Lawyers for the New Hampshire Department of Education (NHED) denied Reaching Higher NH’s request for the latest version of the Minimum Standards for Public School Approval (Ed 306 rules) on Friday, October 28. The request was filed under New Hampshire’s Right to Know Law (RSA 91-A) on Wednesday, October 19.
“Any drafts of the Ed 306 Minimum Standards for Public School Approval received from the National Center for Competency Based Education (NCCBL) are draft agency documents,” wrote Elizabeth A. Brown, legal counsel for the NHED, in their denial of the request.
Despite their response, we believe that any changes to the Minimum Standards are a matter of public interest as they serve as the foundational rules that govern all of our public schools. The drafting process should be an open one that includes parents, educators, and the public to ensure a wide representation of input and feedback as they are being developed. So far, the drafting process has not included any opportunity for public input or feedback of any kind.
Purpose of the request
Reaching Higher NH requested the latest version of the Minimum Standards because of growing concerns that a previous proposal, released in July 2022, would undermine and weaken New Hampshire’s public schools. Both the Commissioner of Education, Frank Edelblut, and the NCCBL President Fred Bramante, have dismissed concerns, saying that they are in response to an “outdated” draft.
Read the request here: Reaching Higher requests latest version of minimum standards revision before teacher feedback session
Since RHNH raised concerns over the process so far, NHED has announced one nonpublic input session for selective feedback from a group of New Hampshire teachers scheduled for mid-November. The NHED has partnered with a state-based professional association to identify participants and facilitate the session. However, it is unclear whether participants will receive the proposed revisions in advance.
“If the NHED and NCCBL want meaningful, actionable input, educators and the public must have an adequate amount of time to unpack, understand, and process the changes before the rules are introduced to the NH State Board of Education,” said Nicole Heimarck, Executive Director of Reaching Higher NH.
Proposed legislation would restart revision process
Representative Dave Luneau (D-Hopkinton) is expected to introduce legislation in 2023 that would restart the revision process.
The proposed legislation would create a commission similar to the one that drafted the academic standards for teaching about Holocaust and Genocide in New Hampshire schools and the recommended legislation required to enact the standards.
The goal of the proposed legislation would be to create a transparent process that includes greater input from experts, community members, and the public, similar to the drafting process for other administrative rules:
- The Professional Standards Board that oversees the administrative rules for teacher certification publishes minutes of their meetings, which includes discussion around proposed rule changes;
- The Commission on Holocaust and Genocide Education has public meetings, minutes, and drafts available on the internet for its work in crafting administrative rules regarding the creation of academic standards for teaching about the topics; and,
- The Commission to Study School Funding has public meetings, minutes, and drafts available for its work in proposing legislation relating to school funding.
In contrast to these examples, the current process to overhaul the Minimum Standards for Public School Approval has been completely closed to the public, without any public meetings, minutes, drafts, or opportunity for input, despite how important the rules are to our public schools.
The proposal is expected to be introduced as a bill in January.
NHED will provide requested emails
Department lawyers have said that they will comply with Reaching Higher NH’s other requests in the letter: communications and electronic documents between Commissioner Frank Edelblut and Fred Bramante between September 1, 2022 and October 19, 2022, and communications and electronic documents between Bureau Administrator Nate Greene and Fred Bramante in the same time frame.
According to the response, the NHED will fulfill the requests in the coming weeks. Reaching Higher NH will update this post as more information becomes available.
Next Steps
Reaching Higher NH continues to provide the public with critical information about the Minimum Standards and the process to revise them. There have been no opportunities for public input scheduled to date; however, once those dates are made available, Reaching Higher NH will publish them on our website and on social media.
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