Opinion: The fox is in the hen house on 306 rules draft


Published: 06-29-2023 6:00 AM

Sarah Robinson is the education justice campaign director for Granite State Progress.

When I was in elementary school, my art teacher introduced me to oil pastels. I had never used them before. When I felt it glide smoothly across the surface of the thick paper she had given us, something changed in my brain. I felt freedom to create something that was new and exciting.

Without access to that teacher and those materials, I would never have discovered my love of art and the medium that spoke to me in a way I could understand. Yes, this is a small personal experience, but it’s one that’s followed me throughout my life. I return to art to process difficult emotions or to simply sit in the joy of form, color and light. It’s made my life richer.

A person’s education is one of the most important aspects of their lives, apart from the essentials of life like family, food, and shelter. A strong educational foundation gives children the opportunity to become strong young adults with the tools to pursue their dreams. It also gives our society business and civic leaders and educated community members to steward our democracy and nation.

But a student’s educational experience is not just about one or two subjects. It also includes building friendships and community and trying new things. Was art your favorite class in school? Maybe it was music class? Did you have a teacher in one of those classes that saw your inner artist or a physical education teacher who encouraged you in athletics?

So many essential aspects of our children’s education that bring richness and fullness to a student’s experience are outside of the traditional subjects of reading and mathematics, and that is a good thing. However, if it is up to the State Board of Education and Education Commissioner Frank Edelblut, those essential pieces of education will be removed from public schools and eliminate key opportunities for our children to learn and thrive.

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We previously witnessed the commissioner’s attempts to gut our children’s learning experiences when he supported HB 1671, a curriculum bill in 2022 that proposed to remove everything from the classroom except the “bare essentials” of learning, basically math, reading, and science. That was rightfully derided and soundly revised by state legislators who understand the critical role arts and music education plays and the importance of a robust overarching education.

With those plans and other attempts foiled, Commissioner Edelblut has now set his sights on the ED 306 Administrative Rules, also referred to as the Minimum Standards for Public Education, as another path to joyless and meaningless education.

The 306 rules are the primary tool for establishing an adequate education in our state. It’s the large and detailed compliance document that determines everything from professional certification for educators to academic standards and accountability for students to what food is served in the cafeteria. What goes into the rules being drafted under Commissioner Edelblut will define public education for the next ten years. That’s almost the entirety of the K-12 experience for a student.

Given the significance and breadth of this issue, a wide range of stakeholders should be included in the conversation around the 306 rule draft, including school administrators, educators, parents, and students. While the State Board of Education has never had a sufficiently inclusive process for drafting these rules, the real issue this time around is the intentions of the folks at the helm.

Neither Education Commissioner Frank Edelblut nor the members of the NH State Board of Education support public education, based on their actions. Governor Chris Sununu nominated these individuals for the opposite reason it seems, because they have track records of opposing strong public schools.

Now, these same appointed decision-makers will do real damage to public schools, which 86% of Granite State families choose, unless we raise our voices.

The currently proposed harmful changes to the 306 rules would reduce the curriculum to a shell of itself by removing large quantities and subject topics, including eliminating art, music, and PE in our elementary schools. Any reference to equity, race, gender, or other protected classes has also been removed. The language that focuses on tailoring lessons to students’ talents and interests, in order to spur interest and encourage learning? Gone. Also notably absent is any attempt to define an adequate and robust education, because Commissioner Edelblut knows that means that public education will have to be fully funded if so.

Justice and joy are a foundational part of public education and those elements have been surgically removed from the administrative rules that determine the student experience. This destruction does not end at the classroom threshold, either.

The days of internships being about fetching coffee or organizing files should be long over. Students should be learning actual skills, whether that’s creating graphics for a local nonprofit or aiding a teacher in their lesson plans to learn whether an education career might be a good fit. Many school districts outline clear standards where a student meets with an advisor to ensure that they learn something, and set goals to meet throughout the internship.

But the new draft language removes the accountability piece, opening up students to be exploited by places looking for free labor that don’t offer any real learning opportunities. Commissioner Edelblut’s ill-fated Learn Everywhere program has been attempting to pull students away from formative experiences and into vulnerable territory for more than a year now. Enshrining these labor-law thwarting attempts into the 306 rules would do real harm to academic rigor in out-of-class settings and set students up for exploitation.

These revelations of harm and disruption should be alarming, but what are we as parents, students, taxpayers, and conscientious Granite Staters able to do about it? We need to hold Commissioner Edelblut and the State Board of Education accountable and demand a better set of 306 rules before they are finalized.

Public listening sessions are being hosted in districts across the state as part of the formal public process of adopting the rules. Granite Staters need to be present in these sessions to lift our voices and demand that our concerns be taken seriously. We can also email the State Board of Education and tell them not only what we don’t want them to do, but what our dreams and hopes are for our students.

Our students deserve more than an adequate education, they deserve an excellent education and we deserve a commissioner that shares that vision.