Michael Gove appears to have done that rare thing in politics - he's come up with a policy that almost no one supports.
Teacher union opposition might be seen as par for the course for an education secretary wanting to shake things up; it might even be viewed as a political necessity for one wishing to keep the right-wing press on side.
But classroom "militants" are not the only ones up in arms about Gove's plan to introduce English Baccalaureate Certificates (EBCs) in core subjects as a replacement for GCSEs.
Major doubts have been raised by the heads of the schools supposed to use them, the exam boards that will provide them, the watchdog that will regulate them and the employers that will consume them.
Serious concerns have also been voiced by academic experts in assessment, elite independent schools and academies, and by bodies outside education including the CBI and high-profile figures and organisations representing the arts and sport.
There are even significant misgivings within Gove's own party. A former Tory education secretary recently described EBCs as a "huge mistake", while the current Conservative chair of the Education Select Committee has suggested that the reform is the result of a "lack of coherent thinking". The worries are said to go all the way to Number 10.
One might think that for the secretary of state to pursue a plan that is so lacking in expert backing and political support he must be certain that wider public opinion is behind his reform.
But a YouGov poll suggests he would be unwise to assume that that is the case. The survey carried out in September, immediately after the plans were formally announced, found that only 39 per cent of adults in England supported the EBC.
Worse still for Gove, the poll suggests that much of this support could melt away when voters become aware of what the EBCs will actually entail (see `public opinion' below).
The official consultation on the reform closed on 10 December. But the Department for Education (DfE) has refused to release to TES any details of the responses it received, or even a list of the organisations that responded.
A spokeswoman said that the DfE would be publishing its own summary of the submissions this year, but could not say when. This reluctance to publish what are likely to be critical responses comes despite Gove's telling the Education Select Committee last month: "If someone submits a response to a public consultation, then of course you can ask me about what they have said in public."
Today, TES understands that the EBC is now so under siege that the department may be about to back down on key elements of the reform. The aspects alleged to be under threat are so central to the whole EBC concept that to do so could represent an embarrassing retreat for Gove.
But the alternatives available to him look equally untenable. If he proceeds with the qualification as originally envisaged, not only are experts warning that it will lead to "more wrong grades" awarded according to "the luck of the draw" but many schools may simply refuse to use it.
Russell Hobby, general secretary of the NAHT heads' union, predicts a "massive exodus of state schools" to IGCSEs and the International Baccalaureate Middle Years Programme if the EBC proceeds as the DfE proposed last year. "There is so much concern about what is going on there and about the political interference in the exams system that I think many schools would take that option," Hobby says.
The Association of School and College Leaders also recognises the possibility that schools will simply ignore the new qualification. If they do so then the government could end up with an exam white elephant even more costly and damaging than Labour's ill-fated diplomas - which, by 2011, had cost the taxpayer nearly pound;20,000 for every candidate completing the qualifications.
Of course, Gove could stop any exodus by making the EBC compulsory, but to do so would mean abandoning his oft-stated principle of allowing schools to decide which exams they use.
So he now faces three very unattractive options: retreat on a highly publicised flagship policy; risk creating an expensive, deeply unpopular qualification that could well be ignored by teachers; or backtrack and curtail a key school freedom.
But how did the education secretary come to be in this invidious position in the first place? Hobby believes it is because he and those advising him have "managed (the process with an eye) to headlines rather than the substantive teaching issues".
Certainly it was through a newspaper headline rather than a speech, parliamentary statement, press release or official consultation that many found out about the plan.
"Return of the O-level," thundered the Daily Mail on 20 June last year, heralding a story that came out of the blue for most people. Even Prime Minister David Cameron had been left in the dark about its release, Downing Street later admitted.
The article was an exceedingly detailed leak, outlining "revolutionary plans" for:
- Pupils to study for new "explicitly harder" exams in English, maths, physics, chemistry, biology, history, geography and modern languages from 2014;
- GCSEs to "disappear from schools within the next few years";
- The "bottom 25 per cent of pupils" to "sit simpler exams, similar to the old CSEs";
- Exam boards to compete for the right to become a single exclusive provider for each of the tougher O-level-style exams.
That the entire education sector seemed to have been left out of the loop should not perhaps have come as a great surprise. Gove has long regarded it with suspicion and made no secret of this distrust.
