Corrections

WEEK/MODULE #4 FINAL PAPER OUTLINE

(ALL highlighted sections must be completed and submitted for grading by end of week/module #4)

Final Paper Authors:

( Insert Above: your name only if you are doing the final paper individually. Insert ALL of the team/group members’ names if you are doing the final paper in a team/group. Remember no more than 4 people per team/group)

Confirm the following: All final papers will be in accordance with the below MANDATORY paper structure and I/we will have “level 1 Headings” and “Level 2 APA Headings” as identified in the below outline for each part: Do you understand these requirements: _I UNDERSTAND_ ( Insert Above: either “I UNDERSTAND” or “I DON’T UNDERSTAND”).

Confirm the following: I/We realize that I/We can submit just one final paper draft to the instructor during week/module #6 only. This is optional (not grade) but a great way to get the instructor’s feedback and comments to improve our final paper. _I UNDERSTAND_( Insert Above: either “I UNDERSTAND” or “I DON’T UNDERSTAND”).

Confirm the following: I/We realize that the final paper is broken down into a total of 28 points for this term as follows:

· 1 point for final paper topic selection & submitting it to the instructor during week/module #2

· 4 points for substantially completing this outline & submitting it to the instructor during week/module #4

· 25 points for submitting the final paper to the instructor during week/module #8

__ I UNDERSTAND _( Insert Above: either “I UNDERSTAND” or “I DON’T UNDERSTAND”).

Mandatory Term Paper Format, Outline and Grading Rubric:

Title Page:

Integrating Values - The Legality, Morality, and Community Welfare of

Federal agencies loan forgiveness regulations to cancel out $20,000.00 for each student borrower (this regulation was ruled improper by the USSCT in summer of 2023 ( Insert Above: the specific agency’s rule, regulation or action that is controversial in nature and occurred in the last 5 years)

Abstract:

The paper attempts to critically analyze the 2023 loan forgiveness rule promulgated by the Department of Education, which proposed the cancellation of up to $20,000 per borrower which the U.S. Supreme Court said was issued improperly. This study also analyzes the rule's legality, ethical considerations, and impacts on community welfare. The paper develops such themes as the conflicts of rulemaking, legal standing for the Department of Education, and the interests of conflicting stakeholders. Ethical analysis shall involve legal positivism, utilitarianism, and deontology in deducing whether the policy is coherent with general societal values. Lastly, recommendations are made in the paper on other ways to resolve the student debt crisis without losing legality and equity.

(Abstracts give the reader an overview of what you intend to do with this paper and how you intend to do it---but you NEVER conclude in your abstract)

Body of Your Paper:

(each main section should be a “level 1” heading in APA format)

I. Introduction (worth 2.0 points)

A. Introduction of the Paper

· Analytical paper - “3 value” analysis of law, ethics, and community welfare.

· Current, controversial, and narrowly focused topic involving an administrative agency’s controversial rule, regulation or action that has been passed and implemented in the last 5 years. The 2023 regulation aimed to alleviate the growing student debt crisis by forgiving substantial amounts of federal loans for qualifying borrowers. The proposed policy directly impacted over 40 million borrowers, raising questions about economic mobility, taxpayer burdens, and the Department's authority.

( Insert Above: Provide a general description of your selected agency’s controversial rule, regulation action here. Remember it CANNOT be a legislative bill that was created by Congress and signed into law by the President. It must be created by a specific administrative agency. It CANNOT be a state bill that was created by the state legislature and signed into law by the Governor---it must be created by a specific administrative rule, regulation or action.)

· Significance of topic to the public.

B. Background Information regarding topic

· Describe the administrative agency, its history, its powers and authority The U.S. Department of Education (ED), established as a standalone agency in 1980, oversees federal education policy, funding, and civil rights enforcement. It administers federal student aid, enforces laws like Title IX, allocates funding for K-12 and higher education, and regulates institutions receiving federal aid. While it influences national education policy, its authority is limited by Congress, the courts, and state governments, as education is primarily state-controlled. Recent issues include student loan forgiveness, Title IX expansions, and debates over school choice policies. Despite its power, the ED’s actions must align with federal law and constitutional limits..

· ( Insert Above: Provide here the name of your administrative agency and when it was formed and what area does it regulate.)

