosity about the natural world, including its relevance to everyday lives. the intention to focus on key ideas relating to sciences which are inter-linked and are of universal application, and the recognition that some of these apply across and between the three sciences. FSC is concerned that the subject content, in physics in particular, does not fulfill these aims. Interdisciplinary approaches characterize much of the most inspirational contemporary science research but the subject content of the three sciences does not emphasise this. Potential ‘outfacing’ linkages could be made (for example) through: food yields (biology) and fertilisers (chemistry) and changes of state (physics); decomposition (biology); efficacy of recycling (chemistry) and national & global energy sources (physics). Many of these connections could be made through extended practicals and fieldwork. Recommendation FSC recommends that an additional bullet is added (immediately following the first bullet), to read: develop awareness and understanding of how key ideas in science may be interlinked with applications across and between the three sciences. Subject content Overall observation The level of content (in length and depth of detail) presented in the separate sciences is inconsistent. This could undermine opportunities to teach across the sciences, and/or for teachers to negotiate ‘off timetable’ activities such as fieldwork visits with colleagues teaching other sciences. Biology FSC welcomes the recognition that ‘biological information is used to help humans improve their own lives and strive to create a sustainable world for future generations’. This is a powerful statement that should be retained. We are concerned that fieldwork is not required explicitly in the biology subject content (or in the overall science subject aims and learning outcomes – see above). Considerable evidence demonstrates that any presumption that fieldwork will be adopted as one of the ‘other learning environments’ is flawed. FSC recommends that the need for fieldwork should be stated explicitly in (at least) the Ecosystems section. For example, the introductory bullet in the Biodiversity sub-section should be amended to read: Carry out a fieldwork investigation into the distribution and abundance of organisms in an ecosystem and determine their numbers in a given area. FSC recommends that the ‘biological challenges of increasing food yields using fewer resources’ sub-section (within the Ecosystems section) becomes a general requirement for all GCSE biology specifications, not (as currently presented) an exclusive requirement for single award biology. This sub-section should be an integral part to delivering the ‘sustainable world’ aim which applies to the whole of biology (see above). Chemistry FSC welcomes and endorses the balance of subject content and the links made to human impacts and management. We recommend that existing content is retained including references to: agricultural productivity; industrial applications; efficacy of recycling; greenhouse gases; climate change; atmospheric pollutants; water resources. We believe that these links will help to deliver the overall science aim ‘to help students to develop curiosity about the natural world, including its relevance to everyday lives’ (see above). FSC recommends that the sub-section ‘Agricultural productivity and the use of nitrogen, phosphorous and potassium-based fertilisers’ (within the ‘Chemicals and allied industries’ section) becomes a general requirement for all GCSE chemistry specifications, not (as currently presented) an exclusive requirement for single award chemistry. FSC believes that the present balance in the chemistry subject content could be introduced by a contextual statement in the introduction, similar to the one made in biology. We recommend that the following statement is included: Chemical information is used to help humans improve their own lives and strive to create a sustainable world for future generations Physics The subject content (including derived units and equations appendices) is twice as long as biology, mainly because it includes over 6 times as much recall. This appears to contradict the science subject aim ‘that there is no expectation that teaching (such) content should be repeated during the GCSE course where it has already been covered at an earlier stage’. FSC recommends that the present level of ‘recall’ is reduced, to create space which can be used for themes and contexts which are weakly represented including sustainability (encompassing the effects of human activity) and earth science. It will also release time to carry out practicals, including fieldwork; these will be squeezed out by an unbalanced emphasis on ‘revision’ which, inevitably, will be largely classroom-based. Integrating human activity will provide opportunities to teach physics in contexts that link to everyday lives, including activities which can take place outside the classroom and laboratory, including fieldwork. This strengthening of the human and everyday context will encourage recruitment to further study, at A level and beyond. This is important; the need for more people with key skills in earth science is a recurring theme in reviews of UK STEM capacity. FSC recommends that an additional sentence is added to the introductory sentence of the physics section, to bring the discipline into line with the introduction and/or content of biology and chemistry. Physical information is used to help humans improve their own lives and strive to create a sustainable world for future generations 3b Is the relative weighting of the assessment objectives right for sciences, which includes biology, chemistry, physics and combined science? x Yes No Not Sure FSC welcomes DfE’s recognition of the critical importance of practical work in science subjects and endorses the 20% weighting given in AO3 and AO4 to experimental skills and methods. We also support the guidance that 10% should be assessed through direct internal assessment. We have recommended in our response to Ofqual in the concurrent GCSE reform consultation that clear and strong guidance should be provided to ensure that this internal assessment includes the collection of primary data and avoids the use of prescriptive and sanitised practical activities which have