Sociology Department

Gladfelter Hall, 7th floor (025-23)

1115 Polett Walk

Philadelphia, PA 19122

phone 215-204-7760

fax 215-204-3352

email soc@temple.edu

web www.temple.edu/soc

Kimberly A. Goyette, Associate Professor

Phone: 215-204-0134 e-mail: kgoyette@temple.edu

url: http://www.temple.edu/soc/goyette

February 11, 2013

Stephanie Valentine

Director of the Information Collection Clearance Division

U.S. Department of Education

400 Maryland Avenue SW. 

LBJ, Room 2E117

Washington, DC 20202-4537

Dear Ms. Valentine, 

I have read the Federal Registry’s call for public comment regarding the collection of all K to 12 school 

attendance boundaries embedded within school districts throughout the United States. I endorse the 

Department’s efforts to collect a nationwide database consisting of school attendance boundary 

information. The dissemination of school catchment area geography—when integrated with the Common 

Core of Data and the American Community Survey—will be a powerful resource for local, state and 

Federal officials, members of the public, policy-makers and academic researchers and, as such, will vastly 

improve the delivery of educational services to public school children throughout the country.

While I encourage the Department of Education to move forward with the project, I would like to ask a 

series of questions that will help the U.S. Department of Education disseminate a database of the highest

quality. In particular, I am responding to the Department’s suggestion that citizens comment on ways 

“The Department [can] enhance the quality, utility, and clarity of the information to be collected.” Here 

are my questions:

Does the U.S.D.O.E have a web page that provides the public with an organizational chart for this 

project? Who are the key participants on the project and what are their responsibilities? Who is the 

Principal Investigator who oversees—and is responsible for—the final product? Is the P.I. a member of 

the DOE or is the PI someone outside of the DOE that might provide expert and independent oversight of 

the project? Which personnel oversee the day-to-day collection and storage of the spatial data and who is 

responsible for the maintenance of the remote digitizing service? Who is responsible for preserving the 

accuracy of the original information that is collected and who is responsible for data quality? Who will be 

responsible for ensuring that all 13,700 school districts supply spatial information to the project? Who 

will ensure that staff at the U.S. Census Bureau will collect the correct data and digitize these data 

accurately and completely?

Does the project have independent advisory board that provides oversight, accountability and direction

to the project? Will the board consist of members from a variety of constituencies—e.g., will the board 

consist of members of the K to 12 educational community, academics from the Nation’s top universities, 

and the GIS community? For example, will the project recruit local or state superintendents (or elected 

school board members and state-level officials) so that the project is responsive to the needs and 
Sociology Department

Gladfelter Hall, 7th floor (025-23)

1115 Polett Walk

Philadelphia, PA 19122

phone 215-204-7760

fax 215-204-3352

email soc@temple.edu

web www.temple.edu/soc

concerns of the jurisdictions that supply data to the project—and that will eventually use the data that 

they supply? Has the DOE considered inviting Jack Dangermond—the president of Esri—or another highranking official from Esri to participate on the Board? Will there be any board members from the nations’ 

universities—experts in computer science, data modeling, statistics, educational research, geography, 

and Geographic Information Systems? Who will recruit board members—the Principal Investigator or 

Jack Buckley? Could a board supply invaluable intellectual advice and material support to the project?

What is the role of the. U.S. Census Bureau on the project? Do they have clearance to integrate the 

American Community Survey data with school attendance boundary information and, if so, what 

variables will they disseminate with the system? What is the level of aggregation for these variables? Will 

school boundary geography become part of the Census Bureau’s geographic products—and is that a longterm goal of the school attendance boundary information survey? If it is, are members of the U.S. Census 

Bureau’s geography division involved with the project—and, if so, in what capacity?

Will the GIS files disseminated by the school attendance boundary survey comply with legally required 

Federal Geographic Content Standards (see http://www.fgdc.gov/csdgmgraphical/index.html ) signed 

into law by President Clinton? What will be the positional accuracy of the spatial data? Will the source 

data be specified in the metadata (i.e., will users know whether the data were obtained as shapefiles from 

school districts, were digitized by the U.S. Census Bureau or were digitized using the remote digitizing 

service)? What base layers are used for digitizing—both by Census Bureau staff and on the remote 

digitizing service? Will the attributes be specified clearly in the metadata? Will the metadata specify, for 

each school district, the number of schools in the district that have boundaries—and which schools have 

more than one boundary or which schools have overlapping boundaries? Will the metadata specify 

school attendance boundaries that are derived from school district boundaries (i.e., those school 

attendance boundaries that are the same as a school district boundary)? 

Is there a logical and/or physical data model for the school attendance boundary survey and, if so, will it 

be posted on the school attendance boundary survey’s web page? If a data model exists, does it specify 

the relationship between schools and the boundaries to which they provide services? Does the data 

model correspond with normal forms that are the hallmark of all robust Database Management Systems?

