**SLC NPP Comments**

\-\-\-\--Original Message\-\-\-\--

From: \[REDACTED\]

Sent: Saturday, March 31, 2007 3:23 PM

To: Smaller Learning Communities

Subject: SLC Proposed Requirements\'\'

The LA Chamber formally recommends:

We need to increase focus on Middle schools and make them eligible
should invite them to also apply

this was shared last week with Kerri Briggs in a meeting

thx

David

Do you need stars for your company ?

David Rattray

VP Education and Workforce Development

Los Angeles Area Chamber of Commerce

President

UNITE-LA School-to-Career

350 S. Bixel

L.A. CA 90017

\-\-\-\--Original Message\-\-\-\--

From: \[REDACTED\]

Sent: Monday, April 02, 2007 2:41 PM

To: Smaller Learning Communities

Subject: SLC COMMENT

Congratulations for simplifying the SLC federal register notice!! It

should provide more in-depth opportunities for grantees to describe

their proposed programs.

Cohort 5 and 6 notices required wall-to-wall SLCs. Please clarify in

cohort 7 final notice whether this continues to be a requirement.

Sharleen Grove

Salem-Keizer Public Schools

Salem, Oregon

\-\-\-\--Original Message\-\-\-\--

From: Larry Green

Sent: Tuesday, April 03, 2007 10:53 AM

To: Smaller Learning Communities

Subject: SLC Proposed Requirements

To Whom It May Concern,

I am writing to provide comments regarding the Department of
Education\'s Notice of Proposed Information Collection Request, Federal
Register/Vol.72, No.45/ Thursday, March 8, 2007. Be advised that The
Thurgood Marshall College Fund is very interested in submitting on this
proposed SLC Program however, the current eligibility requirements do
not allow eligibility for non-profit organizations. Please note that we
are a non profit entity that represents 47 Historically and
Predominately Black Colleges and Universities (HBCU\'s). With TMCF
assistance, our colleges and universities have partnered with school
districts to redesign low performing schools to create smaller learning
communities that focus on rigor but also assist the high schools with
curriculum and instruction.

We were initially funded by the Bill and Melinda Gates Foundation
whereby we partnered six low performing school districts with five of
our HBCU\'s. We look to expand this program with the assistance of this
Department of Education SLC program. It is our belief that small or low
performing school districts might not have the opportunity to submit on
a project such as this because they lack the resources. If this program
does not allow non profits, such as TMCF to submit, we believe several
inner city and rural minority areas will be left out of this program
simply because they lack staff and additional resources to compete. Non
profits, such as TMCF, allow the poorer school districts to compete
because we partner them with colleges and universities in their
community and also are able to take care of the administrative
responsibilities such as monitoring and reporting.

TMCF and our member colleges provide additional resources that just are
not available to poorer school districts. Our institutions are located
in Louisiana, Mississippi, Chicago, Houston, areas in which additional
support is critically needed. If allowed, TMCF, wishes to fill in the
gaps and assist those school districts with programs such as SLC. Non
Profits are also in a position to provide matching outside resources to
assist with the Department efforts unlike most school district simply
because of the way they are structured. We believe that we are already
conducting the work you seek done with the upcoming RFP. Thus, we
strongly urge you to allow non-profit organizations the opportunity to
submit on this project as we are certain our organization will be able
to deliver on the desired outcomes. Below please find information on our
current SLC efforts and understand why we believe allowing non-profit
organizations to submit is so important:

Thurgood Marshall College Fund\'s (TMCF) National School Reform and
Partnership Initiative is established to close academic achievement gaps
and increase college readiness/preparation and college-going rates among
students, especially those of color. In partnership with its members
colleges and universities, TMCF views involvement in national reform
efforts as a critical component to closing achievement gaps while
ensuring a continuous pipeline of new leaders.

First, public Historically Black Colleges and Universities (HBCUs) have
served as major teacher training institutions since their inception and
graduated more than 50 percent of African-American public school
teachers. Second, public HBCUs serve as valuable resources of talent for
a needed national pool of diverse teachers. As of fall 2003,
approximately 230,000 students were enrolled in TMCF member
institutions. Third, HBCUs and their colleges of education have a
history of educating students K-12 in lab schools located on their
campuses.

TMCF seeks to partner with member schools and public school districts to
prepare high school students to successfully compete in a global market,
increase opportunities for public HBCUs to assist school districts in
closing achievement gaps, provide increased pools of highly qualified
teachers through its partnerships with TMCF member colleges of
education, and provide increased pools of diverse talent in
underrepresented fields such as health, science, technology, engineering
and mathematics.

