Letter to the Honorable Secretary Arne Duncan, U.S. Department of Education

Letter

Senator Kent Conrad presented Secretary of Education Arne Duncan with a letter today noting his approval of steps the Administration is taking to move away from its "one size fits all" approach to improving the nation's education system while cautioning that those steps have not gone far enough to meet the needs of the nation's most rural schools.

"I and many in the North Dakota education community remain concerned that some of the Administration's proposed policies…will greatly disadvantage schools in smaller, more geographically isolated communities," Senator Conrad wrote. "It is my sincere hope that the Administration will work closely with Congress to ensure that federal education policies support all schools and students, regardless of their address."

The Senator went on to note that the very nature of schools in North Dakota's most rural communities do not lend themselves easily to securing federal competitive grants. Senator Conrad said capacity limitations and urban-centric criteria often prevent rural schools from accessing competitively funded programs. The Senator called on the Secretary to broaden grant competition criteria to account for schools in sparsely populated areas to achieve the common objectives of improving the quality of education in North Dakota and around the country.

An emphasis on the role of charter schools -- a key component in that Administration's "Race to the Top" competition -- is not relevant in North Dakota, the Senator added. And while he praised the Administration for calling on parents to play a greater role in their children's education, their recommendations to increase parental involvement may not be workable for North Dakota's families.

Senator Conrad praised Secretary Duncan and the Administration for placing an increased emphasis on student academic growth to evaluate progress, though cautioned against placing too much stock in student test scores.

A strong supporter of rural education, Senator Conrad is the author of the Rural Education Achievement Program and a co-chair of the Senate Rural Education Caucus.

The letter appears below:

March 1, 2011

The Honorable Arne Duncan
Secretary
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202

Dear Secretary Duncan,

Thank you for your response to my October 6, 2010, letter regarding the Administration's proposed changes to the Elementary and Secondary Education Act (ESEA). I appreciate the opportunity to continue our dialogue about perceived challenges with the proposed Blueprint, particularly for rural schools and districts in a frontier state like North Dakota.

Certainly, schools across the country face different challenges and advantages as they work to provide young Americans with the best possible education. North Dakota's education challenges and advantages are unique when compared to more urban and suburban counterparts across the country. In fact, they are often different from those faced by other rural school districts across the country.

When I meet with education leaders from my home state, I hear about challenges stemming from low population density, geographic isolation, and poverty. Despite these challenges, I have seen firsthand that these same schools are a breeding ground for innovation, community unity, and academic success. For example, Kulm High School (54 students) has been recognized as a Blue Ribbon school for its innovative use of technology to transform student learning and improve student achievement levels. However, this same school struggles to provide advanced courses and electives partly because of the highly qualified teacher definition under No Child Left Behind.

I am pleased that the Department of Education is committed to addressing the needs of rural school districts. Proposals to retain the Rural Education Achievement Program (REAP), and plans for continued formula distribution of REAP funding (as well as for other programs important to rural areas, like Impact Aid, Title I and Indian Education) are critically important to ensuring that rural schools have the necessary resources to deliver high quality education. As I mentioned, I oppose any competitive allocation of REAP funding because it would ultimately reduce the only funding stream dedicated to leveling the playing field for rural schools.

However, Iand many in the North Dakota education community remain concerned that some of the Administration's proposed policies take too much of a "one-size-fits-all" approach that, while they may be workable for larger rural districts close to urban centers, will greatly disadvantage schools in smaller, more geographically isolated communities.

For example, the proposed competitive education grant programs would create serious challenges for rural schools. You correctly point out that funding and regulatory flexibility are of great importance to rural schools, and the Department has taken steps to advantage rural schools in some of its competitive education grant competitions. However, over and over again, I hear from educators in my state that inherent capacity limitations within rural and frontier schools create insurmountable challenges to accessing Federal competitive funding. Relative to more populated schools and school districts, limited staff and diseconomies of scale contribute significantly to these capacity challenges. It is my experience that competitive allocation of funding will, in most cases, disqualify sparsely populated rural areas, and prevent schools in my State from even accessing the funding and benefitting from the proposed flexibility.

