This article points to two major issues with cognitive load theory. First, "germane cognitive load makes cognitive load theory unfalsifiable... (but) Unless a theory can make predictions that can be tested as right or wrong, it is an unscientific theory." Second, the theory can't really "explain the potentially conflicting experimental results where both raising and lowering cognitive load can lead to better outcomes under different circumstances." That (to me) is why the advice coming from cognitive load theorists to always lower cognitive load sounds so unintuitive.
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