Gates Marshall Redesign Project

Project Description

Also referred to as the RADICAL Program (Reinventing Academic
Development to Inspire Creative Achievement and Learning), this project
funded by the Bill & Melinda Gates Foundation for \$4.9 million over
five years, is designed to newly create and redesign low performing high
schools in economically distressed areas, especially located in the
south, into small secondary model schools of 400 students. High schools
are developed through partnerships between TMCF member schools, those
being public Historically Black Colleges and Universities (HBCUs), and
their local public school districts. University partners provide
programmatic support to teachers and administrators and college course
enrollment opportunities to students.

Sites were selected through a competitive proposal process in targeted
states; Arkansas, Alabama, Florida, Georgia, Louisiana, Maryland,
Mississippi, North Carolina and Texas. The Fund serves as the
intermediary and assumes fiscal responsibility and programmatic
oversight for the newly formed college/high school partnerships.

Gates/Marshall high schools focus on 4 R\'s - - rigor, relationships,
relevance and results in preparing students for college, work, and
citizenship. Schools are based on the attributes of high achieving
schools such as common focus, and technology as a tool. The seven newly
created and redesigned small high schools located in Louisiana,
Maryland, North Carolina, and Texas are scheduled to serve 3000
students.

Benchmarks used to determine the effectiveness of the Gates/Marshall
redesigned high schools are established in the following major areas:

Students graduate with a high school diploma and some college credits.

High schools establish the enabling conditions necessary to prepare
students for success in a rigorous, well-structured academic program
leading to high school graduation with some college credits.

High schools provide comprehensive student supports based on students
academic and social needs.

High schools demonstrate effective instructional practices.

High schools engage students, parents, community, business and public
agencies in developing and sustaining the schools.

School districts together with the colleges develop plans for
sustainability.

THE NATIONAL SCHOOL REFORM & PARTNERSHIPS INITIATIVE CONSISTS OF THREE
COMPONENTS

High School Redesign Program

Leadership for Educational Reform Conferences

Research and Evaluation

High School Redesign Program

TMCF member schools are working with their local school districts to
newly create and redesign low-performing high schools. The first effort
in this area is the Gates/Marshall Redesign Project funded by the Bill
and Melinda Gates Foundation. Planning and implementation grants support
seven new and redesigned university-assisted high schools over a
five-year period.

Leadership for Educational Reform Conferences

TMCF facilitates annual technical assistance meetings, leadership
conferences, and site visits during the year. College and university
leaders, school district administrators, principals, and teachers are
provided opportunities to convene and share success stories, teaching
strategies and techniques, and engage in problem-solving exchanges.
Educators also have opportunities to broaden their leadership skills in
education through conferences led by national experts and practitioners
in the field.

Research and Evaluation

According to a recent study, 24 TMCF member institutions are involved in
some level of school reform work with their local school districts. The
Fund seeks to study the levels of involvement and the actual impact of
HBCU partnerships and intermediary roles in promoting and increasing
achievement of targeted students in P-12. Data will be used to national
report findings that suggest successful strategies and techniques used
to improve academic outcomes and college-going rates for students as a
product of the collaboration in which the fund serves as an intermediary
for partnerships between HBCUs and local public school districts. Data
will also be gathered to identify similar findings from other reform
partnership projects involving member institutions, but not necessarily
involving the Fund\'s role as the intermediary.

If you have any questions or if I can be of further assistance, please
advise.

Larry V. Green, Esq.

Vice President of Government Affairs

Thurgood Marshall College Fund

901 F. Street, NW, Suite 200

Washington, DC 20004

[www.thurgoodmarshallfund.org](http://www.thurgoodmarshallfund.org/)

\-\-\-\--Original Message\-\-\-\--

From: Hardy, Georgeann

Sent: Thursday, April 05, 2007 5:50 PM

To: Smaller Learning Communities

Cc: Jackson, Bruce; Maniscalco, Larry

Subject: Comment on upcoming priorities and other

Thank you for the opportunity to comment on the smaller learning
communities grants priorities for the 2006 funding year.

I think that the priorities are appropriate. We want to see our students
prepared for post secondary education so that they do not need
remediation.

To do that we need to keep more of our students engaged in meaningful
and supportive secondary education activities so that they have the
opportunity to graduate and pursue post secondary opportunities.

Last year we submitted a SLC implementation grant proposal that was not
funded.

As directed, we provided a copy of each high school's SARC report with
the appendix documentation.

