Garden Grove Education Association Fresno Teachers Association Oakland Education Association Sacramento City Teachers Association Santa Ana Education Association Teachers Association of Long Beach United Teachers Los Angeles United Educators of San Francisco June 12, 2013 Dear Mr. Miller: Recently, a few of us received your invitation 'to go through the application' submitted for a waiver to the federal No Child Left Behind (NCLB) that was developed by your private consulting firm, the self-styled California Office to Reform Education (CORE). You cite the work of Michael Fullan and Andy Hargreaves as being at the core of your approach. We respect the efforts of Professors Fullan and Hargreaves and appreciate Dr. Fullan's willingness to facilitate a conversation. However, we must decline your offer. We have profound criticisms of the current NCLB regime and its corrosive effects on public education. We believe NCLB has served to fracture a public education system stressed by years of disinvestment and neglect. As educators and advocates we are committed to improving the conditions of teaching and learning, advancing the cause of free, universal and quality public education and ensuring that the dignity and civil rights of all children are protected. We believe your plan undermines and weakens a comprehensive and coherent approach to improving our public system. Instead, it allows CORE to establish and operate a privatized 'shadow' system of education in California, making students susceptible to market exploitation and profiteering. ? Memoranda of Understanding: The superintendents leading the nine core districts signed a memorandum of understanding. Noticeably absent from these documents is any evidence of the agreement or engagement of other stakeholders. These agreements should describe the consortium governance structure and the individual LEA's role in the structure. In the more than four years since this document was first drafted, there is still no transparency or explanation about the role of stakeholders, like our associations, in the governance of the consortium. Frankly, we are surprised that no draft of the scope of work for implementing this plan accompanied the invitation. ? An Incomplete Assessment System: The plan metrics for monitoring and reporting student growth are both incomplete and out of sync with the state's planned transition to a new assessment system. In determining student growth for preschool to thirdgrade students, measures of student achievement should be developmentally appropriate and, to the extent possible, reflect assessments in a comprehensive assessment system. This consideration remains unclear in this application. In addition, the timeline for implementation does not fully encompass or account for the systemic issues related to the transition to the Common Core assessments. For example, as part of the 2013-14 field testing of the SBAC assessment, California must administer the assessment to 1.8 million students statewide. Many CORE school sites will participate out of necessity. Lacking cut scores, achievement level descriptors, and a policy for interpolating these new assessment outcomes to the old assessment matrix, your plan gives nothing more than lip service to accountability. ? The Wrong Drivers for Educator Evaluation: Our core values about educator effectiveness are anchored in seventeen (17) principles which take aim directly on changing the culture of teaching and learning. Our principles are aligned to Dr. Fullan's ideals for building capacity, sustaining a learning community, improving pedagogy, and the type of reciprocal accountability that mandates whole system changes to improve the conditions for teaching and learning. Your plan mandates an evaluation system that is clearly divergent in intent and practice from these ideals. ? The Wrong Drivers for Education Reform: In contrast to the work of Dr. Fullan, we doubt the plan's weighted focus on accountability, silver bullets of unproven reforms, and a fragmented arc of monitoring and oversight will lead to improvement. The mandates of the ESEA waiver for which you are seeking with this plan are actually antithetical to the ideals of Dr. Fullan. CORE can never establish the right conditions for whole system reform and meet the mandates of the ESEA waiver at the same time. As reflected in the work of Fullan and Hargreaves, any effort to foster 'whole system reform' and promote the development of 'professional capital' in renewing, rebuilding and transforming the public education system in California must involve and, as you note, is the responsibility of the 'entire school community'. This must include educators and their representatives, as well as other stakeholders, in meaningful decision-making roles throughout that process, including its design, development and ultimate execution - not as an afterthought. It is, indeed, unfortunate that this request for participation and dialogue has come at the end of your process rather than in the beginning stages. We will continue to be involved in the work of whole system reform of public education. We will conduct that undertaking in each and every community across California as a new funding system that focuses on the needs of students who need help the most is implemented. We are committed to participating with our students, parents and the communities in which we live and work in that effort. We look forward to engaging the school boards and administrators of the 1000 school districts and County Offices of Education as we seek to establish a just, democratic and equitable society in California. Respectfully, President, UTLA President, OEA President, GGEA President, UESF President, SCTA President, TALB President, SATA President, FTA President, CTA