CALIFORNIA DEPARTMENT OF EDUCATION CALIFORNIA STATE BOARD OF EDUCATION TOM TORLAKSON, State Superintendent of Public Instruction 916-319-0800 1430 N Street Sacramento, CA 95814-5901 MICHAEL W. KIRST, President 916-319-0827 January 6, 2017 The Honorable Ann Whalen, Senior Advisor Office of Elementary and Secondary Education U.S. Department of Education 400 Maryland Avenue, SW Washington, DC 20202 Dear Senior Advisor Whalen: California is writing in order to provide additional material in advance of our scheduled January 6, 2017, appeal hearing concerning California’s request for a waiver to implement its transition plan for administering new general and alternate science assessments aligned to the California Next Generation Science Standards (CA NGSS). In early 2016, California requested a waiver to eliminate double testing eligible students as the State continues development of assessments of aligned to the CA NGSS. California’s request came shortly after our receipt of a letter from Secretary King to the Chief State School Officers describing President Obama’s Testing Action Plan (Plan), dated February 6, 2016: The Plan encourages States and school districts to tackle instances where students spend too much time taking standardized tests, as well as instances where such tests are redundant or fail to provide useful information. The Administration is committed to supporting States, districts, and schools in administering high-quality and fair assessments that take up the minimum necessary time, and reflect the expectation that all students will graduate collegeand career-ready… The bipartisan ESSA takes additional steps to support smart, effective assessments and to reduce overtesting, including efforts to encourage States to limit classroom time spent on statewide standardized testing and to strive for continued improvement and innovation in assessments…The Administration looks forward to implementing the ESSA in a manner that better assists States and school districts in addressing the challenge of overtesting. Ann Whalen, Senior Advisor to the Secretary January 6, 2017 Page 2 We believe that President Obama’s Testing Action Plan—and Congressional intent regarding assessments in the newly-reauthorized ESSA—align with California’s intentions in requesting a double-testing waiver on these CA NGSS-aligned assessments. California respectfully requests that you consider this additional information in support of the waiver request, and allow California to:  Pilot and field test new CA NGSS-aligned assessments without creating unduly and burdensome double-testing for all eligible students enrolled in grades five, eight, and high school;  Discontinue administration of the current science assessments that are based on outdated science standards that are no longer supported by daily classroom instruction; and  Temporarily suspend the required reporting of individual student scores for the 2016–17 and 2017–18 school years (SYs) for the CA NGSS general education assessment, and 2016–17 through the 2018–19 SYs for the alternate CA NGSSaligned assessments. California intends to publicly report student participation rates at school-, district-, and county-levels for both the pilot and field tests for both the CA NGSS-aligned general education and alternative assessments. This waiver request is similar to the waiver that California received from the U.S. Department of Education (ED) in 2013 for English language arts (ELA) and mathematics assessments during the State’s transition to assessments aligned with the Common Core Standards (CCSS). The 2013 waiver significantly contributed to the smooth and successful transition to the new Smarter Balanced assessments aligned to the CCSS. The process yielded positive media exposure for the country’s most populous state, highlighting high participation rates and widespread public support for the standards and assessments. The ED served as a key partner with California during that successful transition. California hopes this partnership may continue as California continues the difficult work of developing CA NGSS-aligned assessments to enable appropriate reporting of educational opportunities for California students. By approving this waiver request you will issue an important signal of support for California’s efforts to transition to the new science standards and assessments using a process that replicates the successful transition to the new ELA and mathematics standards and assessments in 2013-14. Ann Whalen, Senior Advisor to the Secretary January 6, 2017 Page 3 California’s transition plan to administer CA NGSS-aligned assessments provides an efficient and effective transition to support and inform instruction focused on these rigorous standards. Honoring the waiver request will ensure full implementation of the new science standards sooner rather than later, enable a successful transition to the new assessment protocol, and allow more accurate reporting of students’ progress in learning the new standards when the new assessments are fully operational. Rushing assessment development, especially new computer-based assessments, has proven to be unsuccessful, as evidenced by the first year of nationwide ELA and mathematics assessments; many states had technical malfunctions and were unable to provide results to parents and the