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August 21, 2009 VIA eRulemaking Portal: www.regulations.gov Secretary of Education Arne Duncan c/o Office of Elementary and Secondary Education Attn: Race to the Top Comments U.S. Department of Education 400 Maryland Avenue, SW, Room 3W329 Washington, DC 20202 Re: Race to the Top Fund
The National Education Association appreciates the opportunity to comment on the Notice of Proposed Priorities, Requirements, Definitions, and Selection Criteria published in the July 29, 2009 Federal Register regarding the Race to the Top Fund.
On Friday, July 24, 2009, the Department of Education unveiled a package of proposals and priorities designed to invite comment on ways to reform the public education system in this country—the Race to the Top proposal subsequently was published in the Federal Register. It is clear that this Administration cares about students and it is clear that NEA and this Administration share the same goal: to dramatically transform the public education system so that every public school is a center of excellence and all students gain the skills and education they need to become lifelong learners and healthy, productive citizens in this global society.
Admirable Goals NEA appreciates that the Obama Administration is speaking out about a crucial truth: The current system is failing many students. If nothing changes, up to half of America’s school children who are poor and minority will not graduate from high school—a situation that is not only deplorable, but criminal as well.
NEA applauds the Obama Administration for keeping its commitment to deliver resources to support and improve the public education system. Earlier this year, the American Recovery and Reinvestment Act (ARRA) was enacted, and in July, the Administration unveiled $4.35 billion of those funds as part of the Race to the Top competitive grant program. With the other grant funds described that day, the federal investment will be close to $10 billion. NEA applauds the Obama Administration’s commitment to students at risk—the grant funds are targeted to schools in the highest poverty areas.
NEA applauds the fact that the RTTT grant applications require the support of teachers and other school staff—for far too long the voices of educators have been ignored.
NEA applauds the fact that the RTTT grant competition will require states to adopt internationally recognized high standards, as well as better tests and more comprehensive tracking of multiple lines of evidence of student achievement.
NEA applauds the fact that the Obama Administration continues to emphasize the importance of teacher quality in student success, and that schools that face the toughest challenges must have the most talented, qualified people available.
Proposal Misses the Mark Up to this point, the NEA has been a vocal supporter of the Obama Administration’s plans to transform public education by being “tight” on goals, but “looser” in how you achieve them. We were in total agreement with the sentiments expressed by Secretary Duncan in a speech at the National Press Club on May 29, 2009 when he said: “You know, when I was in Chicago, I didn’t think all the good ideas came from Washington. Now that I’m in Washington, I know all the good ideas don’t come from Washington. The good ideas are always going to come from great educators in local communities. And we want to continue to empower them.”
Given the details of the July Race to the Top grant proposal, NEA must now ask: Where did that commitment to local communities go?
The details of the RTTT proposal do not seem to square with the Administration’s earlier philosophy. The Administration’s theory of success now seems to be tight on the goals and tight on the means, with prescriptions that are not well-grounded in knowledge from practice and are unlikely to meet the goals. We find this top-down approach disturbing; we have been down that road before with the failures of No Child Left Behind, and we cannot support yet another layer of federal mandates that have little or no research base of success and that usurp state and local government’s responsibilities for public education.
Instead of focusing on strengthening enforcement of civil rights laws to promote access and opportunity for students, the Administration has chosen the path of a series of top-down directives that may discourage rather than encourage productive innovation in classrooms and schools across the country. Despite growing evidence to the contrary, it appears that the Administration has decided that charter schools are the only answer to what ails America’s public schools—urban, suburban, exurban, and rural—and all must comply with that silver bullet, despite the fact that charters have often produced lower achievement gains than district-run public schools.
We urge the Administration to step outside of this narrow agenda and embrace the diversity of choices available to students, parents, school districts, and states across the country. Well-designed charters are not the only way to innovate, and we need to embrace and champion other models such as magnet schools.
Assessing student learning is another area where we need more and better options. What is being proposed is simply tweaking the current top-down, federally mandated insistence on hewing to standardized test scores. We know that model is not working, so basing even more educational decisions on these same test scores is counterproductive and counterintuitive. Enough is enough.
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In addition to these overall comments, we have provided detailed comments below on several priority issues.
Thank you in advance for your consideration of NEA’s comments and we look forward to discussing this matter with the appropriate staff. I can be reached via telephone at (202) 822-7946 or via email at [email protected].
Sincerely,
/Kay Brilliant/
Kay Brilliant, Director Education Policy and Practice Department
WaPo took an indepth assessment paper and turned it into "attack"
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