For example, are the fields and tables organized to minimize redundancies and dependencies? In 

particular, is the Common Core of Data isolated from the school attendance boundary survey so that it is 

easy to make additions, deletions, and modifications of the fields in one database (or table) and have 

these updates propagated throughout the rest of the database via the defined relationships? Will users 

have access to documentation that will allow them to understand entities in the school attendance 

boundary survey and the relationships between school attendance boundary geographies, the Common 

Core of Data and the American Community Survey? How does the data model address multi-part 

polygons? If a school provides services to more than one boundary, how is this modeled? If a school 

attendance boundary is served by more than one school, how is this relationship modeled? If schools

share portions of their school attendance boundaries, how is the relationship modeled? How does the 

data model address situations in which a school has different boundaries for: (1) different years of data 

and (2) different levels and grades? Will the data model include and enforce appropriate topology such 

that there are no gaps and overlaps between school attendance boundaries (and between school 

boundaries and school districts)? What are the topological rules for school attendance boundaries across 

grade spans? For example, if a portion of an elementary school boundary is supposed to share the same 
Sociology Department

Gladfelter Hall, 7th floor (025-23)

1115 Polett Walk

Philadelphia, PA 19122

phone 215-204-7760

fax 215-204-3352

email soc@temple.edu

web www.temple.edu/soc

geography (i.e., share the same line features) with a middle and/or high school boundary, will it? If not, 

why not?

What is the data collection and quality assurance plan? Will project staff contact every school district 

one-at-a-time or will the project work in a hierarchical fashion and ask states to conduct out-reach to 

their districts? Will data for districts be collected bi-annually or will data collection be staggered such 

that complete data for half of the states are collected in one year and half of the states in another? Will 

there be a mechanism for school districts to correct and update their data? How quickly can the 

correction be made—and is it possible for districts to make such corrections in real-time? What steps can 

be taken to ensure—and reassure—local and state officials that the data that they provide will not be 

degraded such that school attendance boundaries are not grossly changed, modified or discarded? What 

does the project plan to do if school district boundaries disseminated by the Census Bureau do not 

correspond with school attendance boundary geography supplied by states and local school districts? 

Will the school attendance boundary survey identify discrepancies between the two datasets? How will 

the project rectify these discrepancies—and will the project notify the public about these discrepancies? 

How will the spatial and tabular data—and user documentation—be disseminated—and what is the plan 

for user support and user outreach? Will school districts be able to request a “widget” for their web 

pages—such that school districts can install this widget and allows public school parents in their districts 

to visualize school attendance boundary geography? Will users be able to extract geographies and tables 

for specific school districts, grades, and grade spans? Will users be able to summarize data to school 

attendance boundaries—and to schools? Or will they be restricted to summarizing data to one entity? If 

users are able to summarize data to schools, how will the data be weighted (or can users weight the 

boundary data for themselves)? For example, will a user be able to query the database and ask for 

Kindergarten boundaries for the largest school districts, along with corresponding tabular data from the 

CCD and the ACS? Will a user be able to specify a geographic extent (perhaps by drawing a box on a webenabled GIS) and select and extract geographies within that extent? Who will answer questions about the 

data—or field questions about potential data errors? Who will correct errors as they arise? What is the 

plan for outreach and user support at MIS conferences, educational conferences, state-planning 

conferences, GIS conferences, and academic conferences such as the Population Association of America 

and the American Educational Research Association? 

Finally, will the Department of Education husband tax payer dollars wisely such that there is no 

duplication or waste between the school attendance boundary survey and similar public and private 

data collection and dissemination projects? Does the school attendance boundary survey have a formal or

informal relationship with private companies such as Maponics or Home Town Locator, both of which 

collect and disseminate school attendance boundary data? Similarly, what is the relationship between the

U.S.D.O.E.’s School Attendance Boundary Survey and the School Attendance Boundary Information 

System (SABINS) housed at the University of Minnesota’s Minnesota Population Center (and which is 

funded by another federal agency—the National Science Foundation)? What data, advice or information 

do these organizations exchange with one another? Are these organizations duplicating each other’s 

work—some of which is funded by taxpayers? If not, how are these projects complementary with one 

another such that taxpayer dollars are used efficiently? Will the publicly-funded projects be able to use 

each other’s data—or are their respective databases incompatible? How will geographic and tabular 

discrepancies between databases distributed by each of these organizations be reconciled? What are the 

differences and similarities between the data distributed by the U.S.D.O.E.’s school attendance boundary 
Sociology Department

Gladfelter Hall, 7th floor (025-23)

1115 Polett Walk

Philadelphia, PA 19122

phone 215-204-7760

fax 215-204-3352

email soc@temple.edu

web www.temple.edu/soc

survey, the SABINS data infrastructure project, Maponics and Home Town Locator? Would it be wise to 

consolidate the publicly-funded portions of the projects into a common project such that they share the 

same organizational chart, PI(s), personnel and advisory board? If not, how does the U.S.D.O.E. intend to 

prevent duplication?

Will members of the public be invited to submit future suggestions after the first wave of data (for the 

2010-2011 school year) have been disseminated? How will the U.S.D.O.E. respond to these questions now 

and in the future?

In my view, the U.S. Department of Education should collect and disseminate school attendance boundary 

data; the collection of such data does not place a burden on local school districts and, in my view, will

represent cost-savings to local taxpayers. Local school districts will be able to use an online digitizing 

service, as displayed on the call for public comment, and thousands of districts will be able to digitize 

(and display) their boundaries free-of-charge. This is an economy-of-scale that represents a huge 

potential costs-savings to local agencies—and thus to tax payers. Moreover, thousands of districts will 

have access to data that describe the demographic characteristics of children who live within school 

catchment areas; this again is of an enormous benefit to districts who must engage in continual schoolsite planning, enrollment projections, boundary adjustments and similar tasks. Yet, to maximize the many 

benefits of the school attendance boundary survey it is necessary to consider the questions I have asked 

(as I am certain the USDOE has) and answer them fully and publicly.