· Describe who currently runs your administrative agency now and how do they get their jobs? _ As of February 2025, the U.S. Department of Education is led by Secretary Linda McMahon, who was appointed by President Donald Trump during his second term. The Secretary of Education is nominated by the President and must be confirmed by the Senate, as outlined in 20 U.S. Code § 3411. This process involves the President selecting a candidate, followed by Senate hearings and a confirmation vote. Once confirmed, the Secretary oversees federal education policies and programs.

· _ ( Insert Above: Explain if your administrative agency is headed by one director or a commission or a committee. Explain who that one person is, or if it is a commission or committee then identify who currently sits on that commission).

· The U.S. Department of Education (ED) is headed by a single individual, the Secretary of Education, who serves as a member of the President’s Cabinet. The Secretary is appointed by the President of the United States and must be confirmed by the U.S. Senate. As of February 2025, the current U.S. Secretary of Education is Miguel Cardona, who was appointed by President Joe Biden in 2021. The Secretary oversees education policy, federal student aid programs, and civil rights enforcement in schools and universities across the country. While the Secretary is the primary leader, the Department of Education also includes Deputy Secretaries, Assistant Secretaries, and advisory committees that help shape policies and implement education programs.

___________________________________________________________________________________ ( Insert Above: Explain how this agency head(s) got their job)

· Place a link in your paper to the administrative agency’s home page. _______ https://www.ed.gov/ ______________________________________________________________________________________________________________ ( Insert Above: All administrative agencies have websites. Provide the website URL hyperlink here)

· Describe the certain agency rule, regulation or action that was passed (ie. the regulation created) Initiated through notice-and-comment rulemaking, the policy intended to forgive $10,000-$20,000 per borrower based on income thresholds. https://www.federalregister.gov/documents/2024/04/17/2024-07726/student-debt-relief-for-the-william-d-ford-federal-direct-loan-program-direct-loans-the-federal

( Insert Above: Provide the citation to the agency rule, regulation or action---provide a hyperlink to display the actual governmental rule, regulation or action and NOT just an article about it. You must find the actual primary source of the law: rule, regulation or action published.)

· Describe its impact on individuals or businesses and include statistics, facts, data on the effects to show the reader this is an important issue in administrative law.

· Often agencies take “comments” from the public and those to be regulated before they create the regulation—try to find these past comments and what were the concerns or objections of those who objected to the proposed regulation. __The Proposed Rule goes beyond the statutory authority of the Secretary of Education under the Higher Education Act. The Proposed Rule violates the Supreme Court’s Major Questions Doctrine. The Proposed Rule undermines the interests of the American public._______________________________________________________________________________________________________________________________ ( Insert Above: If your controversial administrative rule, regulation or action was produced by notice/comment procedures, provide some examples of the submitted comments here.)

· Give one or more “real life” stories of consumers, employees, vendors, stakeholders etc… who were affected (either good or bad) by your agency’s controversial rule, regulation or action to put a human face on the topic. __ Nancy Peter, a 71-year-old retired grandmother, has been repaying her student loans for nearly 40 years. Despite her consistent payments, her debt has ballooned to approximately $108,000 due to accumulating interest. Nancy's situation underscores the challenges faced by long-term borrowers, especially those on income-driven repayment plans where payments may not cover accruing interest. The Court's ruling means that borrowers like Nancy, who might have benefited from the proposed debt relief, continue to grapple with substantial financial burdens. (Insert Above: Provide a short testimonial or description of a real life person or business that is actually harmed or negatively affected by this administrative agency’s rule, regulation or action)

· Describe to the reader the good/bad of the agency rule, regulation or action The regulation aimed to cancel up to $20,000 per borrower, helping millions of Americans reduce or eliminate their student debt burden. Forgiving loans could have freed up funds for consumer spending, homeownership, and investment, boosting the economy. The plan disproportionately benefited low-income borrowers and communities of color, who are more likely to struggle with repayment. With many borrowers behind on payments, debt cancellation could have prevented defaults, protecting credit scores and financial stability.

· Was there any estimate as to the economic impact of the rule, regulation or action taken? The proposed student loan forgiveness program by the U.S. Department of Education was projected to have significant economic implications. Estimates of the program's cost varied among analysts: University of Pennsylvania's Wharton School estimated that forgiving up to $10,000 per borrower would cost approximately $300 billion over a 10-year period.

