ESEA Waiver

We are sending the letter below as commentary on the Regents ESEA Waiver Request. We will include our APPR Letter Signatories as signatories. Please feel free to send your own comments on the waiver request to

Dear Dr. King and members of the Board of Regents:

We are deeply disappointed that the serious concerns expressed in our letter regarding the use of test scores for educator evaluations which is signed by 1280 New York State principals and 4200 teachers,  administrators, parents, superintendents, professors of education and citizens at large were disregarded in the recently posted draft ESEA waiver request to the United States Department of Education. Rather than addressing our concerns regarding the use of test scores to evaluate educators, this application further institutionalizes APPR and extends it by:

  • Including APPR as presently designed as a rationale for granting the waiver
  • Adding additional tests in ELA in grades 9 and 10 to generate VAM scores
  • Increasing proficiency levels on the English Regents to 75 and the math Regents to 80 and mastery rates to scores of 90 and above
  • Using elementary and secondary student test scores as one of three measures by which to hold teacher education programs accountable

 Further, we are concerned that we could not find on the State Education website or in the document the costs associated with the waiver, costs which the state of California estimates to be in the range of 2 billion dollars. See the article posted here:

We request that prior to submitting the waiver application, the State Education Department prepare and publicly share the costs of the waiver and that the concerns expressed in the principals’ letter be addressed.