little educational value in the teaching of science. In short, we would like to see a considerable improvement on some of the approaches used since GCSE coursework and controlled assessments were introduced in 1988 and 2009 respectively. The need for Awarding Bodies to develop assessment which promotes a culture of in-depth teaching and learning and encompasses the breadth of educational experiences gained through fieldwork was one of six main recommendations in the Outdoor Science report, published by FSC for ASE and King’s College London, launched in parliament in January 2011. See: http://www.field-studies-council.org/media/154119/2010_outdoor_science.pdf See also FSC’s response to Q3d. 3c Has the right practical content for science been identified to allow students to gain the skills to progress in the subject? x Yes No Not Sure The use of practicals FSC welcomes the statement that specifications should enable students to develop and apply observational, practical, modelling, enquiry and problem-solving skills. However, FSC is concerned that fieldwork is not mentioned specifically as a teaching and learning approach, either in the overall subject aims for science or in the introductions and subject content in the separate sciences. We recommend that fieldwork is reinstated, as a requirement across all science teaching. Without this it is likely that ‘Outdoor Science’ will continue to decline, and with it the opportunity to explore inspirational science which is presented in contexts that have clear links to everyday lives (including inter-disciplinary issues and themes - see previous section). Recommendation FSC recommends that the third bullet is amended, to read: develop and learn to apply observational, practical, modelling, enquiry and problemsolving skills, in the laboratory, through fieldwork and in other learning environments. 3d Do the proposed subject content and assessment objectives for sciences, which includes biology, chemistry, physics and combined science, provide assurance that essential knowledge taught at the earlier key stages is built upon and represented adequately? x Yes No Not Sure See also FSC response to Q3a. FSC is concerned that the content in physics is unbalanced by an overly prescriptive approach to ensuring progression from earlier key stages. The subject content (including derived units and equations appendices) is twice as long as biology, mainly because it includes over 6 times as much recall. This appears to contradict the science subject aim ‘that there is no expectation that teaching (such) content should be repeated during the GCSE course where it has already been covered at an earlier stage’. FSC recommends that the present level of ‘recall’ is reduced, to create space which can be used for themes and contexts which are weakly represented including sustainability (encompassing the effects of human activity) and earth science. It will also release time to carry out practicals, including fieldwork; these will be squeezed out by an unbalanced emphasis on ‘revision’ which, inevitably, will be largely classroom-based. 3e Will the proposed qualifications in sciences, which includes biology, chemistry, physics and combined science, secure sound progression for the purposes of further academic and vocational study? x Yes No Not Sure FSC welcomes the inclusion of themes linked to environment, its management and human impacts in biology and chemistry. We are concerned that physics is entirely devoid of such links. This will provide a weak foundation for progression into A levels (and HE), but particularly into vocational study where much of the subject is characterised by inter-disciplinary applications in research, manufacturing etc., often in environmental fields. 3f Will the combined science double award provide students with a sufficiently secure basis for progression to A level study of each of biology, chemistry and physics? x Yes No Not Sure FSC recommends that the ‘biological challenges of increasing food yields using fewer resources’ sub-section (within the Ecosystems section) becomes a general requirement for all GCSE science specifications, not (as currently presented) an exclusive requirement for single award biology. This sub-section should be an integral part to delivering the ‘sustainable world’ aim which applies to the whole of biology (see above). 4. Geography 4a Do the proposed subject content and assessment objectives for geography cover the appropriate knowledge and understanding for GCSEs in this subject? x Yes No -insufficiently demanding No- overly demanding Not Sure Subject aims and learning outcomes FSC welcomes the breadth of aims and outcomes and recommends that all are retained. This should include the present focus on ‘illuminating the impact of change and of complex peopleenvironment interactions’ and the developing of students’ competence in using a wide range of geographical investigative skills and approaches. FSC also welcomes the specific references to fieldwork in two of the four enabling statements. We support the recognition that fieldwork is an essential requirement for a fully rounded GCSE geography education. The references to fieldwork provide a coherent progression from the most recent draft National Curriculum Programmes of Study and Attainment Targets (published 8 July 2013). Subject Content Location knowledge FSC welcomes and endorses the requirement to link locational knowledge and context of two countries/regions directly with other subject criteria (for example, ecosystems in science). FSC recommends that the requirement for these cross-curricular links are made explicit in any guidance notes accompanying the GCSE subject content, and are targeted in subject inspection frameworks. Without this encouragement we question whether the links will be made in many secondary schools. Place knowledge Geography in the UK. FSC welcomes and endorses the inclusion of environmental challenges in this section. People and environment: processes and interactions FSC welcomes and endorses the balance and content of this section including the inclusion of issues related to sustainable use and management in Global Ecosystems. Maps, fieldwork and geographical skills FSC welcomes and endorses the requirements that: different approaches to fieldwork should be undertaken in at least two contrasting environments; fieldwork should involve the collection of primary data collected fieldwork data should be subjected to interpretation, presentation, application and evaluation. Assessment Objectives FSC welcomes and endorses the requirement for fieldwork to account for at least 15% of the total weighting (<5% skills; <10% application). We are concerned, however, that assessment will be entirely through external examination – see FSC responses to Q4b & Q4c. 4b Is the relative weighting of the assessment objectives right for geography? x Yes No Not Sure Assessment Objectives FSC welcomes and endorses the requirement for fieldwork to account for at least 15% of the total weighting (<5% skills; <10% application). 