I was discussing this the other day and we thought, take Gove's argument - 'some schools are achieving this [outcome] despite the context and thus all schools should stop citing context' - and apply this to schools' leaders and managers. Some school leaders and their managers do create a positive place to work. These schools do not have high levels of churn and their teachers are inspired to work under the good leadership. Some school leaders and their managers misinterpret government and OfSTED policy and create unnecessary workload and use bullying tactics to achieve their targets. Most schools exist within the spectrum of the two. Thus isn't part of the answer improved leadership and management selection and training? Some schools are selecting the wrong people as managers and/or not providing good training to them. And then OfSTED and all its idiocies etc., I grant.