In October 2007, the then shadow education secretary wrote: "For any politician asked to improve our schools, the real obstacle to progress doesn't sit on the other side of the despatch box. No, the real enemy of excellence is the entrenched, complacent, educational establishment that opposes greater rigour, is suspicious of anything considered `traditional' and has undermined tried-and-tested teaching methods because they're `old- fashioned' and `authoritarian'." Four and a half years later, the leak over what would become known as the EBC suggests he had not changed his mind.
But if the qualification does progress as planned, it will not be the first time a government has completely ignored the views of the "educational establishment" on exam reform.
In the run-up to the 2005 general election, the Blair administration decided to reject the Tomlinson report's key recommendation for an overarching 14-19 diploma, in the face of its unanimous support from virtually everyone working in education.
Labour ministers feared the electoral fallout from anything that could be portrayed as signalling the end of A levels and GCSEs. So instead they opted for a last-minute halfway house that would allow the "gold standard" of the academic qualifications to survive, with diplomas developed alongside them to offer more applied learning. These new qualifications suffered from all the complicated unwieldiness of Tomlinson's proposed overarching diploma, but jettisoned what could have been its main achievement - an end to the academic vocational divide and all the snobbery that goes with it.
Despite millions of pounds of investment, the close involvement of employers in its development and relentless government marketing, the diploma never came close to taking off as even a minority qualification in schools, let alone emerging as the serious challenger to A levels that some had hoped for.
Engaging with `the enemy of excellence'
So could Gove be about to follow in his Labour predecessors' doomed footsteps by rejecting the unified view of education on how best to reform school qualifications?
Despite his previous fiery rhetoric, since becoming education secretary he has actually made attempts to engage with the "enemy of excellence". When it came to the government's national curriculum review, a panel of academic experts - and fully paid-up members of the "educational establishment" - were appointed as advisers. The experience, however, was not wholly positive for either side. Half of the experts felt their views were largely ignored and had to be talked out of resigning halfway through. They eventually said so in public but were dismissed by Gove in Parliament as "a few professors".
So, fingers burned by that attempt to work with education's great and good, did the secretary of state decide to save himself the bother of talking to them at all before producing the EBC proposals?
That is certainly the impression gained by Robert Coe, professor of education at Durham University, whose work on GCSE grade inflation was actually cited by the government when it officially announced the EBC plans in September. "I don't know what they are thinking or who they have talked to," he said back then. "Where are the models for this?"
But as with Labour's rejection of Tomlinson's recommendations, there is widespread suspicion that the EBC plan - particularly the way it was first leaked - had as much to do with political considerations as educational ones.
The newspaper story that broke the news was viewed by many as a deliberate appeal to Tory grassroots hankering for the "traditional" education that a return to the O level seemed to promise. Some commentators suggested that this was Gove out "on manoeuvres" - a calculated political play from an ambitious minister positioning himself as a future Conservative Party leader.
If that was the idea, then in the short term it appeared to work, as right-wing commentators such as Melanie Phillips raved over the "stunning" plan. But its reception by voters seems less clear-cut. In September, YouGov found that although 59 per cent of those who voted Tory in 2010 said they liked the overall concept, 50 per cent of them were opposed to one of its key components - the idea that all assessment should be done through a final exam.
By then, the way the policy was spun in June had had some potentially highly damaging consequences for the way the EBC plan would unfold. The most problematic element of the Daily Mail story was not the idea of a return to "explicitly harder" O-level-style exams, it was the suggestion that the bottom quarter of "less intelligent" pupils would "sit simpler exams, similar to the old CSEs" with questions emphasising "real-life situations such as counting change in a shop or reading a railway timetable".
Critics, who included the last reforming Conservative education secretary Lord Baker of Dorking, immediately attacked the return of the CSE, arguing that the government should not "resurrect a failure". Baker is also clear that he believes the government should not be wasting its time on an exam at 16, when he argues that 14+ specialisation should be the government's direction of travel. Deputy Prime Minister Nick Clegg revealed that the Liberal Democrat side of the coalition had been told nothing of proposals and quickly voiced opposition to a "two-tier" approach to exams.
Within hours of the Daily Mail story breaking, Gove was on the retreat. Forced to defend the leaked proposals in Parliament, he made no mention of the CSE idea and insisted that the current exam system was already two- tier.
It was a prelude to the eventual dropping of the concept of a second exam for the less able. When the EBC proposals were formally announced in September, following a second newspaper leak, they described a single set of single-tier exams that would be taken by all pupils who would have sat a GCSE. But they would also be "more rigorous" than GCSEs.