II. Legal Section (worth 2.0 points)

1. Introduction to Legal Section

· All administrative agencies are created by “enabling legislation”—research and cite the enabling legislation that created your specific administrative agency. The Department of Education Organization Act (Public Law 96-88), which was passed in 1979, created the Department of Education. The Department was given the power to oversee federal student loans and other education programs by this act. The Act gives the Secretary of Education the jurisdiction to "establish, operate, and oversee" student financial aid programs, including the right to create rules pertaining to loan forgiveness.

Citation: Department of Education Organization Act, 20 U.S.C. § 3401 et seq.

Link:  https://www.govinfo.gov/content/pkg/USCODE-2011-title20/pdf/USCODE-2011-title20-chap48-subchapI.pdf

· ( Insert Above: Find this enabling legislation (actual statute or federal code provision) that created and empowered your agency, cite it, and link it into your paper.

· Rulemaking or Adjudication---explain this two ways in which administrative agencies act and how they are different and which one requires more “due process” and why.__ Rulemaking and adjudication are two ways administrative agencies operate. Rulemaking involves creating regulations through a structured process that includes public notice and comment but generally requires less stringent due process since it establishes general rules. In contrast, adjudication resolves specific disputes related to these rules, involving hearings where evidence is presented, thus necessitating more robust due process protection, such as the right to hearing and the opportunity to appeal decisions. Essentially, rulemaking sets the framework, while adjudication applies to individual cases, with adjudication requiring more due process due to its direct impact on individual rights. __________________( Insert Above: which one required more “due process”?) Now which one was used to make your rule, regulation or action? Explain why you concluded this way.

B. Statement of Relevant Legal Principles and Rules of Law

· Conduct Legal Research and find when the rule, regulation or action was noticed and published to the public in the federal registry or corresponding state publication---give the citation to the notice and opportunity to be heard publication and hyperlink it in your paper in this section.

https://www.federalregister.gov/documents/2024/04/17/2024-07726/student-debt-relief-for-the-william-d-ford-federal-direct-loan-program-direct-loans-the-federal

· Explain generally how any rule, regulation or action can be challenged under Due Process (both Procedural Due Process and Substantive Due Process). Explain the legal elements involved when a court decides these due process attacks on administrative regulation.

· Can this controversial rule, regulation or action be challenged under either of these?

· If so, how so. If not, why not.

Has your specific rule, regulation or action spawned any litigation or appeals? If so, cite the case and/or administrative holding, explain the litigants (involved parties) the facts of the case, and the ultimate holding of the case. You can find court appeals cases via the link https://scholar.google.com/ (Google Scholar) or other legal research links found in our Modules CANVAS classroom near the bottom of that page. _

Due Process Challenges

• Procedural due process allows for the challenge of administrative norms.

Demands that the rulemaking procedure be impartial, open, and open to public comment.

The American Psychological Association requires notice, comment periods, and feedback consideration.

Substantive Due Process: Ensures that the rule does not violate constitutional rights or exceed the agency's statutory authority.

• There were two reasons why the loan forgiveness rule was contested. Under the Higher Education Relief Opportunities for Students (HEROES) Act of 2003, which gives the Secretary of Education the power to change or waive student loan restrictions in times of national emergency, the Department of Education was accused of going beyond its legislative jurisdiction. Critics argued that the HEROES Act did not justify the rule's expansive application.

Litigation and Supreme Court Ruling

• The rule led to a great deal of litigation, which resulted in the 2023 Supreme Court case Biden v. Nebraska. The plaintiffs, which included a number of states and individual borrowers, contended that the rule placed an excessive burden on taxpayers and went beyond the Department's power. Citing unclear congressional authorization for such a broad program, the Supreme Court declared that the rule was illegally issued.

Citation: Schumm, M. E. (2023). Biden v. Nebraska. Ohio NUL Rev., 50, 175.

( Insert Above: Insert any cases and links to articles or cases that you found so far )

1. Legal Conclusion as to if the agency’s rule, regulation or action was legal and provided “due process” through its enactment (then transition to Ethics Section) Due process and statutory authority issues were the main causes of the major legal challenges against the Department of Education's loan forgiveness rule. The HEROES Act raised concerns about the rule's substance constitutionality even though it complied with APA procedural criteria. The Supreme Court's ruling emphasizes how crucial explicit congressional approval is for significant policy changes. Despite having a good procedure, the rule's passage ultimately lacked the statutory basis required to stand up to legal examination.

