Evidence and Concerns

A rising number of teachers, parents and taxpayers are expressing concerns about South Dakota’s adoption of the Common Core Initiative (CCI), its accompanying federal standards for states (CCSS) and its federally overseen and controlled testing arm (SBAC). Why?

1. South Dakota did not seek out CCI; the initiative was presented as an eligibility enhancement by the U.S. Department of Education in its The Race To The Top grant. Joining the SBAC, too, improved eligibility in the grant application. When South Dakotaagreed to join the CCI and SBAC in 2010, the standards had not yet been written.
South Dakota joined both the CCI and the SBAC to win points toward getting the grant, and although South Dakota won no money, the extremely expensive and educationally restricting consequences of having agreed to sign up for CCI and SBAC remain.

2. South Dakota has two conflicting sets of educational standards to juggle– the South Dakota Core, to which we currently test, and the CCSS. South Dakota is not likely to stick with the Dakota STEP when testing begins based on the federal CCSS in 2014. The appendix to the SBAC states that the tests will be based on the CCSS (federal) standards, and the SBAC project manager, WestEd, has affirmed:
In order for this [testing] system to have a real impact within a state, the state will need to adopt the Common Core State Standards (i.e., not have two sets of standards.)” -April 2012 statement from WestEd Assessments and Standards Senior Research Associate
3. There is no amendment process for the CCSS (federal standards) and withdrawing from the SBAC requires consortium and federal approval (page 14). If we delay the state will be too financially invested and legally entangled to withdraw.
4. There has been no cost analysis or legal analysis. Implementation of CCI has already begun in South Dakota schools; full implementation of the initiative and its tests will be completed in the 2014-2015 school year.
An independent think tank in Massachusetts states that the cost over the first 7 years to states will be 16 billion dollars, or over 200 million per state, on top of regular educational needs. The Congressional Budget Office was not asked to do a cost analysis because asking would have pointed out that this was not a state-led initiative, contrary to the claims of its proponents. States’ commitments to CCI require billions of dollars in implementation and maintenance spending, money that competes with already-stretched educational budgets.

5. South Dakota leaders have signed South Dakota on as a governing member of the SBAC. As a governing member we get one vote out of 21 governing states to influence deviations from the original assessment structure and scope, consortium policy, and consortium governance. South Dakota can be held hostage by other states.
6. The U.S. Department of Education (through the America COMPETES Act, the American Recovery and Reinvestment Act, and the Race to the Top competition) has required the states to develop massive databases about school children.
7. The Common Core initiative represents an overreach of federal power into personal privacy as well as into state educational autonomy. There will be personal student information collected via the centralized testing-data collection, accessible to the Executive Branch. SBAC assessments’ includes psychometric testing for database profiling purposes.

8. Both of the CCI’s testing arms (SBAC and PARCC) must coordinate tests and share information “across consortia” as well as giving the U.S. Department of Education phone responses, written status updates and access to information “on an ongoing basis.” Data will be triangulated with control, oversight and centralization by the Executive Branch (U.S. Dept. of Education). “Cooperative Agreement between the U.S. DOE and the SBAC
9. The Department of Education has eviscerated the Family Educational Rights and Privacy Act (FERPA) by issuing new regulations that allow nonconsent tracking and sharing of this personal data with other federal agencies, with government agencies in other states, and with private entities.
10. South Dakota has ceded her voice and educational sovereignty because South Dakota’s top educational leaders are persuaded that having standards and testing in common with other states matters more than holding onto the state’s right to raise standards sky-high. To South Dakota education leaders, the right to soar seems a freedom not worth fighting for, and maintaining state educational sovereignty is not a priority.
11. The effort to nationalize and centralize education results in severe loss of state control of education and pushes states into a minimalist, common set of standards.  Dr. Sandra Stotsky, an official member of the CCSS Validation Committee, refused to sign off on the adequacy of the standards and testified that “Common Core has yet to provide a solid evidentiary base for its minimalist conceptualization of college readiness–and for equating college readiness with career readiness. Moreover…it had no evidence on both issues.”
13. Common Core standards are not considered among the best standards in the nation, and there are clearly superior standards.  Additionally, the CCI robs states of the sovereign right to raise state standards in the future. There’s no provision for  amending the CCSS federal standards, were we to choose to still remain bound by them.
14. The Common Core English standards reduce the study of literature in favor of informational texts designed to train children in a school-to-work agenda. The unsophisticated composition of those selected to write the Common Core Standards and the lack of transparency about the standards-writing process also raises concerns.
15. CCSS states a goal to promote “career and college ready standards,” a euphemism for “school-to-work” programs, diluting individual choice by directing children where to go and what to learn. They make no distinction between 2-year, 4-year or vocational standards.
16. Common Core has not proven to be state-led nor strictly voluntary; the U.S. Department of Education Secretary rages against states who reject the Common Core Initiative.
When South Carolina Governor Haley backed away from the “voluntary” CCSS, she drew a sharp response from Arne Duncan, the federal Secretary of Education.  Duncan also publicly insulted all Texas students on television, saying “I feel very badly for Texas school children,” following Texas Governor Perry’s refusal to join the CC initiative. (Yet Texas math standards are higher than Common Core standards.)  Messages in public letters from Duncan to South Dakota leaders conflict with multiple, legally binding documents signed by his team at the U.S. Department of Education.
17.  The Common Core Initiative, far from being state-designed, is the product of the U.S. Department of Education funding and directing special interest groups (NGA, CCSSO, NCEE, Achieve, Inc., WestEd, and others) via federal grants.
18.  The Common Core Initiative violates fundamental laws that protect states’ independence. The Federal Government’s creation of national curricular materials, through contractors, and its control and oversight of testing and data collection, and its tests written to federal, nationalized standards, are in violation of three existing laws: NCLB, the Department of Education Organization Act, and the General Education Provisions Act; States have a responsibility to protect the balance of powers granted in the Constitution.
19.  Transparency and  public debate about Common Core are lacking.  South Dakota educational leaders have a responsibility to encourage public discussion and lively debate about Common Core, because the initiative will impact children, taxpayers and teachers for a long time to come.

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