June 8, 2017 Mike Kirst and Board Members California State Board of Education 1430 N Street, Suite 5111 Sacramento, CA 95814 Dear President Kirst and Members of the California State Board of Education: Thank you for continuing to engage with us about the advantages of establishing an Innovation Zone in California’s school accountability system. We strongly urge the state to take full advantage of the statutory authority granted within the Every Student Succeeds Act (ESSA) to support local innovations. Concerns raised by your staff about equity, learning for the state and timing of our proposal in a May 26 letter are addressed in detail below. Equity for Schools and Students The Innovation Zone purposely advances equity and continuous improvement. The Innovation Zone would permit any school district sharing data within our established network to voluntarily join the zone in order to help the state identify the best measures to include in an accountability model. First, while additional common local measures would be used to identify schools only within the Innovation Zone districts, the waiver would purposely maintain one coherent accountability system. For example, in some of the models for identification of schools (e.g., the “tiered” or “sequential” approach) now under consideration, the list of underperforming schools can be oversampled to start, with additional measures used to narrow the list to the final five percent. While a school identified at the beginning of the process may not be identified at the end, there is no equity issue. This is the way the identification system is intended to work. The Innovation Zone schools would simply go through an additional narrowing process. Second, we were asked by board staff to pursue a legal opinion about “equity,” which we did. We contracted with a leading California education law firm, which produced a legal opinion that concludes, “We reviewed the applicable provisions of the California Constitution, and case law interpreting them, and conclude there is no equity issue related to the proposed waiver.” (The full opinion was included in your May board packet.) Lastly, our districts fully intend to continue to work to address the needs of all students at all of our underperforming schools, not just those identified through the Innovation Zone. We are confident our Local Control and Accountability Plan (LCAP) and executive summary describe in detail our work. LCAPs and accompanying documents will continue to be available to the state and to our school communities. Learning for the State and Districts 1107 9th Street, Ste. 500 Sacramento, CA 95814 916 596-2548 COREdistricts.org The Innovation Zone creates powerful learning to help all of us get better together. Frankly, we were struck and concerned that your letter raised as reason not to support our proposal that CORE is “not sure (we have) picked the right measures.” Continuous learning is not about having the all the answers from the start, nor is it about a single measure. It may be that local measures now in use and under development might fit in a statewide accountability system. The idea of an Innovation Zone purposely creates space for this type of continuous learning and innovation, so we are encouraging local educators to design measures that enhance the reach and power of our accountability system. First, your letter raised skepticism about how the state can draw conclusions from our proposed Innovation Zone. Dr. Heather Hough, the Executive Director of the CORE-PACE research partnership, offers the following perspective: “Local measurement is central to the state’s plan. Yet, there is currently no mechanism to learn about local measures in ways that can be shared statewide. CORE’s Innovation Zone can provide this mechanism. We want to help the state learn, and, through the CORE-Policy Analysis for California Education (PACE) partnership, we can continue to introduce new measurement types, and conduct analyses designed to better understand validity, reliability, and use. Without the Innovation Zone, this is harder, because in order to learn about how data can be used in accountability systems, it must be used in the context of an accountability system. Powerfully, this is not an avoidance of accountability.” Second, our measurements can continuously inform ongoing development statewide. We are currently working to integrate data from the National Student Clearinghouse to better understand how our measures are related to actual college and career outcomes. This is just one example of how we will always be working to advance our collective understanding of student and school performance measurement. Because we are nimble, we can leverage our measurement system and funding infrastructure more quickly than the state to advance learning that benefits everyone. Third, while it is the state’s intent to design a student growth measure, we know there are significant and difficult policy decisions that still must be addressed by the board. The state’s chosen model could be significantly different than the one now used in our system, which could result in important learnings about how these policy decisions translate to action at the school level. Even if our growth models are the same in the end, this is not about a single measure but embedding a system of continuous learning into our state system; we have other differentiating measures in use, in development and under consideration that can be added to inform the state. Fourth, there also is significant learning potential about common surveys simply because the Innovation Zone is voluntary. Through decisions of locally elected school boards, districts participating in the Innovation Zone voluntarily choose to administer a common survey. Then, through the CORE-PACE research partnership, we will learn whether common surveys can help improve student achievement, thus providing the state critical information to make future decisions. California should use continuous improvement principles to build a high-quality state accountability system not based on ideology or personal beliefs, but on data and results. 1107 9th Street, Ste. 500 Sacramento, CA 95814 916 596-2548 COREdistricts.org Fifth, in the spirit of local control, when referencing “the state” we must consider the thousands of local decision makers who will be charged with developing measures and intervention approaches in the years ahead. While it may be true that there is no intention of requiring state measurement on social-emotional learning (SEL), for example, local leaders are very interested in measurement in this domain and contact us regularly to find out what we are learning. This desire to assess SEL is reflected in the California Collaborative for Academic, Social, and Emotional Learning (CASEL) team, which has convened dozens of stakeholders in crafting a vision for how SEL is approached in our state. Our measurement helps everyone learn, not just policymakers in Sacramento. Lastly, what we find most exciting about this proposal is how perfectly it aligns with the state’s vision. The CORE Districts together represent 20 percent of the state’s students, and our 50 Data Collaborative districts add many urban, rural and suburban students and diverse geographies. Dr. Hough went on to state, “Even when participation in the Innovation Zone is voluntary, findings about measurement will be generalizable and absolutely can be used to inform state policy and local learnings.” Timing of the Innovation Zone We must not postpone what we know is the right path forward for students. We respect the board’s need to deliberate in July about district versus school-level support and the identification of and intervention in the bottom 5 percent of schools. We believe, though, a waiver for the Innovation Zone in the July version of the ESSA state plan will be viewed positively by schools, students, parents, educators and stakeholders. Plus, the timing will allow our local school boards and districts to volunteer to be part of the Innovation Zone this summer, before California’s new accountability system begins in the fall. Long Beach Unified and other leading districts are more advanced in using a more complete set of measures to identify strengths and weaknesses in local schools. Districts such as ours that choose to participate in the Innovation Zone can start immediately to inform schools of their status and work with them beginning in 2017-18. The state’s evolving system will immediately benefit by having access to the latest research and findings from schools in the Innovation Zone. Finally, I’d like to speak to definitively identifying which districts will participate. The commitment requires superintendents, including myself, to bring participation in the Innovation Zone to our local school boards for a vote. We are concerned about bringing California’s Innovation Zone to our school communities and trustees without a firm commitment from the California State Board of Education. I am impressed with the level of support for this proposal among my superintendent colleagues, and I feel very confident my board would support participating in California’s Innovation Zone if it becomes a reality. We respectfully request that a waiver be included in the July version of the ESSA plan so local school districts can pursue participation with their locally elected school boards before the start of the 2017-18 school year. In order to purse the Innovation Zone locally, we would also like to request a conference call involving me and some of my superintendent colleagues and you, Vice President Straus and any 1107 9th Street, Ste. 500 Sacramento, CA 95814 916 596-2548 COREdistricts.org other state board members you felt appropriate to discuss our proposal and to try to get to “yes” at the July board meeting. Sincerely, Christopher Steinhauser President of the CORE Districts and Superintendent of Long Beach Unified School District 1107 9th Street, Ste. 500 Sacramento, CA 95814 916 596-2548 COREdistricts.org