In our proposal we wrote about our needs and explained in detail how
many students drop out before the 11th and 12th grade. They may end up
at the continuation high school, they may end up at the local adult
school, often, they just disappear from our local educational system. We
are concerned that these students are missing out on receiving an
adequate education because they may not be engaged in their education
and may be struggling. Many do not have the necessary amount of credits
by the end of 10th grade for graduation at the 12th grade. They are
discouraged and leave the system.

One of the readers for our proposal made the feedback comment that the
SARC (state graduation rate) for our high schools was too high,
therefore we should not be qualifying for an SLC grant as we were not
needy enough. However, what the reader failed to pick up from the
narrative was the part about our "missing" students....students so
discouraged that they left the system. The SARC graduation rate is very
misleading if a reader intuits that the data shows that we do not have
the need to implement SLCs. All the students that are successful and
stay for graduation are the only students represented in the grad rate,
of course, not the disheartened students that have dropped out.

So, I would hope, that readers receive some kind of training when they
read proposals so that they do not perceive that because a grad rate
looks high that all kids are succeeding at a high school. The narrative
should be given greater weight than the SARC report to be fair to those
kids who have dropped out and in actuality could benefit from access to
strong and successful SLC implementations.

Please consider this. Thank you.

\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^\^

Georgeann Hardy

Director Educational Technology/Instructional Materials

San Lorenzo Unified School District

15510 Usher St.

San Lorenzo, CA 94580

\-\-\-\--Original Message\-\-\-\--

From: Mullins, Rachael

Sent: Thursday, April 05, 2007 6:08 PM

To: Smaller Learning Communities

Cc: Reilly, Ellen; O\'Melia, Leslie; Fair, Betsy Rhae

Subject: comment on pending RFP language

Thank you for the opportunity to give input on the Smaller Learning
Community granting process. The Davenport Community Schools is an urban
district in the primarily rural state of Iowa. We operate the state's
largest high school, West High School, and two other large traditional
high schools that each serve an increasingly diverse population. We
intend to apply for this summer's competition for Smaller Learning
Communities for these three high schools, all of which meet the RFP
requirements for enrollment.

We have reviewed the proposed RFP language and support the changes that
have been made since last year's application, in particular in the
increased explicitness of the criteria language and the post-secondary
focus.

There was not, however, a lot of detail on the criteria that will be
used for the priority point system. We would like to recommend that you
consider competitive priority points for schools and/or district's that
have been named as "in need of assistance" or "in need of improvement"
through their state accountability plan for No Child Left Behind.
Traditionally in our state, these are district's that have larger, more
diverse student bodies that, it would seem, would be best served by the
smaller learning communities approach. We would also like to recommend
that the RFP address social-behavioral needs of students by encouraging
alignment with Title IV/Safe and Connected to School activities and
strategies. We believe that the smaller learning community approach
offers an ideal opportunity to introduce a more systematic "pyramid of
intervention" for struggling students that offers broader learning
supports in the affective realm.

Thank you for your consideration of these comments. We look forward to
the release of the Smaller Learning Communities RFP and the impact that
the program could have on the youth of the Davenport Community Schools.
If you have any questions regarding these suggestions, I can be reached
at \[REDACTED\].

Rachael Mullins

Development Supervisor

Davenport Community Schools

\-\-\-\--Original Message\-\-\-\--

From: patricia clark

Sent: Monday, April 09, 2007 12:30 PM

To: Smaller Learning Communities

Subject: SLC Proposed Requirements

To: Gregory Dennis

From: Dani Hull

One of the very best aspects of the Smaller Learning

Communities work is the focus on equity.

For the Smaller Learning Communities Grant

competition, it seems important to be more explicit

(either in the wording of priorities or specific

criteria) about:

1\) STUDENT PLACEMENT Applicants should describe how

students will be placed in SLCs so that students are

NOT placed in SLCs based on test scores or perceived

ability. (and this criteria should be tied to points)

AND

2\) STUDENT INCLUSION Applicants should describe how

ALL students will be included in SLCs by the end of

the funding period

(and this criteria should be tied to points)

Patricia Clark

Education Consultant & Youth Advocate

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Now that\'s room service! Choose from over 150,000 hotels

in 45,000 destinations on Yahoo! Travel to find your fit.

http://farechase.yahoo.com/promo-generic-14795097

\-\-\-\--Original Message\-\-\-\--

From: Walsh, Russ

Sent: Monday, April 09, 2007 12:34 PM

To: Smaller Learning Communities

Subject: Comment on Notice of proposed priority, requirements, and
selection of SLC Grants

To whom it may concern:

The proposed priorities indicate that the Department does not plan to
accept planning grants this year. The rationale is that a number of
planning grants have been awarded in the past and that good models are
available to help with implementation. This rationale ignores the real
need for the planning grants: planning for the implementation at the
school level. Any initiative of this size requires the individual school
to plan for staff development, resource allocation, scheduling, course
realignment, course construction, community input and any number of
other activities that make a new initiative possible. By denying schools
access to planning grants, the Department is encouraging faulty
implementation. Please reconsider this proposed change to the grant
structure.

