June 30, 2014 Washington State Board of Education 600 Washington St. SE Olympia, WA 98504 Dear State Board Members; We request that the proposed rules to implement SB 6552 be revised to reflect the intent of the Legislature. Below we enumerate the three major areas where the proposed rules are out of alignment with the letter, spirit or intent of the law. This letter addresses only those concerns that result from the proposed rules to implement the new 24 credit framework for high school graduation. At your recent public forum on June 6th, Reps. Hunt and Reykdal provided public comment based on feedback from the group of legislators who crafted the final version of SB 6552 which passed the Legislature (House 93-5 and Senate 45-2) on March 13, 2014 and was signed into law by Governor Inslee on April 3, 2014. This letter reinforces those comments. Below are three areas where proposed WAC 180-51-068 is inconsistent with legislative intent:  Our intent as a Legislature was to allow the two credit waiver for unusual circumstances to apply to the entire 24 credit portfolio - not just the seven flexible credits beyond the core 17 credits. The goal of this policy was to allow the maximum flexibility to districts in order to meet the unique needs of their students. The proposed rule does NOT allow for this flexibility. The clear intent of the Legislature was to have the Washington State School Directors Association (WSSDA) develop a model policy for districts BEFORE the SBE adopted rules. Otherwise, there would have been no point in our directing WSSDA to develop a model policy. The rules should wait and take into consideration the model policy developed by WSSDA.  The role of the parent or guardian in the decision making process regarding the 3rd credit of math and science is the foremost role. School principal and counselor would be secondary. The rules are not clear on the primacy of the parent/guardian decision.  The SBE has exceeded the intent and scope of the bill by requiring the HSBP to begin in the 8th grade. While we agree that the most promising practices indicate that HSBPs begin in the 7 th or 8th grade, we simply did not get to this issue with any depth in the legislation and therefore enacting a rule to require it in the 7th or 8th grade violates the law at this time. We strongly urge you to make the appropriate revisions to the proposed rules to reflect the actual intent of the Legislature. Sincerely: Sherry Appleton State Representative 23rd Legislative District Susan Fagan State Representative 9th Legislative District Kathy Haigh State Representative 35th Legislative District Brian Blake State Representative 19th Legislative District Jake Fey State Representative 27th Legislative District Larry Haler State Representative 8th Legislative District Vincent Buys State Representative 42nd Legislative District Tami Green State Representative 28th Legislative District Paul Harris State Representative 17th Legislative District Eileen Cody State Representative 34th Legislative District Mia Gregerson State Representative 33rd Legislative District Dave Hayes State Representative 10th Legislative District Jeff Holy State Representative 6th Legislative District Joel Kretz State Representative 7th Legislative District Kevin Parker State Representative 6th Legislative District Graham Hunt State Representative 2nd Legislative District Jim Moeller State Representative 49th Legislative District Chris Reykdal State Representative 22nd Legislative District Sam Hunt State Representative 22nd Legislative District Luis Moscoso State Representative 1st Legislative District Sharon Tomiko Santos State Representative 37th Legislative District Norm Johnson State Representative 14th Legislative District Lillian Ortiz-Self State Representative 21st Legislative District Larry Seaquist State Representative 26th Legislative District Linda Kochmar State Representative 30th Legislative District Jason Overstreet State Representative 42nd Legislative District Elizabeth Scott State Representative 39th Legislative District Mike Sells State Representative 38th Legislative District David Taylor State Representative 15th Legislative District Matt Shea State Representative 4th Legislative District Steve Tharinger State Representative 24th Legislative District Shelly Short State Representative 7th Legislative District Hans Zeiger State Representative 25th Legislative District Monica Stonier State Representative 17th Legislative District cc: Ben Rarick, SBE Executive Director Speaker Frank Chopp Rep. Dan Christiansen Rep. Dan Sullivan Rep. Sharon Tomiko Santos