May Chapter 13 Plans Discharge Student Loans Without Any Finding of Undue Hardship?

During fiscal year 2008, Federal Student Aid awarded $96 billion in student loans and had an outstanding loan portfolio of over $500 billion. [...] there were 362,762 Chapter 13 cases filed during calendar 2008. Outside the realm of discharge, plans have been confirmed with other kinds of provisions that do not comply with either the Code or the Rules - certain injunctions against third parties, avoidance of liens, recovery of voidable transfers, sales of property, etc. [...] bankruptcy courts confirm plans not only under Chapter 13 but also under Chapters 9 (municipal insolvency), 11 (business reorganization) and 12 (family farmer debt adjustments).