The change - combined with a decision to delay the first teaching of EBCs until September 2015, after the next general election - was enough to get the Lib Dems on board. Indeed, Lib Dem schools minister David Laws seems to be one of the few people happy with the latest version of the proposals.
However, experts in academic assessment certainly aren't. They are warning that it may be "impossible" to create a qualification that is tougher than the GCSE but can also assess all the abilities catered for by GCSEs, within a single exam.
Coe says that the broad range of ability taking one exam would limit the amount of syllabus that could be tested and the precision of the exam. "The reliability of the scores is less," he says. "The luck of the draw - whether you get questions that you happen to be able to do or you can guess or whatever - starts to play more of a role. You get more wrong grades."
Professor Dylan Wiliam, a member of the government's national curriculum review expert panel, has similar concerns. "The scores that students get will just depend on the luck of the draw," he explains. "This is unavoidable because it is beyond the ability of test writers to write enough good questions every year that could actually differentiate by outcome."
Like them or loathe them, the original proposals that were leaked in June were a much more practical proposition because they were based on reality. It is understood that they were inspired by the system in Singapore where about 60 per cent of pupils are placed on a fast-track course to academic O levels with the rest taking easier N (normal) levels.
It is a two-tier system, but it also allows for progression from the lower tier. For some pupils in Singapore, the N level is just a staging post on the way to O levels, which are eventually sat by some 80 per cent of a cohort.
These subtleties were completely lost in the original Daily Mail story. And by using the CSE as a comparison, it instantly invoked all the negative, backward-looking connotations associated with the long-extinct qualification.
Facing up to reality
At least one influential government insider has been suggesting for months that Gove may have to face reality and accept that his ambitions are impossible within one tier. And in November, Ofqual chief executive Glenys Stacey told Gove that "the aims for EBCs may exceed what is realistically achievable through a single assessment". It is understood that this is one key aspect of the EBC that could disappear when the government responds to its consultation in the coming weeks.
That could be embarrassing for a secretary of state who has been making a big virtue of the fact that his plan will end the current two-tier system and its "cap on aspiration". Wags have already suggested that the DfE could try to limit the damage by talking about layers or levels. But even if Gove can successfully finesse a way out through this veil of tiers, his EBC problems are far from over.
Other objections come from the independent sector, which one might assume would be instinctively supportive of the reform. The Headmasters' and Headmistresses' Conference (HMC) group of elite schools opposes 100 per cent of assessment being done through external exams.
It is also understood that the idea of having a single exam board for each EBC is being reconsidered, raising the prospect of a second embarrassing retreat. On the face of it, this franchising system - also rejected by the HMC - seems to make the most sense of any aspect of the EBC plan.
It is certainly the most popular according to YouGov, with 82 per cent of voters backing the idea of a single exam board for each subject. Gove first suggested the idea in December 2011 to counter the exam board "race to the bottom" highlighted by a newspaper investigation into the seminars the boards were arranging for teachers.
Exam boards were understandably quick to point out the disadvantages of the franchising approach - the loss of competition and the concentration of all the expertise in a subject in a single board making it hard for any other organisation to win a contract.
But their case has been backed by a powerful advocate with much less of a vested interest - Ofqual's Stacey. By October, she had warned that franchising would not only make EBCs "extremely difficult" to regulate and to ensure "both standards and value for money" in, it would also increase risks for A levels, remaining GCSEs and the viability of entire exam boards.
In November she wrote to Gove warning that franchising would mean "the system would lose a large amount of subject expertise". In December she wrote again and asked him to reconsider the whole franchising proposal because of the "significant risks to the safe and continued delivery of all qualifications".
Stacey is no product of the "educational establishment". She was Gove's own appointment to Ofqual and has been his stalwart ally in the controversial fight to see off grade inflation in existing school qualifications.
But asked last month whether he was prepared to overrule Ofqual on his reforms, the secretary of state told MPs: "If it were the case that after a process of seeking to reassure, the regulator still had concerns but I believed that it was right to go ahead, then I would, and on my own head be it."
It was a defiant performance, but there are further considerations that may prompt a rethink. There is the whole issue of whether, as the DfE hopes, the franchising system can be introduced outside European procurement rules. If not, then it could quickly become more time- consuming, expensive and complicated.
