Public comments on minimum ed standards revision are overwhelmingly in opposition

NH Department of Education.

CONCORD, NH – The NH Department of Education’s proposed update of minimum standards for public education is drawing significant backlash from the public, at least according to the overwhelming opposition contained in over 200 written comments sent to the department.

The public comment period on the proposed changes to the minimum standards – known as the 306 rules – came to a close April 30. A total of 204 written testimonies were sent to the state Board of Education and made public on the department’s website. All except one of the 204 written accounts were in opposition to the current revisions.

The department’s proposed revisions of the minimum standards, which are updated every 10 years, have received intense opposition from educators and other stakeholders since they were released Feb. 15. The overwhelming majority of speakers voiced their opposition at the board’s two public hearings in April. 

In addition, attorneys in the Office of Legislative Services, an arm of the NH Legislature, voiced several concerns about the proposal – including its constitutionality – in a draft reviewing the proposal for legal compliance.

The main points of concern in the public comments sent to the board included potential removal of state public education funding, eliminating caps on classroom sizes, shifts in wording from “shall provide” to “may include” – which educators assert makes certain program elements optional – and the overall impact on student achievement going forward.

“While neighboring states move ahead with forward-thinking proposals and programs, the NH Department of Education seems determined to drag us backward and squash our kids’ chances of reaching their potential,” wrote Richard Popovic of Nelson. Sara Lewis, a music teacher at Josiah Bartlett Elementary School in Bartlett and interim principal at Pine Tree Elementary School in Conway, had similar sentiments.

“Our neighbors in Vermont are doing just the opposite,” she wrote. “Increasing funding to put MORE money toward students who have been historically marginalized and discriminated against.”

MaryEllen Reinself of Enfield echoed concerns over New Hampshire’s educational standing.

“When compared with other states, New Hampshire has a very strong national ranking for the quality of its public education. These proposed revisions to the 306 Rules threaten to eviscerate public education in New Hampshire,” she wrote.

Catrina Annis of Berlin raised concerns over the future of her children’s education in a district with lower funding.

“As a parent of two children in the Berlin Public Schools in the county of COOS how dare you attempt to reduce the standards in place for our children.”

Asked why she felt motivated to provide testimony, Annis replied to the Granite State News Collaborative in an email:,  “Our taxes are high yet our schools are in disrepair and our students and staff have to make do with lower quality materials and supplements … not only are we significantly poorer, we are receiving less help from the state then they are obligated to provide.”    

Despite Kent Hackmann’s granddaughter being in her last year of public school, he also expressed concern over the future of New Hampshire’s education.

“I am 86, a vet … and the grandfather of a student completing her senior year in high school. I am a firm believer in the role of public school education,” he said.

Greg Eaton of Winchester communicated his worry over potential impact on taxpayers.

“This is a horrible idea as a way for the State to save money. Education is not the place to make those changes and cuts,” he wrote. “The direct potential effect on us as parents in a small NH Town is frightening.”

Another motivator to publicly comment was due to the removal of “acknowledgement of “diversity” from the standards and instead replacing it with “respect for differences.”

Jacob Bennett of Chester took particular issue with this.

“Deleting ‘diversity’ from existing language in Ed 306.06 cannot be understood as a mere editorial decision but a fundamental shift away from requiring affirmative policy and toward allowing passive ‘respect for differences,’” he wrote.

Some commenters specifically called out Education Commissioner Frank Edelblut and state Board of Education Chairman Drew Cline.

“This is a blatant misuse of power and a reminder that Commissioner Edelblut is trying to dismantle New Hampshire’s public schools. The fox guarding the henhouse, indeed,” wrote Mel Hinebach of Concord.

“I am outraged by the deceit, the outright lies, and most of all, the anti-democratic agenda so obviously promoted in the 306 revisions. Cline has a mission to impose his own conservative philosophy onto New Hampshire’s educational system, thereby harming public schools in his fervor to transfer badly needed public money to private, often religious schools and homeschooling,” said Kris Flather of Hanover.

“These revisions threaten to hurt our students by redefining and watering down what is considered an essential, required, and adequate education in New Hampshire,” wrote Sean Parr, a member of the Manchester Board of School Committee and chair of its Education Legislation Committee

When asked later why he felt compelled to include his voice in the conversation, he replied, “The Ed. 306’s are something that we as a board have been pretty unanimous about the whole time and I thought it was important to go on the public record, expressing that.”

He also emphasized the disconnect between two state bodies, the Department of Education and the Office of Legislative services.

The commissioner and board have repeatedly emphasized their belief that the document is in the best interest of students, but educators, parents and taxpayers continue to fear the impacts of the revisions if passed.

“This weakening of our public schools seems to me to be part of a national campaign by extremists to dismantle one of the cornerstones of our democracy,” said Charles Rhoades of Dover.

Liz Tentarelli of Kearsarge left the Board with an important message and plea.

“You have the opportunity to turn down these suggestions,” she said. “If a diploma from a NH high school is to stand for anything, you need to discard these vague 306 standards and start anew, with expert and professional input from those who will use them to teach. Remember where your responsibility lies: with the schools and the students, not with Mr. Edelblut.”

The only person to write in favor of the proposal was Luke Felthun of Bedford. He said he felt that keeping the wording change of “may” from “shall” when referencing program elements was a good decision. 

“This may not be an ideal approach but is nevertheless an improvement as many of the requirements increased student and teacher workload without adding meaningfully to learning,” he said.

In addition to the individual public testimony, Christine Downing, director of curriculum, instruction and assessment for the Cornish, Grantham and Plainfield school districts, submitted testimony from her own educator review sessions, in which she and educators across the state came together on multiple occasions to analyze the dept’s proposed revisions. 

Within the 13-page testimony, Downing outlined important educator recommendations for the board to consider.

Educators who attended Downing’s sessions found that not all minimum standards had actually expired. The standards must be updated every 10 years, but from time to time certain sections are individually updated within those 10 years, leading to varying expiration dates. Downing’s team recommended putting the most focus towards the standards that are about to expire and creating more time to come to agreements on the ones whose dates are not as pressing.

The Department of Education issued a statement responding to the heated criticism in the public comments that were submitted:

“The New Hampshire Department of Education appreciates and welcomes the public feedback that has been received. It is clear that, given the substantial public interest, there are strong feelings and significant input regarding the vast importance of updating the Ed 306 Minimum Standards Rules. This is understandable and not unexpected given the significant impact of the rules, which is evident based on the 30-year history of previous attempts by the New Hampshire State Board of Education to update and revise minimum education standards for public schools – most notably similar issues that were raised in 1992 that captured nationwide attention.”

The department provided two links to New York Times articles from August and November 1992 regarding previous education standards revisions in New Hampshire that caused considerable public concern. At the time, the state school board at first voted to eliminate virtually all minimum state education standards and allow districts to set their own. The state board eventually backtracked on the plan in the race of immense opposition.

“We are pleased that this has been a robust process with active participation from the public, and we are excited for the State Board to move forward with its responsibility of rulemaking. The State Board is in the process of reviewing public input and will take all comments into consideration during its revisions to the rules,” the department’s statement concluded.

On June 11 at 10 a.m., Commissioner Edelblut attended a public meeting of  the Legislative Oversight Committee for the Education Improvement and Assessment Program to further discuss the revisions. The meeting took place at the Legislative Office Building in Concord. You can watch a livestream  of the meeting here

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