1. De-registration after maximum period of study
The standard period of study is 6 semesters for a Bachelor's degree and 4 semesters for a Master's degree. The initial draft proposal to set a maximum period of study at 1.5 or 2 times the standard period of study would mean that a Bachelor's programme would now have to be completed within a maximum of 9 or 12 semesters, and a Master's programme within 6 to 8 semesters. Due to time pressure, students will enrol in more seminars than they can handle, leading to inadequate preparation and motivation, which in turn results in a loss of quality in teaching. 
These regulations restrict students and disadvantage those who have other commitments alongside their studies. Students who suffer from health problems must provide medical certificates. Those who provide care work must prove this, as must students who are involved in university politics, voluntary work or other activities. Students who have to work alongside their studies in order to finance them would be pushed into an even more precarious situation by the planned restructuring of the framework regulations. 
The possibility of proving these burdens and obtaining an extension cannot compensate for this structural disadvantage. On the one hand, some of these additional burdens are simply not verifiable, and on the other hand, the sheer number of applications will place an excessive burden on the administration responsible for processing them, which is why extreme waiting times are to be expected. In addition, decisions on applications of this kind are often made to the detriment of students. It is also questionable how it can be ensured that additional semesters really compensate for disadvantages that cannot be measured solely in terms of time. 
The planned amendment to the framework regulations would exacerbate the structural disadvantage of a large group of already overburdened students and lead to a de-democratisation of higher education. This is particularly because the restructuring would make it extremely difficult to engage in higher education policy (Hochschulpolitik) and student councils (Studierendenvertretung). The amendment would thus accept the demise of those institutions that are already weakened but are necessary for the democratic functioning of higher education and indispensable in countering the growing right-wing tendencies.  

2. German as an obligation? 
According to the initial draft, international students and students whose native language is not German will be required to provide proof of German language proficiency by the third semester of their BA programme, even if they are enrolled in programmes taught entirely in a foreign language. This regulation discriminates against these students and contradicts Goethe University's internationalisation efforts. It is not clear how such a regulation relates to the academic success of these students, especially since they are enrolled in foreign-language degree programmes. The rationale behind this is to promote integration and improve opportunities on the labour market. Behind this lies a questionable concept of integration, which the university is trying to force on international students by means of the framework regulations. Goethe University must trust in the personal responsibility and initiative of its students, who must be able to decide for themselves to what level learning a language is relevant for their studies – and for their ‘integration’. In the context of the internationalisation of teaching, such a focus on the German language is not conducive to achieving this goal and privileges native German speakers.

These two criticised aspects are examples of how the planned framework regulations curtail democratic participation opportunities at the university and patronise the student body. They are examples of how the self-administration of the departments is endangered by imposing disproportionate restrictions on what a degree programme should look like. The Presidium has no right to dictate to students or the democratic bodies of the departments to this extent how they should organise their studies and degree programmes. Students need the opportunity to choose their course content independently and on their own responsibility, to take examinations and to get involved outside of lectures and examinations – these goals should form the basis for the new framework regulations! 
We support the Student Council Conference (Fachschaftenkonferenz) with its position paper, which formulates further points of criticism of the framework regulations, such as the specification of CP steps, which would severely restrict science degree programmes.

We call on the executive Committee (Präsidium) of Goethe University to delete the criticised changes without replacement and to revise the framework regulations taking into account the above-mentioned goals!

Translated with DeepL.com (free version)