Comment of Advancement Project

Comment of Advancement Project




August 26, 2009


Secretary of Education Arne Duncan

U.S. Department of Education

400 Maryland Avenue, SW, Room 3W329

Washington, DC 20202


Mr. Secretary,


As a national racial justice organization dedicated to supporting the work of organized, multi-racial, grassroots organizations, Advancement Project is disappointed that DOE’s proposed criteria are missing an historic opportunity to take steps to dismantle the structural barriers to educational opportunity facing youth of color. By focusing narrowly on measurement, DOE is supporting test and punish strategies that exacerbate inequality while failing to incentivize innovation to attack structural inequity at the roots. We agree with the detailed critiques of what is in the proposed criteria provided in other groups’ comments (Fair Test, EPI, NEA, and CLASP). We write to highlight what has not been proposed.


DOE’s vision of innovation is focused on measurement: more and better tests used more and better.  But this is, at best, a backdoor way of attacking structural inequality in our public schools. There is no reason not to attack inequity directly. DOE should be incentivizing innovation to equalize educational inputs for all students. Specifically, DOE should reward states who are taking steps to: allocate resources fairly so that every student has access to a high quality education, provide effective teachers to all students, and provide an engaging and challenging curriculum to all students.


In addition, DOE should encourage innovation aimed at making sure that schools support student learning for all students. Specifically, DOE should reward schools that provide more support to students through interventions and counseling, and move toward non-punitive disciplinary alternatives to policing and punishment.


Too many students go to schools that: do not engage them, punish them harshly, and do not challenge them to succeed. Students cannot learn in this setting. These are the structural barriers that so many students of color face every day in school. Real reform must break down these barriers. DOE’s proposed measurements are not that reform, they are a distraction.