**Sociology Department**  Gladfelte r Hall, 7th floor (025

- 2 3 ) 1115 Polett Walk Philadelphia, PA 19122 phone 215

- 204

- 77 60 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 c all for public comment regarding the collection of all K to 12 school attendance boundaries embedded within s chool districts throughout the United States. I endorse the Department’s efforts to collect a nationwide database consisting of school attendance b oundary information

. The dissemination of s chool 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 official s , members of the public, policy

- maker s and ac ademic researchers and, as such, will vastly improve the de livery 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 serie s 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, an d 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 ? W ho are the key participants on the project and what are their responsibilitie s? 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 ser vice ? Who is responsible for preserving the accuracy of the original information that is collected and who is responsible for d ata 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 complete ly?

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 u niversities, and the GIS communi ty ? For example, will the project recruit local or state superintendent s (or elected school board members and state

- level officials ) so that the project is responsive t o the needs and**Sociology Department**  Gladfelte r Hall, 7th floor (025

- 2 3 ) 1115 Polett Walk Philadelphia, PA 19122 phone 215

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concerns of the jurisdictions that supply data to the project

— and that will eventually use th e data that they supply ? Has the DOE considered inviting Jack Dangermond

— the president of Esri

— or another high

ranking official from Esri to partic ipate 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? W ho will recruit board members

— the Principal Inv estigator 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 sch ool 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 long

term goal of th e 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 boun dary survey comply with l egally 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 digitiz ing

— both by Census Bureau staff and on the remote digitizing service? Will the attributes be specified clearly in the metadata? Will the me tadata 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 robu st 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 i n 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 m ore 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 school s share portion s 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 sc hool 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**  Gladfelte r Hall, 7th floor (025

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ge ography (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 o f the states in another? Will there be a m echanism 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 r eassure

— 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 discrep ancies

— 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 extrac t 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 summari ze 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 web

enabled GIS) and select and extract geographies within that extent? Who will answer questions about the data

— or field questions abo ut potential data errors? Who will correct errors as they arise ? What is the plan for outreac h and user support at MIS conferences, educational conferences, state

- planning conferences, GIS conferences, and academic conferences such as the Population Associ ation of America and the American Educational Research Association?

Finally, will the Department of Education husband tax payer dollars wisely such that there is no duplicatio n 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 Surve y 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 comple mentary with one another such that taxpayer dollars are used efficiently? Wil l the publicly

- funded project s be able to use each other’s data

— or are their respective d atabases incompatible ? How will geographic and tabular discrepancies between databases distributed by e ach 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**  Gladfelte r Hall, 7th floor (025

- 2 3 ) 1115 Polett Walk Philadelphia, PA 19122 phone 215

- 204

- 77 60 fax 215

- 204

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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 shou ld collect and disseminate school attendance boundary data; the collection of such data does not place a burden on local schoo l 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 contin ual school

site 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 the m fully and publicly.