Sincerely,

Russ Walsh, Director of Language Arts

Montgomery Township School District

Skillman, NJ 08558

![](media/image1.png){width="2.8715277777777777in"
height="0.7895833333333333in"}

9 April 2007

Mr. Gregory Dennis

U.S. Department of Education

400 Maryland Avenue, SW

FB-6, Room 3W243

Washington, DC 20202-6200

Dear Mr. Dennis:

Thank you for the opportunity to comment on the proposed priority for
the Smaller Learning Communities Program as described in the March 8,
2007 Federal Register. The Department's intention to emphasize
postsecondary preparation through this program holds a great deal of
promise, and we are encouraged by the possibilities. We look forward to
an opportunity to work with the Department to ensure the success of this
initiative.

According to the notice, the Department has reviewed a growing body of
evidence that indicates that the current structural focus of the Smaller
Learning Communities Program should be expanded. The notice cites the
following recent findings by the Department and others:

-   Smaller Learning Communities are most likely to be successful in
    raising academic achievement and improving other student outcomes if
    their implementation is integrated closely with improvements in
    curriculum and instruction.

-   Considerable numbers of young people are graduating from high school
    without the academic foundation needed to succeed in postsecondary
    education.

-   Students who plan to enter the workforce immediately after high
    school, rather than pursue postsecondary education, also need a
    strong academic foundation.

In expanding the program, the Department proposes "to support projects
that create or expand SLCs that are part of a comprehensive effort to
prepare all students to succeed in postsecondary education and careers
without need for remediation". A key element in these reform efforts, as
described in the proposed priority, is increasing opportunities for
students to participate in rigorous courses such as Advanced Placement
(AP) courses, and it is in this area that we would like to provide
further comment, as we believe this is an important strength of the SLC
program.

The College Board is a national not-for-profit association of more than
5,000 member schools, colleges, and universities. Its mission is to
connect students to college success and opportunity. One of the College
Board's most ambitious and important teaching and learning programs is
the Advanced Placement Program (AP). Comprised of 37 college-level
courses taught in high school, AP represents the highest standard of
academic excellence in our nation's schools and has become the most
influential general education program in the country. A collaborative
effort between motivated students, dedicated teachers, expert college
professors, and committed high schools, colleges, and universities, the
AP Program has allowed millions of students to take college-level
courses and exams and to earn college credit or placement while still in
high school since its inception in 1955. Ninety percent of the colleges
and universities in the United States, as well as colleges and
universities in 30 other countries, have an AP policy granting incoming
students credit, placement, or both on the basis of their AP Exam
grades. Many of these institutions grant up to a full year of college
credit (sophomore standing) to students who earn a sufficient number of
qualifying AP scores.

[The Advanced Placement Program]{.underline}

A strong correlation exists between a student's participation in
rigorous coursework and his or her success in college. For example, new
research shows that students earning Advanced Placement Exam grades of 3
or higher experience high levels of college performance *and* completion
once they enroll in college. In 2006, more than 1.3 million students
took a total of more than 2 million AP Exams, with nearly 60 percent of
these students earning a grade of 3 or higher on an exam, indicating
course mastery that could enable them to earn college credit while still
in high school.

AP is a time-tested program with an existing infrastructure of tens of
thousands of teachers and a network of hundreds of training sites across
the country. The principles and values of the AP Program can be stated
quite simply:

-   *AP supports academic excellence*. AP represents a commitment to
    high standards, hard work, and enriched academic experiences for
    students, teachers, and schools.

-   *AP can support equity*. The AP Program should be open to all
    students, and we believe that every student should have access to AP
    courses and should be given the support he or she needs to succeed
    in these challenging courses.

-   *AP can drive school-wide academic reform*. Schools that use AP as
    an anchor for setting high standards and raising expectations for
    all students see significant returns not just in terms of AP
    participation but in terms of increasing the overall quality and
    intensity of their academic programs.

