In its submission to the Scottish Office criticising the proposed mandatory testing of pupils in the first two years of secondary school, the Convention of Scottish Local Authorities observes: "Levels are not equivalent of grades. Levels are phases of learning."
Cosla wants this more informal approach to continue into the first two years of secondary school despite acknowledging that the Inspectorate is right to be concerned about pupil attainment at this stage. The submission asserts: "There is no evidence that externally set tests will raise standards."
The response, which reflects the political views of councillors rather than the professional stance of education officials, rehearses familiar arguments about the strait-jacket of formal tests and suggests they are "an easy but ineffective form of assessment" that would not provide parents with the detailed information they need.
The Labour-dominated convention sets out an alternative five-point action plan for improving pupil performance in S1 and S2. It particularly wants to see closer planning between primaries and secondaries, an eradication of the fresh start approach in the first year and a common format for reporting pupil progress.
Individual councils say Scottish Office plans run counter to the rest of the 5-14 testing regime in primaries. Borders suggests the logic of the Government's position is that, if the proposed secondary tests are useful and valid, "then surely there needs to be a similar move towards standardisation of testing in primary schools".
Submissions also challenge the feasibility of having five overlapping tests from level A to the proposed new level F.
The convention concludes that compulsory testing in reading, writing and maths, which ministers want to pilot next spring, will make Scottish pupils among the most assessed in Europe. "Only in S3 will young people escape the pressures of external national assessment," it comments.