English learners. However, “protected time” is not defined. Recommendation: PTA recommends that the CDE and State Board define “protected time” in further detail within the regulations that allows for public comment. Otherwise, teachers and parents will not know what to expect nor anticipate for each English learner in terms of their rights and access to ELD. Cynthia Rice, et al. See Letter #3 Martha Zaragoza-Diaz See Letter #1 Liz Guillen See Letter #8 Commenters suggest that “The definition of "English Learner Parent Advisory Committee must be expanded so that it is consistent with current law.” Recommendation: (b) "English learner parent advisory committee", means the committee established by a school district or county superintendent of schools pursuant to Education Code sections 52063 and 52069, 52176(b) and (c), 62002.5 and 64001(a) and Title 5 California Code of Regulations sections 11308 and 15495(b). REJECT The proposed regulations are consistent with the requirements of EC sections 305, 306, 310, 52063, and 52069. Proposed section 11301(b) suggests methods for engaging stakeholders [defined in proposed section 11300(k)], school advisory committees, or other groups representing stakeholders. 11300(d) Cynthia Rice, et al. See Letter #3 Martha Zaragoza-Diaz See Letter #1 The proposed definition of "language acquisition program" is inconsistent with Education Code section 306. Recommendation: “Language acquisition programs” are educational programs designed for English learners to ensure English acquisition as rapidly and effectively as ACCEPT (in part) The suggested language naming the language acquisition programs described in EC Section 306(c) is added to the definition of “language acquisition programs.” In addition, the term “grade-level” has been added to section 11309(c)(3)(A) to align with the statute; section 11309(c)(3)(B) did not necessitate a change because it already aligned with EC Section 306(c).
11311(f) See Letter #4 below. Commenter also requests that “Dual Language Immersion, Transitional and Developmental Language Acquisition Programs be defined.” Recommendation: “Multilingual Language Programs (MLPs)” are Language Acquisition Pprograms that are designed to provide opportunities for pupils to be instructed in languages other than English to a degree sufficient to produce proficiency in those languages, consistent with the provisions of Education Code section 305, subdivision (c). Multilingual Programs include Dual Language Immersion, Transitional and Developmental Language Acquisition Programs. The term “multilingual” is incorporated into the current title of Chapter 11, Subchapter 4. The proposed subchapter is now titled “Multilingual and English Learner Education.” Proposed section 11300((h) defines the term “multilingual,” and proposed section 11311(f) incorporates the same term to describe some program models as “multilingual.” REJECT (in part) The recommendation as written is not consistent with EC sections 305(c) or 306. 11300(i) Jorge Cuevas Antillón See Letter #4 Recommendation: ”Parents” means the natural or adoptive parents, legal guardians, or other caretakers persons holding the right to make educational decisions for the pupil pursuant to Welfare and Institutions Code section 361 or 727, or Education Code section 56028 or 56055, including foster parents who hold rights to make educational decisions. REJECT The current language sufficiently addresses any person who holds legal rights to make educational decisions for a child. 11300(k) Mary Perry See Letter #7 On Page 2, line 15 “Stakeholders” means parents, pupils, teachers, administrators, other school personnel, and interested members of the public. Recommendation: REJECT The current language sufficiently addresses any person who holds legal rights to make educational decisions for a child. The use of “parents” in the remaining regulations is consistent with the statute.
PTA recommends inserting “and families” after parents. We would make the same recommendation throughout the regulations wherever “parents” are referenced. 11301 Form Letter See Letter #9 The definition of Parent Engagement must include and go beyond the advice of the English Learner Advisory Committee. The LCAP process for parent engagement is an outreach to all parents not just advisory committees. In addition, the language acquisition programs are for English Learners and parents of native English speakers. Only consulting the LCAP English Learner Advisory Committee does not include engagement of all parents and is a very limited definition for engagement in the process of establishing language acquisition programs. REJECT The proposed regulations are consistent with the requirements of EC sections 305, 306, 310, 52063, and 52069. Proposed section 11301(b) suggests methods for engaging stakeholders [defined in proposed section 11300(k)], school advisory committees, or other groups representing stakeholders. Mary Perry See Letter #7 Recommendation: On Page 3 beginning on line 18 amend to read: As part of the development of the LCAP and annual updates, an LEA shall inform and receive input from stakeholders, including the English learner parent advisory committee and the parent advisory committee, and other parent and family organizations on school sites including but not limited to the Parent Teacher Association, school site councils, and other groups, regarding the LEA’s existing language acquisition programs and language programs, and establishing other such programs. REJECT The proposed regulations are consistent with the requirements of EC sections 305, 306, 310, 52063, and 52069. Proposed section 11301(b) suggests methods for engaging stakeholders [defined in proposed section 11300(k)], school advisory committees, or other groups representing stakeholders.
Recommendation: (B) In the case where the LEA determines it is not possible to implement a language acquisition program requested by parents, the LEA shall provide an explanation of the reason(s) the program cannot be provided, and shall take reasonable steps to offer may offer a suitable an alternate option that can be implemented at the school as well as enrollment of pupils in the requested language acquisition option at another school in the LEA. available at another to request alternative attendance following local procedures. School districts adopt local procedures that allow for open enrollment or not. The local policies, however, allow for local appeals. REJECT (in part) The recommended language has already been addressed in proposed section 11311(h) Cynthia Rice, et al. See Letter #3 Martha Zaragoza-Diaz See Letter #1 The regulations should clarify and strengthen the type and form of notice required when a school district denies a parental request for a language acquisition program. Recommendation: Apply the type of language used for denial of waivers in the regulations for Prop 227, including a full written explanation for denial so parents can challenge a denial if they do not agree. ACCEPT (in part) Proposed section 11311(h)(3)(B) is modified to require that an LEA provide a written explanation of the reasons why a language acquisition program will not be implemented. This requirement provides documentation for parents to approach the local governing board with possible concerns regarding such a determination, if so desired. REJECT (in part) Application of the type of language in the regulations for Proposition 227 is not consistent with EC sections 305 and 310. 11311(h) Cynthia Rice, et al. See Letter #3 Martha Zaragoza-Diaz A response time of 90 days to act on parental requests encourages needless Recommendation: The regulations should be revised to include a requirement that the district notifying the Notification of Available Programs REJECT EC Section 310(b)(2) requires notice to all parents on the types of programs available in the district. The process for this notice is outlined in proposed section 11310.