1. ESL classes have continuous intake. PBLA does not work in classes that have continuous intake. How can you have a portfolio when new students are joining every day and older ones are leaving?
The turnover of some classes is 60% to 70% per session ( every 4 months).
2. ESL is supposed to be taught in a safe learning environment. Students don’t like to be tested every other session. In many instances, they simply don’t show up when there is an assessment. Classes that are taught 5 hours a week have to be assessed once every three weeks.
3. Teachers are no longer motivated to make the class as interesting and useful as possible. What they are constantly thinking about is to see how many artifacts (assessments) they can make out of each session.
4. The conversations among Instructors during lunch breaks revolve around the negative impact of the PBLA on their life, which creates unhealthy work environment and contributes to stress .
5. PBLA is not something that was thought through from the beginning. Requirements keep changing. For instance, at first teachers were supposed to write a report card once a year. Now, they have to do that three times a year. PBLA was supposed to stop during the summer. Later, they changed their opinion. Lesson plans and modules were supposed to be written on paper; now, they want them on paper and on the Internet.
6. Supposedly, the pilot was done in Manitoba with classes of 7 to 9 students. Our classes in Ontario have 25 to 30 students. Classes with fewer than 15 students are either closed or threatened to be closed. Reports printed about the success rate of PBLA in Manitoba sound far from real. Numbers such as 95%of the students and 89% of the teachers loved it, and fake testimonies are all over the documents that are published. These numbers and testimonies are far from what is seen throughout the board. You talk to teachers and students they will all say that they despise it.
7. PBLA was never used in ESL classes originally, nor do we have seen any evidence that it has been authentically implemented in any identical settings in an unbiased manner for its approval.
8. PBLA does not add much to the performance of the students. Many students don’t show up for assessment and those who do sit side by side taking the assessments.
8. Apart from the many hours that the teachers have to take to make these assessments, teachers have to take classroom time to administer them, mark those assessments and make sure that the results are recorded in the inventory sheets and the master inventory sheets, and that the instructor gives students constructive feedback and that students take the time to write a reflection on what they have learned after each assessment. Imagine how much time it takes to do all of this. Think how difficult if not impossible this is if you are teaching a literacy class, or level 1 /2 /or even 3.
9. PBLA and CLB have nothing to do with TOEFL, IELTS, Computer,  academic programs that are not CLB-based at all,  or even citizenship classes. Why are they forcing these programs to use the PBLA?
10. As a result of PBLA, the number of students has dropped considerably.
11. Many experienced teachers have either quit or will quit the teaching profession altogether or have started teaching in colleges and universities where there is no PBLA. School Board has lost and continues losing its best professionals with highest academic degrees and huge amount of experience.
11. PBLA is being used to intimidate and harass teachers. It seems that the quality of teaching and building a rapport with students is no longer important. All that the board and ministry are thinking about is implementing the PBLA, even if the strong majority of srudents, instructors, and administrators believe that it is not feasible in our contexts.