Public Education Advocates Request the Department of Education to Halt 306 Rules Revision Until Clear Public Process and Timeline Established
The minimum standards for public education are being redrafted with little transparency or public input
A copy of the below letter was sent to Education Commissioner Frank Edelblut, the NH State Board of Education, and Governor Chris Sununu this morning, and shared during public testimony at the NH State Board of Education today.
For Immediate Release
Thursday, December 8, 2022
CONCORD, NH – Professional educators, parents, and community leaders from some of the state’s leading public education organizations have signed a joint letter requesting the New Hampshire Department of Education and the NH State Board of Education to halt the current 306 Rules revision process until a more transparent and inclusive public process and timeline is established for the consequential rules.
The 306 Rules, also known as the Minimum Standards for Public Education, address every aspect of public education in New Hampshire. From professional development for teachers to classroom curriculum to what is served in the cafeteria, the 306’s have a significant impact on the way New Hampshire public education students experience schooling. Yet the process for drafting the new rules has left many concerned. The letter addresses several aspects of the current process that the state’s top public education advocates want addressed, such as a lack of diverse and critical input from key education partners and stakeholders, the current drafted version’s attempts to gut core content areas, and a lack of public transparency and accountability and a clear timeline on behalf of both the NH Department of Education and the National Center for Competency Based Learning (NCCBL), the firm hired through a sole-source contract to conduct the revision process.
“The NH Department of Education’s current 306 Rules drafting process is being conducted by an outside firm with little public oversight for how stakeholders are selected, the content they discuss, the input they provide, or the timeline they are operating on,” said Sarah Robinson, the Education Justice Campaign Director for Granite State Progress. “These rules are crucial to maintaining a strong and inclusive public education in our state. Without broad public input and scrutiny from all stakeholders, how can the DOE expect to offer a draft that meets the needs of our students? We should all be concerned about attempts to rewrite our public education standards without a strong and transparent public process.”
The joint letter, found below, calls to restart the process in a more open and transparent manner and to include a broad and diverse range of stakeholders to ensure the best outcomes for our students, and our state. Signing organizations offer the additional statements:
Megan Tuttle, President, NEA-NH: “The behind-closed-doors process being used by the New Hampshire Department of Education and their selected contractor is very concerning and runs counter to how we do things in New Hampshire. With something as important as rewriting the minimum standards for our public schools, input from a broad variety of stakeholders and the public should have been included from the start. Every New Hampshire student deserves a school with the resources, programs, and curriculum to nurture their curiosity and desire to learn. The 306 Rules are a critical part of ensuring high expectations and standards across our schools that foster strong, inclusive learning environments for our students and facilitate parental, family, and community involvement and engagement. We urge the Commissioner to restart these efforts with a more representative process, operating in a transparent environment.”
Deb Howes, President, AFT-NH: “The 306 Rules serve as the foundation for learning in our public schools, and education stakeholders know how critical it is that the rules are established in the best interest of our students. Without a clear process and timeline, involving a broad and diverse range of stakeholders, the NH Department of Education is harming public confidence in how the rules are being formed and implemented. There is reasonable concern over whether the process is being intentionally conducted outside of established timelines and public oversight, and what that might mean for public schools and our students. Moving quickly to establish a clear and public process allows everyone to move forward together.”
Zack Sheehan, Project Director, NH School Funding Fairness Project: “Changes to these standards impact almost every aspect of our public schools, including conversations and decisions related to funding. These standards must strive to support well-resourced public schools that can provide a great education to every student who walks through their doors. That’s why it is critical that there be a process that incorporates and values opportunities for public input. I understand that actively seeking out input from a diverse set of stakeholders is challenging, time consuming work, but our students, parents, school districts, and taxpayers deserve nothing less.”
Jen Bisson, Board Chair, Support Our Schools New Hampshire: “As a parent of two young daughters, I am disheartened by the way in which the state has handled revising the 306 Administrative rules. I am very concerned that these rules are going to hurt the public schools that my children attend. There has been almost no transparency in the process, and what little we have been able to learn about the process is troubling to say the least. It is time to start this process over and do it right. Our childrens’ education is too important.”