4c We are working on options to ensure that fieldwork takes place. One option might be a letter, submitted to AOs and signed by the head teacher and head of geography, which states that fieldwork has taken place beyond the classroom and school grounds. Do you think this would be an effective measure to demonstrate that fieldwork has taken place beyond the classroom and school grounds? x Yes No Not Sure FSC recommends that fieldwork, or some critical elements of fieldwork, should be assessed internally. FSC fully supports the recognition that fieldwork is crucial to the strong role envisaged for geography in the revised and more challenging curriculum at all levels and, therefore, that it should be assessed through identifiable element or elements. FSC does not support the conclusion that the full cycle of collecting, presenting and analysing geographical data (see subject aims and learning outcomes above) can be assessed exclusively through fieldwork questions in final examination paper(s). The present text refers to fieldwork tasks in the final examination papers. This statement is highly ambivalent and in the absence of any further information we are very concerned that inappropriate external assessment approaches could undermine the very rigour that this new curriculum has set out to achieve, in particular the critical role for acquiring high-level skills developed through real ‘hands-on’ fieldwork. Without guidance for Awarding Bodies in particular there is a significant risk that the external examinations which are developed will hinder rather than help in ensuring the development of high quality geography fieldwork, including critical skills such as collecting and analysing primary data, and using and manipulating equipment. FSC accepts that there could be a role for other evidence, such as a verification letter, but not as a replacement for internal assessment, with external moderation. FSC recommends that further research is carried out into the likely impacts on fieldwork provision in schools, including those from more disadvantaged areas, before this is applied. FSC remains unconvinced (for now) that a non-examined letter will be sufficiently respected by head teachers, teachers or parents to ensure that fieldwork is given high enough priority. This conclusion is supported by a joint FSC/BES report (2002) which summarised a workshop involving chief examiners of biology which concluded that “if it’s not examined, it’s not important”. See: http://www.field-studiescouncil.org/media/268879/2002_creating_the_right_balance._delivering_effective_fieldwork.p df A verifying letter (or certificate) will need to be recognized as an essential requirement in transitioning to another level (A levels for example), or providing a meaningful and respected foundation for future academic or career advancement, for it to protect the provision of highquality fieldwork. To replace the current internal assessment (the application of which we accept is flawed) with unproven written examinations, with or without a ‘letter of verification’, is a high-risk strategy for a subject which everybody accepts has a reliance on practical skills and applications. FSC is also concerned that any erosion in access to fieldwork beyond the classroom and school grounds will occur disproportionately across schools, with fieldwork for students in more disadvantaged areas (with a higher dependency on support targeted through pupil premiums) being most threatened. A statutory requirement is essential in these circumstances. See also FSC response to Q9. FSC accepts that an e-portfolio of laboratory and fieldwork (science) and fieldwork (geography) could become a very useful and effective tool for future assessment, for example by showing that students have taken part in a full range of practical experiences. FSC recommends that Awarding Bodies should be encouraged to explore transferable portfolios of practical work, including those held electronically. If moderated externally, FSC believes that such an approach would encourage teachers and senior managers to engage in more frequent practical work throughout courses, providing greater opportunities for the progressive development of practical and manipulative skills (equipment handling etc.), knowledge, understanding and curiosity. Such a progression would, for example, enable older students (by GCSE at the latest) to tackle open-ended investigations and deal with the ‘messy’ data which often characterizes real science and geography research, but is lacking from current assessment approaches. 4d Do the proposed subject content and assessment objectives for geography provide assurance that essential knowledge taught at the earlier key stages is built upon and represented adequately? x Yes No Not Sure FSC welcomes the higher profile given to environmental geography in the proposed national curriculum for KS3 in particular. This has strengthened the opportunities for progression at all secondary phases. 4e Will the proposed qualifications in geography secure sound progression for the purposes of further academic and vocational study? Yes No Not Sure Comments: No comment. 5. History 5a Do the proposed subject content and assessment objectives for history cover the appropriate knowledge and understanding for GCSEs in this subject? Yes No -insufficiently demanding No- overly demanding Not Sure Comments: No comment. 5b Is the relative weighting of the assessment objectives right for history? Yes No Not Sure Comments: No comment. 