Across the nation, every state and most school districts are exploring
ways to raise standards and ensure that all students take challenging
courses that prepare them for success in college and work. AP is
recognized as a powerful tool for increasing academic rigor, improving
teacher quality, and creating a culture of excellence in high schools.
Students who take AP courses assume the intellectual responsibility of
thinking for themselves, and they learn how to engage the world
critically and analytically---both inside and outside of the classroom.
This is an invaluable experience for students as they prepare for
college or work upon graduation from high school. Moreover, schools in
which AP is widely offered---and accessible to all students---experience
the diffusion of higher standards throughout the entire school
curriculum.

Currently, the Department supports AP through its AP Incentive Program
(APIP), which provides states, districts, and a variety of non-profit
institutions with the resources to offset exam fees, purchase classroom
and laboratory materials and supplies, fund professional development
opportunities, and conduct best practices research. Similarly, the
proposed enhancement of the Smaller Learning Communities Program to
include support for AP is likely to expand access to the program and
help close the gaps in academic achievement and college success.

We are encouraged by the Department's new plans for the Smaller Learning
Communities Program, and we look forward to opportunities to work with
you and with the SLC grantees to ensure the successful implementation of
strategies to increase the academic preparation and college readiness of
all students.

Thank you again for the opportunity to comment and for the Department's
continued work in support of education reform.

Sincerely,

![](media/image2.png){width="2.0631944444444446in"
height="0.5708333333333333in"}

Thomas W. Rudin

Senior Vice President

Advocacy, Government Relations, and Development

![](media/image3.png){width="1.75in" height="1.0923611111111111in"}

April 9, 2007

Gregory Dennis\
U.S. Department of Education\
400 Maryland Avenue, SW.\
FB-6, Room 3W243\
Washington, DC 20202-6200

Dear Mr. Dennis:

On behalf of the Association for Career and Technical Education, I am
writing to submit comments regarding the proposed priority and
requirements for the Smaller Learning Communities (SLC) program, as
requested in the March 8, 2007, issue of the Federal Register.

The Association for Career and Technical Education (ACTE) is the
nation's largest not-for-profit education association dedicated to the
advancement of education that prepares youth and adults for successful
careers. It provides advocacy, public awareness and access to
information, professional development and tools that enable members to
be successful and effective leaders. Founded in 1926, ACTE has more than
29,000 members including teachers, counselors and administrators at the
middle school, high school and postsecondary levels. ACTE is
particularly interested in the SLC program and its ability to prepare
students for postsecondary education and careers by organizing rigorous
content around a career theme.

ACTE supports the goal of preparing every high school student for
postsecondary education and careers, and therefore supports the new SLC
priority of "Preparing All Students to Succeed in Postsecondary
Education and Careers." This priority is proactive and forward thinking,
and better exemplifies the broad skill set that students will need for
successful post-high school futures.

However, with this change, ACTE recommends an additional activity to
ensure the priority is met. Currently, all five priority activities
relate to core academic courses, which, while necessary for career
success, do not represent the total skill set essential for students to
succeed in careers. For example, the Partnership for 21^st^ Century
Skills has identified four additional areas that need focus in order to
prepare students for careers, in addition to core academic subjects.
These include 21^st^ century content, learning and thinking skills,
information and communications technology literacy, and life skills. We
recommend the addition of the following language to the list of priority
activities:

> "(6) Provide students with opportunities for career exploration;
> work-related experiences; such as internships, cooperative education,
> school-based enterprises, entrepreneurship, and job shadowing;
> technological literacy; and access to technical certificate and
> credential programs that integrate academic and technical education."

In light of the new proposed priority, ACTE also suggests revisions to
the proposed performance indicators. In Section 4, "Performance
Indicators," ACTE recommends the following changes:

-   Maintain language in the third indicator related to apprenticeships
    and advanced training, recognizing that these options provide
    valuable postsecondary training opportunities for students pursuing
    specific career fields. This is consistent with other federal
    legislation and the broad definition of postsecondary education
    endorsed by the U.S. Department of Education's Commission on the
    Future of Higher Education. Indicator #3 would then read:

> "The percentage of graduates who enroll in postsecondary education,
> apprenticeships, or advanced training for the semester following
> graduation."

-   Instead of completely eliminating the requirement for programs to
    collect the percentage of graduates who are employed by the end of
    the first quarter after they graduate, add additional flexibility,
    but require that programs collect at least one additional measure
    related to career success that reflects the stated priority. This
    measure should include a range of options for programs, and may
    include employment placement, student attainment of a credential or
    certificate in addition to a high school diploma, student attainment
    on a career readiness assessment, or student participation in
    work-related experiences.