Additionally, too often grant competition criteria disadvantage rural schools at the outset. For example, to be eligible for the Teacher Incentive Fund evaluation competition, an applicant must propose to implement a performance-based compensation system in at least eight qualified high-need schools. Rural educators in North Dakota perceive this to be an urban-centric criterion and have pointed out that it is far more difficult for a rural consortium in a frontier state to develop an application under this particular criterion, than for an urban district with multiple schools. Other examples of urban-centric criteria include matching grant, data collection, and scale-up requirements of the Investing in Innovation (i3) program. Furthermore, there is mounting evidence that the rural competitive preference points utilized in the i3 program were significantly mismanaged. As I have shared in separate correspondence, this is of serious concern to me.

Another example ofthe Administration's one-size-fits-all approach isthe emphasis on charter schools and the use of charter school-related criteria in the Race to the Top competition. I understand that the Administration believes that charter schools provide an important option outside of traditional public schools. While I do not dispute that charter schools can be a valuable resource in some communities, they are not relevant in North Dakota. My underlying concern is that frontier states - which are less likely to have a need for, or the resources to support a strong, high-quality charter school system - are especially disadvantaged from the outset because of the emphasis on charter school criteria within the Race to the Top Competition. While the proposed inclusion of a rural set-aside in the Race to the Top program is encouraging, I remain concerned that the competition criteria are not relevant to rural schools.

The proposed turnaround models for low-performing schoolsfurther illustrate the Department's one-size-fits-all approach. You sharedthat the "transformation model" was included to address the uniqueness of rural schools. In speaking with rural educators, it is increasingly clear that even the "transformation model" is not appropriate for most rural schools in North Dakota. While some schools across the nation may benefit from the "culture shift" instigated by the proposed models, there remain the hard-to-staff, geographically isolated rural schools (tribal schools in particular) that would be hard-pressed to succeed under any of the proposed models. My constituents and I believe that the proposed turnaround models may have serious unintended consequences for smaller rural schools in particular.

Likewise, charter school and performance-based evaluation system requirements tied to the School Improvement Grant (SIG) program make it very difficult for my State to target SIG funding to the highest need schools. I am concerned that these prescriptive criteria, which conflict with North Dakota State law and reflect some of the challenges I have described, prevent North Dakota's most at-risk schools from accessing vital resources needed to raise student achievement.

Regarding some of the other issues you addressed in your letter, I share your support for using student academic growth to evaluate academic progress. However, I caution against an overreliance on student test scores for other purposes. As I pointed out, North Dakota initially faced significant difficulties meeting highly qualified teacher definitions under NCLB. Some of my constituents have raised concerns that an overreliance on student test scores to determine teacher credentials may have unintended consequences for teacher performance.

Finally, I appreciate the Department's strong commitment to parental involvement; however it is not clear how the programs you described would improve parental involvement in frontier states like North Dakota. Your previous letter describes the Department's proposal to increase funding for parent involvement from one to two percent of Title I dollars. Currently, districts receiving over $500,000 in Title I dollars are required to reserve funding for parental involvement strategies. In my State, most North Dakota districts serve low-populated areas and are not able or required to dedicate Title I funds to parental involvement strategies. These low-enrollment districts primarily rely on the Parental Information Resource Center (PIRC) in Minot, North Dakota, to build the local capacity needed to support parental engagement strategies. Because the Administration has proposed eliminating funding for the PIRC's, I am concerned that a program that works well in low population schools would be eliminated, leaving these schools without a proven system of support and technical assistance. I believe more details are needed to understand how the Department's proposed family engagement initiatives would realize results in North Dakota.

I agree we must take steps to improve educational outcomes for all students, and feel very strongly that any changes to ESEA should work to support access to a high quality education across the United States. As we prepare for debate on ESEA reauthorization, it is my sincere hope that the Administration will work closely with Congress to ensure that federal education policies support all schools and students, regardless of their address.

Sincerely,
Kent Conrad
U.S. Senate

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