Carisa Corrow, Founder, Educating for Good: “As times change and priorities shift, New Hampshire’s rules for public schools should be updated regularly in a transparent process that includes students, parents, educators as well as the community at large. The current attempt at updating NH’s education rules has neither been transparent nor inclusive of the communities these rules will serve. While recent attempts to engage educators is encouraging, the Department of Education needs to ensure more voices are heard.”
Janet Ward, Vice President, League of Women Voters NH: “The League of Women Voters of NH supports public schools as a foundation of our democracy. The League believes in transparency in all state departments. Revision of the rules which govern New Hampshire’s schools should be done in an open and public manner. The most recent review of the 306 rules has been done privately, without public participation or oversight. These are the reasons the League signed the letter sent to NH’s Commissioner of Education and the State Board of Education asking for the establishment of an open and transparent 306 revisioning process.”
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December 8, 2022
Education Commissioner Frank Edelblut
NH State Board of Education
25 Hall St.
Concord, NH 03301
Re: Establishing An Open and Transparent 306 Rules Process and Timeline
Dear Education Commissioner Edelblut and Members of the NH State Board of Education:
When our students and schools thrive, so does society. As parents, educators, advocates,
and civic leaders, we urge the NH Department of Education and NH State Board of
Education to halt the process of the ED 306 Minimum Standards for Public School
Approval, as released by the National Center for Competency Based Learning (NCCBL).
The NH Department of Education should begin anew with a stronger commitment to
engaging all stakeholders, including a diverse and representative sample of public school
parents and students, and establish an inclusive and transparent public process before
drafting any revisions to the current administrative rules. We are ready and willing to work
together on the next steps of a more thoughtful and engaging public process that is in line
with our Granite State values.
Since beginning a revision of the minimum standards two years ago – a process that began,
and continues to operate, outside of the public purview – the NH Department of Education’s
approach has made it difficult for educational stakeholders to feel comfortable that the rules
are being formed in the best interest of Granite State students. These concerns include:
- The lack of diverse and critical input from the start from key education partners and
stakeholders, including teachers, special education specialists, diversity equity and
inclusion experts, and others with the experience and expertise needed to ensure
minimum standards that create the framework for strong, inclusive, and high-quality
public schools; - The critical importance of ensuring an adequate set of minimum standards is
adopted, especially in light of recent attempts to gut core content areas in HB 1671
as originally proposed; - The weakening and fracturing of our public schools by removing fundamental
program elements, student equity provisions and protections, local control, and the
role of certified educators in student learning; - The lack of transparency and accountability and a clear timeline, both on behalf of
NCCBL and the NH Department of Education. NCCBL and NH Department of
Education have convened for nearly two years behind closed doors, with no
opportunities for broad public input, progress updates, reports, or committee minutes
for key stakeholders or the public; and, - Conflicting reports over whether the public input process and listening sessions cited
in the contract proposed by the NH Department of Education and approved by the
NH Executive Council will be held before, during, or after the formal rulemaking
process begins under RSA 541-A.
Our organizations strongly believe that it is in the best interest of students, families, schools,
and communities to ensure that the process and the outcomes lead to the best results for
our students and the State of New Hampshire, and that the final 306 Rules are something
everyone can be proud to implement.
Respectfully,
Megan Tuttle, President, NEA-NH
Deb Howes, President, AFT-NH
Jen Bisson, Board Chair, Support Our Schools New Hampshire
Zack Sheehan, Project Director, NH School Funding Fairness Project
Carisa Corrow, Founder, Educating for Good
Sarah Robinson, Education Justice Campaign Director, Granite State Progress
Jonah Wheeler, Education Justice Organizer, Rights & Democracy NH
Dave Doherty, Education Working Group Convener, Kent Street Coalition
Heidi Carrington Heath, NH Council of Churches
Janet Ward, Vice President, NH League of Women Voters
Doris Hampton, Coordinator, Canterbury Citizens for Democracy
Cc: Governor Christopher T. Sununu