Thank you for the opportunity to provide comments on this important
program. If we can provide any additional information or answer any
questions, please contact Alisha Hyslop, ACTE assistant director of
public policy, at 703-683-9331 or <ahyslop@acteonline.org>.

Sincerely,

![](media/image4.png){width="1.3736111111111111in"
height="0.44027777777777777in"}

Janet B. Bray, CAE

ACTE Executive Director

U.S. Department of Education

400 Maryland Avenue, S.W., Room 3W243

Washington, D.C. 20202-6200

Re: SLC Proposed Priority, Requirements, and Criteria

Dear Mr. Dennis:

This letter provides comments on the notice of proposed priority,
requirements, and selection criteria for the Smaller Learning
Communities (SLC) Program published in the March 8, 2007 issue of the
Federal Register.

Our principal comment is that the Department did a fine job of focusing
the program on preparing students for postsecondary education and
justifying that focus based on research. As my staff and I have
discussed with your SLC program office, the promise of Smaller Learning
Communities is not principally about school structure. Rather, Smaller
Learning Communities can be successful if they bring rigorous curriculum
and related supports for students and staff together with a personalized
education that connects to the needs and aspirations of individual
students. Size and structure can matter as a complement to instructional
reforms designed to promote individualized attention and instruction.
The Bill & Melinda Gates Foundation remains committed to supporting
Smaller Learning Communities that embody that focus. We remain
interested in working with the Department to support this program
through the type of partnership, or \"Jointly Funded Program,\"
contemplated in the Conference Report accompanying the Fiscal Year 2006
appropriation.

The notice also effectively addresses the fragmentation of the previous
criteria for the program, and appropriately provides for somewhat larger
awards than in the past.

We have a small number of specific suggestions in response to the
notice:

The notice proposes priorities and requirements \"in addition to any
previously established priorities and requirements,\" and it
specifically refers to particular requirements from the notice published
April, 28, 2005. The previously published priority \-- \"helping all
students to succeed in rigorous academic courses\" \-- overlaps with the
current proposed priority to prepare all students to succeed in college
and careers, but the current proposed priority is better focused and
stated. Also, references to requirements and definitions in the prior
notice make it harder for applicants and grantees to follow what is
required, particularly because the prior notice was not codified in the
Code of Federal Regulations. The Department should delete the reference
to previous priorities and requirements, stick with the currently
proposed priority, and include all applicable requirements in the final
notice.

Limiting the program to the restructuring of large public high schools
with enrollments of 1,000 or more students into smaller units was
included as a directive related to past appropriations, but that is not
the case for the FY 2006 appropriation. We understand the Department\'s
policy preference to continue this limit. However, we suggest that the
Department consider making a clarification that eligible SLCs would
include new, structurally separate schools or learning communities that
are replacing a large existing high school with 1,000 or more students,
which would constitute the baseline for several of the requirements or
criteria related to need and performance.

The proposed priority on preparing students for postsecondary education
and careers is well-stated. Consistent with past practice, and to give
the Department latitude, the notice indicates that the priority can be
applied as an absolute priority (meaning every project must meet it); a
competitive priority (meaning that projects that meet it receive
preference); or an invitational priority (which merely expresses an
interest in receiving applications in this area, but gives no practical
preference to them). We recommend that the priority be applied as an
absolute priority.

The proposed criteria are appropriately shorter, simpler, and less
fragmented than past criteria for the program. We understand that the
criteria will be weighted in the application notice. While all of these
criteria are important, our recommendation is that the criterion on
quality of project services be most heavily weighted, followed in
descending order of weight by quality of the project design; need for
the project; support for implementation; and quality of the project
evaluation. We also recommend that specific weights not be assigned to
each of the specific factors under each of the criteria, which would
have the effect of re-fragmenting the criteria, but rather that a point
score for each criterion be determined based on the strength of the
application on that overall criterion in light of the specified factors.

Thank you for the opportunity to comment. We look forward to continuing
discussions on ways that we can work together in supporting the SLC
program. For the record, this letter addresses program implementation,
is in response to your Federal Register solicitation of public comments,
and is incident to a possible Jointly Funded Program, and therefore does
not constitute lobbying under Federal tax or lobbying disclosure laws.