III. Ethics Section (worth 15 points)

Introduction to the Ethical Section: Explain to the reader the difference between law and ethics. _ A legal system is a set of guidelines that are upheld by a governing body and are intended to preserve justice and order in a community. Contrarily, ethics refers to moral standards that direct behavior on an individual or group level and frequently go beyond the requirements of the law. Ethics are based on cultural, philosophical, or individual ideals and are subjective, whereas laws are defined and enforceable.

( Insert Above: Describe the difference between law and ethics). Define what ethics means. _ The study of ethics focuses on ideas like justice, fairness, and right and wrong as well as the moral rules that guide behavior. The following is a practical definition of ethics: "A set of moral principles that guide decision-making and behavior, emphasizing the welfare of individuals and communities."

( Insert Above: Describe what ethics means. Provide a workable definition)

· Explain why government administrators are held to a heightened level of ethical standards as compared to general business managers

Some feel that law and ethics are the same, explain this thought process called “legal positivism” and define this approach and its soundness. ___ A philosophical perspective known as legal positivism maintains that morality and the law are two distinct fields. According to this theory, a law's legitimacy is established by its correct legal procedures rather than by its moral substance. To put it another way, whether or not a legislation is in line with moral standards, it is still enforceable if it was drafted by a recognized authority and adheres to established legal procedures.

( Insert Above: define what “legal positivism”)

Under “legal positivism” approach, is your rule, regulation or action ethical? _ The morality of the Department of Education's loan forgiveness policy is unrelated to its legality, according to the legal positivist perspective. According to this view, a rule would be deemed legitimate even if it presented ethical questions if it was implemented through the appropriate legal processes. Nonetheless, the Supreme Court's decision that the regulation was issued incorrectly implies that it did not adhere to legal positivism's procedural standards.

· ( Insert Above: Is your agency rule, regulation or action ethical under this theory or not? Explain.

· Is “legal positivism” a sound theory for a responsible administrator to adopt? Debate this in this section of the paper.

Legal positivism has drawn criticism for separating morality from the law, even if it offers a clear framework for assessing the legitimacy of laws. Critics contend that, provided the right procedures are followed, this strategy might justify unfair laws. Since legal positivism ignores the moral consequences of policies, it may not be enough for a responsible administrator. In order to guarantee that laws not only adhere to legal procedures but also advance society welfare and justice, a more balanced approach would incorporate ethical considerations like utilitarianism and deontology.

·

B. Is your agency rule, regulation or action ethical under the “utilitarianism” ethical theory?

Explain the ethical theory of “utilitarianism” and explain it and how it works. _ Utilitarianism seeks to enhance welfare or general happiness by evaluating activities according to their effects. If the loan forgiveness law increased economic mobility, lessened financial stress for millions of borrowers, and promoted economic growth, then it might be morally right from a utilitarian standpoint. Critics may counter that the program could worsen economic disparity and unfairly burden taxpayers.

· ( Insert Above: Provide here an explanation of the Utilitarianism ethical theory and how it works and what it focuses on.)

· Explain the groups or individuals affected by this agency’s rule, regulation or action – this means you MUST identify and list EACH affected group of individuals and explain the affects upon them by this action (good or bad affects). You should actually list them one by one and explain their interests and if their interests are negatively or positively affected by the agency’s rule, regulation or action .

Affected Groups and Their Interests:

· Borrowers of student loans: o Benefits: Millions of borrowers would see a considerable reduction in or elimination of debt as a result of the rule, which would ease their financial burden and enhance their standard of living. Greater economic mobility, more disposable income, and increased economic engagement could result from this. o Adverse Repercussions: Borrowers who are not eligible for forgiveness could feel excluded, which could cause them to feel unfairly treated and resentful. Taxpayers: o Benefits: The rule may encourage economic growth by lessening the debt load on borrowers, which could eventually result in better tax collections. o Adverse Effects: Taxpayers would be responsible for the immediate cost of loan forgiveness, which might result in higher taxes or the reallocation of public finances from other important sectors.

