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The current ACTFL Proficiency Guidelines provide interesting descriptions of expected proficiency by level within the four skill areas. The most measurable feature of proficiency consistently mentioned is the quantity of utterances or text comprehended. At times, characteristics of production are mentioned; however, the vagueness of the descriptors leaves the reader with more questions than answers. Overall, the guidelines most lack measurable features and descriptions of the quality of the skills involved. Qualities of speech such as grammatical complexity, prosody, lexical variety, accuracy, and fluency all seem like obvious choices to assess in a proficiency situation. The ACTFL Guidelines, however, mention these only sporadically and without concrete descriptions of how to gauge them. If these guidelines were to be used to actually place individual learners into levels, there are no quantifiable measures with which to do so. For the purposes of this commentary, the Speaking Guidelines will be analyzed.