Testimony Presented by
Co-founder, Oregon Save Our Schools
835 N. Elm Street,
Canby, Oregon 97013
June 21, 2012
Re: Pursuant to ORS 183.335(14)
NOTICE OF ADMINISTRATIVE RULEMAKING FOR PROPOSED ADOPTION BY THE STATE BOARD OF EDUCATION. Teacher/Administrator Evaluation
We have carefully examined the current version of proposed rule changes for teacher and administrator evaluation. We find four major issues in these changes. These issues are explained below.
1. Since Section(1) says that the "standards shall be customized based on the collaborative efforts of the teachers and administrators of the school district and the exclusive bargaining representative of the employees of the school district, Sections (2) and (4) are unnecessary and abrogate local decision making prerogatives. The state has failed to make clear the compelling reasons for any of the proposed changes---all of which are more prescriptive by the state.
2. By listing "student assessments" in Section (2) and "formative and summative assessments" in Section (4) as possible measures that can be used in personnel evaluation, this draft actually validates using test scores to evaluate teachers and administrators. This practice has been decried by the nation’s ten most highly respected testing experts. See http://www.epi.org/publication/bp278/. Given this compelling evidence, shouldn’t the state forbid this practice rather than validating it?
3. It is unclear from the annotations in the proposed changes whether the suggested rules changes propose a complete deletion of Section (3) (c). That section states: "Allow teacher or administrator to establish a set of classroom or administrative practices and student learning objectives that are based on the individual circumstances of the teacher or administrator, including the classroom or other assignments of the teacher or administrator. The unique context in which teachers and administrators work greatly impacts their work, and this context must be considered in effective evaluations. If the intent is to entirely eliminate this section, we vigorously oppose that deletion.
4. Our final deep concern is that this draft of rule changes attempts to implement elements of an evaluation bill that failed in the last legislative session. By refusing to pass legislation that would have clearly violated principles of local control, our legislature has spoken. Rule-making such as proposed in this draft clearly violates legislative intent---and core principles of local control.