Educational Institutions: o Benefits: Lower student loan debt may inspire more people to seek higher education, which might boost enrollment and income for academic institutions. o Adverse Effects: Financial stability may be impacted if institutions are under pressure to reduce tuition costs or expand financial aid. Government (Department of Education): o Benefits: By strengthening the Department's standing as an engaged player tackling a pressing issue, the rule may boost public confidence. Adverse Impacts: The Department's authority may be weakened and its operations may come under closer scrutiny as a result of the legal issues and possible overreach.

Economy:o Benefits: Lower debt levels may result in higher savings rates, more consumer spending, and general economic expansion. o Adverse Repercussions: The initial outlay for forgiveness may put a burden on the federal budget, which could result in lower financing for other programs or inflationary pressures.

· Under Utilitarianism, is your agency rule, regulation or action ethical? To reach this conclusion, you MUST weigh each of the stakeholder’s interests against each other to find the “greatest” good. This way you support your ultimate conclusion under the Utilitarianism ethical model .

· Do you feel that the agency rule, regulation or action is unethical under utilitarianism?

· Why/why not? The loan forgiveness rule may be supported from a utilitarian perspective if the total benefits (happiness and well-being) outweigh the drawbacks (pain and financial strain). The rule might significantly improve the lives of millions of borrowers, spur economic growth, and improve people's quality of life. However, it is crucial to thoroughly examine both the immediate financial cost on taxpayers and any potential discrepancies among borrowers. ( Insert Above: State your conclusion under Utilitarianism model if the your agency rule, regulation or action is producing more “good” or “harm” and if it is more “good” then your agency rule, regulation or action is ethical. If it is causing more “harm” then your agency rule, regulation or action is unethical.)

1. Is your agency rule, regulation or action ethical under one more ethical theory (of your choice) using the theories listed in on CANVAS classroom at the bottom of the “modules” page?

· Explain the ethical theory of your choice. ___ Deontology is concerned with the morality of deeds rather than their effects. This framework prioritizes responsibilities, guidelines, and values. If the rule is in line with deontological ideals of justice and fairness, like helping those who are in debt, then it may be considered moral. Nonetheless, the rule can be in violation of the obligation to respect constitutional procedures if it is perceived to circumvent legislative power.______________________________________________________________________________________________________________________________ ( Insert Above: Identify the 3rd ethical theory you will use in your paper to evaluate if the agency rule, regulation or action is ethical or not.) and explain it and how it works To assess the ethicality of the loan forgiveness rule under  Deontological ethics, we focus on the principles and duties involved rather than the consequences of the action.

· Deontological Ethics: This ethical theory, primarily associated with philosopher Immanuel Kant, emphasizes the importance of following moral rules or duties regardless of the outcomes. According to deontological ethics, actions are considered ethical if they adhere to established moral laws or principles.

· ( Insert Above: Explain briefly how this 3rd ethical theory works)

· Apply this third ethical theory you have selected to your rule, regulation or action:

· Explain under this theory if your rule, regulation or action is ethical under it and explain why/why not. __  Under Deontological ethics, the ethicality of the loan forgiveness rule can be ambiguous. It may be viewed as ethical if it aligns with the moral duty to help those in need, but it could also be criticized for potential unfairness and for not adhering to legal and procedural norms. __________________________________________________________________________________________________________________________________________________________________________( Insert Above: When applying your third ethical theory explain if this rule, regulation or action is ethical under it and explain why/why not.)

1. How do you feel personally---is this agency rule, regulation or action ethical? Explain your position and logic. _____________________________________________________________________________________________________________________________________________________________________ ( Insert Above: Do you, or if you did your paper in a team/group, feel personally that this agency rule, regulation or action is ethical? Why/why not? )

IV. Community Welfare Section (worth 5 points)

A. Administrative Agencies are branches of the government at different levels (federal, state and local) that carry out “social policies” of the government. Explain what a “social policy” is relative to administrative agencies and governments and give some past “social policies” that our federal government has furthered in the past. Here is a good video link to help you understand this: https://www.youtube.com/watch?v=mlxLX8Fto_A

Government initiatives aimed at addressing societal problems and advancing population welfare are known as social policies. Examples from the past include Social Security, the Affordable Care Act, and the New Deal initiatives.

What “social policy” is your administrative agency’s rule, regulation or action promoting? _ An implied social objective of lowering economic inequality and expanding access to higher education is supported by the loan forgiveness provision. By giving borrowers instant financial relief, the rule hopes to increase their economic mobility and general well-being.

