The administrative rules, known as the 306s, are undergoing a once-a-decade update

Education Commissioner Frank Edelblut during 2019 interview with The Conway Daily Sun. (Jamie Gemetti/The Conway Daily Sun)

In the wake of a report highly critical of proposed statewide educational reforms in the works for two years, local educators sat down for the first time this week with members of the task force overseeing the revisions.

When pressed for details on the Nov. 7 meeting and what it could mean moving forward, attendees willing to even acknowledge it occurred would only describe the session as productive.

Megan Tuttle, NEA New Hampshire president, said she left the meeting feeling hopeful that educators’ voices are now being heard in the revision process. “(This) meeting was the time we were invited to be part of it,” she said. “If this had been done two years ago, I think we’d be in a very different spot today.”

The gathering came just days after the release of a 20-page report detailing criticisms from 176 state educators of proposed changes to the state’s minimum school standards, better known as the 306s.

The report was compiled by Christine Downing, who this fall conducted seven workshops with state educators to review and critique the proposed changes.

Downing is the director of curriculum and instruction in SAUs 32 (Plainfield), 75 (Grantham), and 100 (Cornish).

The report highlighted concerns the proposed changes, which proponents say advance competency-based learning, would actually undermine that approach while weakening local control of educational priorities. The revisions also don’t consider evidence-based research about best practices in education, the report contends.

In its conclusion, the report questioned “the motives and intent” of the New Hampshire Department of Education, Commissioner Frank Elderblut and the state Board of Education by “putting forth rules that include documented instances of contradictions, vagueness, and blurring of local and state control.”

“Ultimately, it will be public school students who will pay the price for such callous actions should the Commissioner and State Board of Education choose to proceed forward with rulemaking,” the report said.

The 306s are part of the Joint Legislative Committee on Administrative Rules and are currently undergoing a once-adecade revision process. The Department of Education provided a sole-source contract in 2020 to the National Center for Competency-Based Learning, a nonprofit led by Fred Bramante, former chairman of the New Hampshire State Board of Education from 2003-2005 and longtime education policymaker in the Granite State.

Educators and others have criticized the revision process as happening outside the public purview and with little input from people who work in schools. The 13-member task force, appointed by Bramante, does not include any classroom teachers — a fact that drove Downing to ensure that educator input was heard, even when it was not solicited by the task force.

“That’s why I did what I did. I firmly believe the practitioner’s ... voice was missing,” she said. “I wanted to get the report out there and get it noticed, to get the voice of the educators on record.”

Downing has no official role when it comes to the revision of the 306s, and yet she has become one of the loudest voices advocating for educators’ concerns to be heard. Last November she was one of about 50 educators invited to give feedback on the task force’s proposed revisions at an event that Bramante’s group held in Laconia. She left with “grave concerns,” about the revisions, feeling that teachers needed more time to review the changes and provide professional input.

Downing took it upon herself to organize seven informational sessions for educators, mostly in September of this year, allowing them to review the 306 revisions and provide feedback. At those sessions, educators worked in small groups to provide 57 written responses to the proposed rule changes.

In October, Downing compiled the report summarizing those responses, which she emailed to members of the House and Senate Education Committees, as well as stakeholders including Bramante. As of Nov. 7, she had not heard back from any of those legislators, which she said is “disappointing.”

Downing’s analysis found that only 5% of educators felt that the revisions represented an improvement to the 306s, while 70% felt the rules “needed further changes.”

Downing identified three key areas of concern from educators. First, about the language used in the report, including the removal of the word “local” in many sections referencing school boards, which educators felt opened the door to chipping away at local control of education.

One piece of educator feedback cited in the report reads, “It seems like (the rules) are moving from one haphazard body of language to another.”

Bramante acknowledges this worry, particularly about the word “local,” but said it has “questionable merit.” He said that the definitions section of the 306s clarifies that “school board” means “local school board,” but added that his task force may reinstate the word “local” throughout the document to address this concern.

The second major theme identified in the report is “missed opportunities to advance competency-based education (CBE) throughout public schools in New Hampshire.”

Downing emphasized that New Hampshire has been a leader in competency-based education. She worries that the 306 task force members are “so removed from the reality of what happens in our public schools that they’re actually going to do detriment to our system, (rather) than supporting our system.”

Finally, educators expressed concern about the lack of evidence-based research in “critical areas,” ranging from class size to equity policies.

Asked if he had seen Downing’s report, Bramante replied, “I think so.” He said he respects Downing’s input since she also supports competency-based education, but expressed concerns that other educators “want to go back to the old model.”

Downing vehemently denies that. “No one wants to go back to the ’70s, ’80s, or ‘90s,” she said. “People are willing to move forward.”

Downing also expressed hope — something she says she has to cling to as a product of New Hampshire public schools and a lifelong educator.

“If I lose hope, I’ve lost the battle, and frankly it feels like a battle right now,” she said.

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Educators expressed concern about the lack of evidence-based research in “critical areas,” ranging from class size to equity policies.