Schools Matter: ESSA: Vermont State Board of Ed Letter to John B. King
Vermont State Board of Education
219 North Main Street, Suite 402
Barre, VT 05641
July 2016
John B. King, Jr., Secretary of Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
Re: Comments on Proposed Rules and Regulations
Dear Secretary King,
The Vermont State Board of Education thanks you for the opportunity to respond to the ESSA
proposed rules. Our Board is proud to represent a state where the people support a strong state
funding system, enjoy schools that foster high student performance and register narrow equity
gaps as compared with the nation. Nevertheless, the opportunity gap is our most pressing
concern and is the number one goal in our strategic plan.
With these traditions and values in mind, we have strong concerns and reservations about
ESSA. Fundamentally, if we are to close the achievement gap, it is imperative that we
substantively address the underlying economic and social disparities that characterize our
nation, our communities and our schools. With two-thirds of the score variance attributable to
outside of school factors, test scores gaps measure the health of our society more than the
quality of the schools.
Consequently, the continuation of a test-based, labeling and “assistance” model (broadly seen
as punishment) has not only proven ineffective, but has had a corrosive effect on the confidence
of the people. The encouragement of privatization has been harmful to local democracy, has
further segregated a too fragmented nation and has diluted rather than focused valuable
resources.
Regarding the draft regulations, we think they go well beyond the role of the federal
government as specified in ESSA. The regulations need to be brought into conformity with the
parameters authorized in law.
We share comments on several specific elements of law and rule:
Education and Accountability is More Than Test Scores: The Narrowness of the Measures – The plan relies on what we can easily measure, rather than on what is important. By requiring that test scores in two subjects and graduation rates be given preferential weight, we discourage schools from supporting truly broad opportunities to learn and the skills necessary for a healthy society. In a world where violence and terrorism command the news, the education of our youth to participate in a Schools Matter: ESSA: Vermont State Board of Ed Letter to John B. King:
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