Explain if there is an express social policy or an implicit social policy being promoted by your agency rule, regulation or action. Will the administrative agency’s rule, regulation or action be effective in promoting this “social policy”? Why/why not? Or is the articulated “social policy” really a “false flag” (or a distraction from the truth) to further some alternative government agency goal (good or bad)?

B. If successful, will the administrative agency’s rule, regulation or action be beneficial to the community, industry or population’s welfare it regulates? Why/why not? Given its legal issues and the possibility of rising national debt, the rule's ability to advance this social goal is in doubt. Although the rule would offer debtors a great deal of relief, its long-term effects on the economy and tax burden might make it less effective.

C. Community Welfare Recommendations : If you feel that the government agency rule, regulation or action is furthering a dangerous, unethical or improper social policy---explain a way to make the agency rule, regulation or action more positive and improve the community welfare of those being regulated by the rule, regulation or action.

Targeted Relief: For low-income borrowers most in need of financial support, offer loan forgiveness or lowered interest rates. Student Loan System Reforms: Put in place measures like expanding income-driven repayment programs and boosting financing for public universities to lower the cost of higher education and avert future student debt crises. Public-Private Partnerships: Promote collaborations between the public and private sectors to give students access to other funding sources, like income-share plans. ( Insert Above: What are some of your specific suggestions that you would offer the administrative agency that are credible and feasible to do, that would improve community welfare. Be specific. Make recommendations on a new approach or direction of the agency if necessary and propose directly some programs it can sponsor to improve community welfare. )

D. Community Welfare Conclusion

V. Conclusion (worth .50 points)

A. Restatement of Major “3 Value” Conclusions

Legality: The Supreme Court ruled that the rule was unconstitutional because it went beyond the Department of Education's legislative power. Morality: The rule's morality is conflicted, with deontological justification for its intention to rectify structural injustices and utilitarian worries about its long-term effects. Community Welfare: The rule's capacity to advance social policy is weakened by possible economic repercussions and legal challenges.

1. Overall Conclusions, Personal Opinions, Recommendations, and Predictions

Although it was poorly implemented, the 2023 loan forgiveness rule is a daring attempt to address the student debt situation. To improve community welfare and address the root causes of student debt, a more well-rounded and legally sound strategy—such as targeted relief and structural reforms—would be more successful. Policymakers should concentrate on developing long-term solutions going ahead that strike a compromise between the demands of borrowers and the wider economic ramifications. In addition to offering practical suggestions for future policy development, this paper offers a thorough assessment of the loan forgiveness law, providing insights into its morality, legality, and effects on community welfare.

Style & References (worth .50 points)

Research sources (six minimum; current; primary sources or “strong” secondary) ·APA style for sources and citations

Cilluffo, A., & Fry, R. (2024, September 18). 5 facts about student loans. Pew Research Center; Pew Research Center. https://www.pewresearch.org/short-reads/2024/09/18/facts-about-student-loans/

Congressional Research Service. (2022). The Higher Education Act (HEA): A Primer. https://crsreports.congress.gov/product/pdf/R/R43351

Hanson, M. (2023, September 20). Effects of Student Loan Debt on Economy [2021]: Data Analysis. Education Data Initiative. https://educationdata.org/student-loan-debt-economic-impact

House Committee on the Budget. (2024, June 21). Via Forbes: CBO: Cost of Federal Student Loans Nears $400 Billion | The U.S. House Committee on the Budget - House Budget Committee. House.gov. https://budget.house.gov/press-release/via-forbes-cbo-cost-of-federal-student-loans-nears-400-billion

Supreme Court of the United States. (2023). SUPREME COURT OF THE UNITED STATES. https://www.supremecourt.gov/opinions/22pdf/22-506_nmip.pdf

Wells, M., & Clayton, C. (2019). Chapter 5: Ethical & Legal Issues in Education. Viva.pressbooks.pub. https://viva.pressbooks.pub/foundationsofamericaneducation/chapter/chapter-5/

( Insert Above: List at least six (6) academic credible resources so far that you have relied upon or found and intend to use in your final paper. Place them in APA formatting which means more than just supplying a URL).

·Consistency of style among sections

·Grammar, spelling, and punctuation

·Lucidity and “flow” of writing ·Integration of paper