Reformulation of UGCs New Regulation and PBAS

To
The Chairman,
University Grants Commission (UGC),
Bahadur Shah Zafar Marg,
New Delhi - 110 002.
Sir,
This is with reference to UGC's new Regulations 2010 on Teachers recruitment in the Indian Universities and Colleges.I welcome all the efforts of UGC to promote quality of higher education and systematisation of recruitment and infusion of transparency in the same.As a stakeholder in higher education system in India, I request you to kindly withdraw the new regulation as it would discourage the talented young scholars from joining universities for teaching and would encourage existing talented young teachers to join private sector and upcoming foreign universities. Hence may I request you to kindly reformulate it in such a way that it ensures the equi-distance between assistant professor and associate professor positions on the one hand and associate professor and professor positions on the other in salary and experience(as under the fourth and fifth pay periods). In this regard I would request you to kindly consider including M.Phil and Ph.D experience as experience in the appointment of associate professor and professor positions.
I request you to withdraw the PBAS which is mandatory for teachers recruitment. The conjectural framework of PBAS lacks theoretical foundation, conceptual clarity (the three categories in the existing PBAS are not mutually exclusive), empirical correspondence, validity, reliability and suffers from lopsided arbitrary scoring and weightage. It does not include any API on the quality of teaching, learning evaluation or research. Rather than improving quality it would perpetuate mediocrity in the higher education system.
I request you kindly reformulate the PBAS system according to the norms of quantitative behavioural science. A committee of expert educationists, psychologists and behavioural scientists (who have experience and proven expertise in designing educational performance appraisal system) need to be appointed to reformulate the PBAS. The new PBAS needs to be conceptually clear and operationalised in terms specific mutually exclusive but interrelated dimensions. The APIs of each dimension need to be specific, precise and measurable. The operational framework of PBAS should be tested empirically on a national sample of university and college teachers so as to assess its reliability and validity. The sample needs to have proportional representation to different regions of the country, different disciplines, and classes of teachers viz., assistant professors, associate professors and professors. The scores of each of the APIs and dimensions need to be assigned weights from the sample data. In each of the dimension indicators of quality need to be incorporated.
I am unhappy that the selection grade lecturers are automatically promoted to associate professorship without any assessment and interview ever since the operation of new regulation. I would like to request you to kindly apply the PBAS system to all equally without any age based discrimination.
I feel that the transparency measures suggested in the new regulation are not adequate so as to depoliticize the recruitment process. I request you to include measures such as mandatory recording of interview proceedings, online publication of applications of all candidates, their scores in each API, interview performance score and video clipping of the interview.