Sincerely,

Sandra Licon

Policy Officer

Bill & Melinda Gates Foundation

Cc: Honorable Margaret Spellings, Secretary of Education

Deputy Secretary Ray Simon

Chief of Staff David Dunn

Acting Assistant Secretary Kerri Briggs

Program Director Joseph Conaty

Stefanie Sanford

\-\-\-\--Original Message\-\-\-\--

From: Run Spot Run \[REDACTED\]

Sent: Monday, April 09, 2007 10:37 PM

To: Smaller Learning Communities; Williams, Deborah

Subject: Comments on Smaller Learning Communities Priorities Notice

These comments are submitted on behalf of 8

representatives of mid-sized school districts that

have applied for and (except for 1) received Smaller

Learning Community grants in the past. Most of us

first met at Smaller Learning Community conferences

you have had, and we decided to join forces to submit

comments on your notice because we thought this would

be more effective and impressive. Since some of our

comments are critical of you, we decided not to

identify ourselves because we are worried that our

comments could bias Dr. Williams and her staff against

our applications. You still may be able to figure

out some of the districts we represent from our

comments, but we did not want to come right out and

identify ourselves.

These are our comments:

Student Enrollment

We could not tell from your notice whether a high

school still needed to have 1,000 students to be

eligible.

We don't understand why 1,000 has always been the

magic number for this program. Most of the high

schools in our districts have more than 1,000

students, but a few have between 915 and 985 students.

These schools are just as needy as the larger

schools, and, in some cases, have greater needs. The

enrollment at some of these schools has dropped

precipitously because they are so dysfunctional. But,

in once case, having 15 fewer students than 1,000

shuts them out of the program. Since you are pushing

for district-level improvement plans, you should give

districts latitude to include schools with less than

1,000 students. We recommend that you make schools

with 900 or more students eligible.

Ten Schools Per Application

You want to limit the number of schools in each

application to 10, as you've done for as long as we

can remember. We believe this is inappropriate and

unfair, and recommend that districts be able to

include only 5 schools. We doubt it's possible for a

district office to do a good job managing a grant that

includes 10 schools, given the enormous amount of work

that implementing these grants at the school level

requires. You have been running this program for a

long time, and we wonder if you have any data that

shows that grants with 10 schools are as successful as

grants with a smaller number of schools. If you look

at your data, we think you will find a lot of problems

with these grants. That's the impression some of us

have from attending your meetings, and talking to the

people who manage these grants.

Letting districts include 10 schools also puts smaller

districts like ours at a competitive disadvantage.

Now that you are proposing to increase the total grant

award (which we support), this is even more of a

problem. Four big districts with 10 schools each

could eat up all of the grant funds, locking out small

and mid-size districts like ours. That's not fair.

We have high schools with a lot of low-income students

and immigrants, too, but never get the kind of

resources the big cities do. We don't receive

millions from Bill Gates. They do.

You should limit districts to 5 schools to make sure

the SLC monies are managed well and that small and

mid-size districts are not discriminated against.

Grant Awards

You propose giving a school with 1,000 to 2,000

students up to \$1,250,000, and up to \$1,500,000 to a

school with 2,001 to 3,000 students, and up to

\$1,750,000 to a school with more than 3,000 students.

While we understand, up to a point, the thinking

behind using student enrollment to determine grant

award amounts, we think there are serious problems

with this:

1\. The arbitrary 1,000 student increments you use to

define your three categories (1,000 to 2,000, etc.)

are too broad and result in inequities that you may

not be aware of. A school with 1,999 students would

generate \$1,250,000 (or \$625 per student) while a

school with 2,001 students (2 more students) would

generate \$1,500,000, which is \$750 per student. It

doesn't make sense that a school B needs \$250,000 more

than school A because it has 2 more students.

2\. You assume that the needs of every student in high

school are equal. A student in special ed that

doesn't speak English generates the same amount as a

student who earns straight A's and is on the honor

roll. This doesn't make sense. Our state aid takes

student needs into account, and provides additional

funds for students with significant needs. You do

not. Several of us work with high schools with less

than 2,000 students that are majority low-income, have

many students with limited English proficiency, and

many special ed placements. Under your formula, these

schools would generate the same dollar amount as

wealthy suburban schools that have fewer needs.

For these reasons, we recommend that you set a single

maximum award that would be available to all high

schools, regardless of their enrollment. We

recommend that \$1,750,000 be set as the maximum award

for all schools.

