In January 1992, the National Council on Education Standards and Testing (NCEST) issued a report "Raising Standards for American Education," which called for the establishment of a national system of educational standards and assessments as a basis for comprehensive reform of U.S. education. This statement is a facsimile of the written testimony that was submitted to the House of Representatives subcommittee. The statement is presented as it appears in the Congressional record, with a preface and references added. It is contended that although the NCEST recommendations appear to be a matter of common sense, they are unlikely to work and may have serious side effects. The recommendations do not adequately address issues of feasibility, fairness, validity, and reliability. Although the new standards are expected to be a common core, the NCEST does not explain why the proposed tests will not narrow the curriculum. Proposed innovative assessments have not yet been adequately tested, and many practical issues must be resolved. Many problems exist in building a set of assessments that will do all that the NCEST proposes. These problems concern the following areas: (1) providing diversity and protecting local initiative; (2) providing comparability of scores; (3) equity; (4) costs; and (5) gauging school effectiveness. While efforts to move ahead with a national debate on educational standards must be encouraged, several alternatives to the proposals must be discussed to ensure feasibility, validity, fairness, and desirability of new assessment programs. (SLD)