The Department for Transport's abortive attempt to award the West Coast Main Line rail franchise last year - a disaster that will cost the taxpayer at least pound;40 million - laid bare the enormous risks involved in such processes. There is every possibility that an exam board that missed out on the EBC franchises would, with its future under threat, follow the example of Virgin Trains and sue the DfE.
Gove has acknowledged that this is a "risk" and that "you can never be certain that anything is legally watertight". Any legal challenge would put even more pressure on an already extremely taut timetable for the introduction of EBCs.
Ofqual will have to have its own consultation before any new qualification can be introduced, but that cannot begin until the government has published the results of its own "listening exercise". Even if that takes place this month, which is far from certain, it is unlikely that Ofqual would be able to report before Easter. Until that happens, exam boards will know only in broad terms what they are being expected to produce. Yet the plan is that they will be expected to submit their bids for the EBC franchises by June.
Graham Stuart, Conservative chair of the Education Select Committee, who has implored the education secretary to "stop taking the urgency pills", says the boards are concerned that they are being expected to design these crucial qualifications "in the dark".
Gove acknowledged last month that there were concerns about the speed of the process. But he added: "I think it is always important in government to keep up the pace of reform. my very, very strong view is that we should stick to the timetable we have set."
Back in 2009 he observed: "In those countries that perform best educationally, from Finland to South Korea, it is academics, not politicians, who preside over the exam system.
"That's the direction we need to move in here. Towards greater power for those who believe in academic rigour, and away from politicians meddling, micromanaging and dumbing down."
The education secretary was talking about A levels when he made those comments. But they are words that may come back to haunt him over EBCs.
There are unpleasant historical precedents for what can happen when the introduction of new qualifications or new test providers is rushed in without proper planning - the A-level grading scandal of 2002 and the Sats debacle of 2008.
In both cases, the exam boards, regulators, quangos and test providers involved acted as useful buffers for the government, shielding ministers from the full political fallout.
Gove may well be about to make a strategic retreat on key elements of the EBC, according to well-placed sources. But if he decides to go ahead as planned, in the face of warnings from schools, teachers, exam boards and the regulator, the education secretary will have no such buffers. The EBC will be, as he has said, on his "own head".
- CBI - First Steps report: "It is at 18 not 16 that we should be thinking in terms of externally-marked, high-value qualifications. There is a risk that the mistakes of the past - both teaching to the test by schools and micro-management of the school system through the means of exams and league tables - may be repeated in the EBC."
- Lord Baker, Conservative education secretary 1986-89: "That's a huge mistake. A lot of youngsters aren't turned on by it. I don't think the English Baccalaureate will survive a change of government."
- Sport and Recreation Alliance, umbrella group representing organisations such as the FA, Rugby Football Union and UK Athletics: "By limiting the (EBC) to five core academic subject areas, there is a real danger that PE will be sidelined by headteachers as they focus on achieving success in the league tables."
- Sir Jonathan Ive, Stella McCartney, Sir Terence Conran and other leading UK designers: "The omission of subjects such as design and technology and art and design from the English Baccalaureate will damage the future prosperity of our industry and the wider creative economy."
- Petition organised by teaching unions signed by more than 17,100 people: "(EBCs) will leave many pupils excluded and damage the economic and cultural health of our nation."
- Simon Lebus, chief executive of Cambridge Assessment and owner of the OCR exam board: a "complete step in the dark".
- Julian Bird, chief executive of Society of London Theatre: "Not including the arts in the proposed (EBC) will have a negative impact on broader skills development, social mobility and in ensuring the UK has the creative workforce it needs in the 21st century."
The Department for Education's intention is "that EBCs should be assessed 100 per cent by externally marked examinations".
But according to YouGov, 64 per cent of voters favour "a mixture of final exams and controlled assessment", with just 28 per cent backing an exam- only system. And that mixture of assessment methods is also most popular among those who voted Conservative in the last general election.
Ministers have already abolished modularisation in GCSEs and do not want it to return in EBCs. But YouGov found that 52 per cent of adults do want modular exams "so if students do badly in just one area they can resit it".
Just 38 per cent backed the idea of "not having modular exams, so students can only do resits by resitting the whole exam".
There is majority support, from 59 per cent, for having a single-tier qualification "that can reflect all levels of ability", but that is the one aspect of EBCs that experts think it will be "near impossible" to deliver. The biggest backing - an overwhelming 82 per cent - is for the idea of having a single exam board per subject. But it is this area of the reform that is sparking most concern from the qualifications regulator Ofqual.
Photo credit: Rex Features