Length of Grants

We also question your making grants for 5 years, three

years that would definitely receive funding, and 2

years that might receive funding. We think we

understand why you want to make 5 year grants (we

think this is so that the grant covers 9th graders

through graduation, but this could be wrong), but we

think you should just make 3 year grants. We are

concerned that the funding won't be there when it

comes time for you to award the second installment.

We recommend that you make a one-time award for 3

years, with the maximum award at \$1,750,000.

District Use of Funds

We are unclear as to whether you are requiring that

all of the grant funds go to the individual high

schools, or if districts can retain a portion of the

money for technical assistance, curriculum alignment,

implementing district-wide reforms, and other tasks

related to the grant. Right now it seems as though

you expect all of the money go to the schools. We

think districts should be able to retain some of the

funds for district-level activities.

Immediate Implementation

We ask you to clarify when the SLC projects are

supposed to start. You seem to require implementation

of the project immediately after you award the grant.

This would be fine if you were going to award the

grants several months before the start of the next

school year, but you are not. It appears that, like

last year, you will be making the awards after the

start of the school year. It is not possible for a

school to create a freshman academy or new courses in

October. This requires months of planning. Yet you

seem to expect this. If you award grants in October,

we think there are some things that districts and

schools can do during the 2007-08 school year, such as

professional development, curriculum development, and

so forth, but full implementation is not feasible.

Please clarify what you expect grant recipients to do

in the first year given your timetable for awarding

grants.

"Wall to Wall" and "Including All Students"

Your notice does not discuss this, but we are confused

by prior year requirements that schools "include all

students" in SLCs. Three of us were told by Debbie

Williams, the Director of the SLC program, that the

program required schools to assign all students to an

academy or a house by the end of the grant. We have

to say, however, that this was not clear from your

grant application instructions, which is a problem. We

wonder how many people had to call the SLC Director to

get clarification.

One of our districts submitted an application last

year that called for assigning 9th graders to a

freshman academy and all upperclassmen to one of 7

career academies. It was not funded. Although Dr.

Williams said this was illegal, another one of our

districts submitted an application that did not assign

all students to academies because the school board,

the superintendent, and other leaders did not believe

this was feasible or appropriate to do. This

application called for a freshman academy and offering

a variety of career pathway options (rather than

academies) to other students. The Department awarded

a grant to this district.

Your requirements about "including all students" do

not seem to be consistent or clear. You need to

provide clearer guidance about this in the application

instructions, and follow the guidance you establish.

If you're going to require that all students be

assigned to academies or houses, you also need to

explain where in the law this is required, and the

science-based research that says this is essential.

There are a lot of ways to provide personalized

support to students without putting all of them in

academies. And you can assign all of your students to

academies without providing any of them personalized

support. We wonder how many of the schools in the

grants you fund are just going through the motions and

putting students into boxes to comply with Dr.

Williams' instructions about "including all students."

We don't agree that it's necessary or appropriate to

distribute all students into academies or other

structures, and don't think you understand how

difficult it would be to do this, much less in a

responsible way that really promotes student

achievement. With all due respect, Dr. Williams and

your staff need to visit more schools to get a better

understanding of how hard it is to do anything

different in high schools. Yes, all students should

get personal support from one or more adults, but you

don't need "wall-to-wall" academies to do this. Also.

we read the Smaller Learning Communities law in No

Child Left Behind and it does not say that schools

have to create SLCs that are "wall-to-wall." Given

that, we are unsure why you tell applicants that they

have to do this.

You should know, too, that the district that submitted

an application that included 7 career academies that

was not funded was, in the end, relieved that it did

not win a grant. The school's principal and teachers

did not think creating 7 career academies was a good

idea or doable, but agreed to it because they needed

the grant funds. When they didn't get the grant, they

decided to create a freshman academy and an IT

Academy. They may create other academies over time,

but are relieved that they don't have to meet some

arbitrary deadline to put all students in academies.

This just makes sense, and shouldn't disqualify them

from funding.

We recommend that you clarify what "including all

students" means---and you need to be very clear so that

every applicant does not have to call Dr.

Williams\-\--and give districts and schools flexibility

to determine how best to provide the personalized

support that the SLC program calls for. The Smaller

Learning Communities law gives this flexibility.

Grantee Meetings

We think the meetings and institutes you have after

the grants are first awarded are, for the most part,

useful. We think you should consider having more

regular meetings over the life of the grant. One of

our districts was invited to a second-year project

directors' meeting this winter, and she thought this

was very helpful, and wondered why you did not have

annual meetings with grantees. Please consider this.

Thank you for considering our views. We think this is

a good program, but hope you will accept our

recommendations to make it better.