5c Should students be encouraged, as part of their GCSE history studies, to undertake a historical investigation that gives them the opportunity to conduct independent research into a historical issue, event or process of their choosing resulting in an extended essay? Yes No Not Sure If so, how can this be achieved best? No comment. 5d Do the proposed subject content and assessment objectives for history provide assurance that essential knowledge taught at the earlier key stages is built upon and represented adequately? Yes No Not Sure Comments: No comment. 5e Will the proposed qualifications in history secure sound progression for the purposes of further academic and vocational study, including encouragement of the ability to conduct independent study in the subject? Yes Comments: No comment. No Not Sure 6. Modern and ancient languages 6a Do the proposed subject content and assessment objectives for modern and ancient languages cover the appropriate knowledge and understanding for GCSEs in these subjects? Yes No -insufficiently demanding No- overly demanding Not Sure Comments: No comment. 6b Is the relative weighting of the assessment objectives right for modern and ancient languages? Yes No Not Sure Comments: No comment. 6c Do the proposed subject content and assessment objectives for modern and ancient languages provide assurance that essential knowledge taught at the earlier key stages is built upon and represented adequately? Yes No Not Sure Comments: No comment. 6d Will the proposed qualifications in modern and ancient languages secure sound progression for the purposes of further academic and vocational study? Yes No Not Sure Comments: No comment. Please answer all the remaining questions, which include questions on literacy, numeracy and impact on specific groups of students. 7 Does the English language content cover the key elements of literacy needed for employment or further study? Yes No Not Sure Comments: No comment. 8 Does the mathematics content cover the key elements of numeracy needed for employment or further study? Yes Comments: No comment. No Not Sure 9 Do any of the proposals have potential to have a disproportionate impact, positive or negative, on specific pupil groups, in particular the 'protected characteristic' groups? (The relevant protected characteristics are disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex and sexual orientation); if they have potential for an adverse impact, how can we reduce this? Yes - Positive impact x Yes - Negative impact No Not Sure Fieldwork is an important element within a pupil’s progressive development of practical skills and as such FSC welcomes its inclusion within a broad and balanced curriculum. However, we are concerned that particular groups of students will face barriers in accessing fieldwork and outdoor learning opportunities due to lack of funding. FSC is concerned that there is as yet no evidence note on the positive impact of outdoor learning on the DfE’s “Pupil premium-how to use it” webpage. Ofsted’s initial review of its use found that only a third of schools had used the funding to subsidise or pay for educational trips or residential visits. We also know of at least one Local Authority which has withdrawn its core funding to support disadvantaged pupils attending residentials as a result of funding being directly allocated to schools. Joint FSC and Institute of Education research identified an overlooked ‘middle group’ who come from borderline families who often have just failed to qualify for hardship support, but who also lack the means to pay for residential visits themselves. Many young people in this group have very high potential which could remain unfulfilled without the opportunity of a learning experience allowing them to develop further. FSC is concerned that currently a whole generation of young people do not experience outdoor learning through no fault of their own. FSC recommends clear guidance should be published by Department for Education directing teachers to additional support – such as Pupil Premium – which will enable them to implement a high-quality curriculum, delivered through effective teaching and learning approaches including fieldwork and outdoor learning, which is accessible to ALL pupils. 10 Have you any further comments? Comments: No comment. 11 Please let us have your views on responding to this consultation (e.g. the number and type of questions, whether it was easy to find, understand, complete etc.). Pages 3-4 do not offer an option for respondents to identify themselves as being from the NGO sector, nor to select ‘other’. Thank you for taking the time to let us have your views. We do not intend to acknowledge individual responses unless you place an 'X' in the box below. Please acknowledge this reply. x E-mail address for acknowledgement: Estelle@field-studies-council.org Here at the Department for Education we carry out our research on many different topics and consultations. As your views are valuable to us, please confirm below if you would be willing to be contacted again from time to time either for research or to send through consultation documents. x Yes No All DfE public consultations are required to meet the Cabinet Office Principles on Consultation The key Consultation Principles are: departments will follow a range of timescales rather than defaulting to a 12-week period, particularly where extensive engagement has occurred before departments will need to give more thought to how they engage with and consult with those who are affected consultation should be ‘digital by default', but other forms should be used where these are needed to reach the groups affected by a policy; and the principles of the Compact between government and the voluntary and community sector will continue to be respected. Responses should be completed on-line or emailed to the relevant consultation email box. However, if you have any comments on how DfE consultations are conducted, please contact Carole Edge, DfE Consultation Coordinator, tel: 0370 000 2288 / email: carole.edge@education.gsi.gov.uk Thank you for taking time to respond to this consultation. Completed responses should be sent to the address shown below by 20 August 2013 Send by post to: Qualification and Assessment Division Department for Education L2 Sanctuary Buildings Great Smith Street London SW1P 3BT Send by e-mail to: GCSEcontent.consultation@education.gsi.gov.uk