From reading some initial responses from other people to the proposed GCSE ML subject content and assessment objectives criteria , I fear that there is a confusion between subject criteria for content and assessment objectives, and regulations about assessment.
It would be extremely helpful to make responses with reference to the previous criteria and not with reference to the exams which the awarding organisations produced.
The features which many people do not like about the current exams (the controlled assessment, the choice that teachers have (understandably) made to encourage rote learning) are to do with regulations about the way the criteria are tested (i.e. the requirement to test the practical elements of writing and speaking by controlled assessment, the constraint that this has to be 60%, and the conditions for the assessment which are 'global' conditions for all GCSEs); they are nothing to do with the criteria for subject content and assessment objectives .
The subject content and objectives of 2008 give greater freedom to teachers and awarding bodies than they have ever had, and certainly much more than the proposed 2016 criteria. This was a particular requirement from the Dearing report - and it was this which drove the QCA and exam boards to require writing and speaking to be tested as CAs. The need to encourage CLIL and imaginative and creative contexts was a key element in the 2008 criteria.
I very much hope that responses will make this distinction, and address the way in which the content is tested when Ofqual launches the relevant consultation.