New York Commissioner of Education Mary Ellen Elia

NYS Education Department Building

89 Washington Street

Board of Regents , Room 110 EB

Albany, NY 12234

Re: 3012-d Public Comment EDU-27-15-00019-P

Dear Commissioner Elia,

Consider this letter my contribution to public comments regarding EDU-27-15-00019-P, in opposition to permanent adoption of this new rule. I have sent this letter to the regents as well, and included my phone number only in the letters to my representative (Regent Tallon) and to you. My hope is that education leaders will truly work for the future good of all by using the suggestions that follow my concerns to consider a more effective path forward. Tests are dipsticks, not care and maintenance.

First, the reasons to oppose adoption of 3012-d Public Comment EDU-27-15-00019-P as a permanent rule:

1)  “Faulty rollout” of the new standards: It is among the reasons cited for the unrest, uneasiness, and displeasure that have arisen regarding the linkage of what were brand new standards, the need to acquire and create curriculum materials tied to those standards…and high stakes tests tying reputations and careers to that faulty rollout.  This new rule would not address the missteps in practice and disrespects to students, citizens and professionals that occurred with that rollout. In fact, this is a move to memorialize one of the biggest missteps, especially since the new tests and testing company haven’t been rolled out yet..

2) Although our governor has taken the positions that: a)  we need a better evaluation system so we can find more teachers to fire; b)  he has no responsibility for education policy (he says this mostly when citizens are unhappy with his approach to education policy)- he has also admitted those faults in the rollout of the new standards. He has also noted the lack of reliability in the tests in accurately gauging student outcomes, and has proclaimed primary importance of parents and kitchen tables as tools for student success. The passage of this new rule puts more focus on entrenching the mistakes and the faults of New York style reform, while ignoring the issues of primary importance. This rule is not an indicator of effective or highly effective policy making.

3)  An approach to APPR so heavily weighted in standardized tests is misguided. While we do need tests to chart student progress toward achieving academic standards, and to inform instruction, the more correlative variables in positive student outcomes are resources and opportunities, not tests and consequences.

Following are my suggestions:

Instead of trying to sell (or impose) the primary importance of tests to people who know that there are so many things more important in the educational experience of a learner-embrace sound pedagogy and practice. Listen to students, parents and concerned citizens and then include the teaching profession in building up learning experiences as opposed to finding someone to blame for the lack of them provided for in policy. Accountability is important-for all of us, and not just for test scores.

Put this new APPR rule at least on hold, and at best in the circular file, while a more holistic and experiential accountability system is created. Think of a portfolio, an ongoing assessment of academic skills, social/emotional indicators, and extra-curricular involvements/experiences…A tracking of the whole child with shared responsibilities between classroom teacher, administrators, school district, family and community… and leaders at the state level. Such a system would have to include regular assessment of essential academic skills, but these could be made far less intrusive on the school schedule and often be completed quickly on a computer and immediately saved as evidence of progress (or not). Third party proctors could be used for the more official assessments, but even then the focus is on building that ongoing resume for our future citizens, not finding someone to blame.  By high school, their portfolio should be showing community service, volunteer activities, leadership roles, internships and college visit records…

Think and reflect on the words of Assembly Speaker Carl Heastie, who in a recent interview acknowledged that educators are often forced to be responsible for a host of burdens that students bring to school with them:

“I really think that we shouldn’t be looking at education alone anymore or mental health alone anymore or poverty alone anymore. I think that we have to look at the total family structure and see why it is that students are going into school not prepared for these challenges. And I think a lot of it has to do with what’s going on at home and their neighborhoods. Even super teacher may not be able to get through to a student whose life outside of school has issues.”

Most of all, we cannot continue letting state education officials and politicians off the hook and/or promoting them onward and upward for little more than lack of honesty and a tin ear. I have personal experience with NYSED’s willingness to self-promote the opportunities it supposedly provides, while at the same time denying that all students have access to those opportunities. “Sadly, that’s the state of funding in our state,” said a NYSED associate to me when explaining why this is the case.

If anything is unethical, it is leadership turning a blind eye to these conditions.

Thank you for considering my position in opposing this rule, and my suggestions for an alternative approach.

Dan McConnell