public. California avoided this by receiving a waiver and conducting a census field test. In the last two years California has successfully tested 3.2 million students; only 900 students needed to take the test on paper/pencil due to the technology infrastructure established by the State and local educational agencies (LEAs) and the field test experience to ensure a successful transition. By taking a deliberative approach, California was able to establish a coalition of all major stakeholders in support of the ELA and mathematics standards and assessments which has resulted in ongoing support and an extremely low opt out rate of less than 1 percent. California is seeking to repeat that same success for the CA NGSS. Similar support has already been gathered, as evidenced by the numerous letters of support for our waiver from all major stakeholders, with no opposition. Requiring students to complete two different assessments on different standards represents a misuse of crucial instructional time and will likely produce mixed and confusing results to students, and their teachers, and parents. Data from current tests will not provide accurate, usable information to students, educators, or parents about students’ progress in mastering new California State Board of Education (SBE) adopted standards. In fact, it may provide information to parents which is confusing or conflicts with other information they receive about student progress and could provide misleading information on schools’ science education programs. California believes the most valuable information parents receive about their child’s science achievement comes directly from their child’s teacher throughout the school year, not from a summative assessment that is only given to students in select grade levels. The absence of a science assessment for a period of two years will not impact the most valuable information provided to parents regarding student achievement. As you mentioned in your letter on December 13, 2016, California may wish to combine items from the assessments aligned to the previous science standards with items from the CA NGSS-aligned pilot assessments. This proposal may be plausible in a state that is changing only to a new assessment, and not also to new standards. Because such a proposal would be based on items aligned with previous standards, it would incentivize Ann Whalen, Senior Advisor to the Secretary January 6, 2017 Page 4 LEAs to maintain instruction and materials based on those old standards. Although it would provide results to parents and schools, it would not provide the more important information of how well schools are providing instruction on the new standards, or how well students are learning the new standards. This suggested option discourages LEAs and teachers from focusing on the new standards. Over the last several years California has completely redesigned the accountability system, and has made several significant changes to improve the quality of information reported to parents and to the public. California will release its initial version of state accountability based on multiple measures in the next couple of months. Although science is not required to be part of the accountability system, the SBE has already voted to approve the inclusion of science assessment results as soon as they are available. California's Local Control Accountability Plan requires every LEA to include a progress report on the implementation of standards, including the CA NGSS. Within the State there is widespread support in favor of the waiver; California’s stakeholders strongly oppose the continuation of outdated science assessments. The enclosed letters represent support from a variety of stakeholders that the State has received to date in support of California’s waiver request. Collectively, we find it unfair to continue evaluating student performance using assessments based on outdated standards that are no longer supported by daily classroom instruction. The California Department of Education received no letters of opposition related to the plan to implement the new CA NGSS-aligned assessments. In addition, at a State hearing on this topic in May 2016 there were no comments of opposition. Also enclosed are several editorials and news articles related to California’s waiver request. California is moving together for positive change in order to ensure the best outcomes for our students. If California’s waiver request is denied again, the brunt of the negative impact will not be felt at the State level, but rather locally at school sites by teachers and students. It would be a shame to impede California’s progress toward standards and assessment alignment, as well as the collaborative relationships built between state government, teachers, students, and advocates. Please direct questions regarding this request to Keric Ashley, Deputy Superintendent of the District, School, and Innovation Branch, by phone at 916-319-0637 or by e-mail at kashley@cde.ca.gov. Thank you for your consideration. Ann Whalen, Senior Advisor to the Secretary January 6, 2017 Page 5 Sincerely, Tom Torlakson State Superintendent of Public Instruction California Department of Education Michael W. Kirst President California State Board of Education TT/MK:mr Enclosure cc: Patrick Rooney, Deputy Director, Office of State Support