New York State Substantial Equivalency Issue

Dear Members of the Park School Community,
 
I am writing to you to ask you to take a few minutes out of your summer break to formally comment to the New York State Education Department (NYSED) within the next two weeks. All comments MUST BE RECEIVED BEFORE SEPTEMBER 2, 2019. Details, instructions and sample letters are below and attached.
 
As you are most likely aware, in April, NYSED regulations of nonpublic schools were struck down in court because NYSED did not follow state law requiring a notice and comment period prior to issuing new regulations. On Wednesday, July 3, NYSED issued new regulations of nonpublic schools and established a public comment period through September 2.
 
The proposed regulations continue to use “substantially equivalent” instruction as a vehicle to delegate the direct oversight of our school to the local public school superintendent and local board of education. The profound threats to our ability to develop curriculum and determine who is best suited to teach this curriculum continue to be serious issues.
 
Governance Threat: The regulations subordinate the legal governing authority of our board of trustees and administration to local public school officials, something that should deeply trouble everyone in our school community. Essentially what is at stake is preserving the independence of independent schools. It is precisely our independence that allows us to provide such a strong foundation for our students.
 
Unnecessary Cost: This effort is duplicative and will impose significant direct and indirect costs on our school. Our school regularly undergoes a lengthy, rigorous accreditation by the New York State Association of Independent Schools (NYSAIS). That extensive review, which benefits our school in many ways, includes a small portion of which is an evaluation of our compliance with New York’s substantial equivalence requirements. Our school greatly exceeds state standards, making the proposed mandate superfluous.
 
Burdensome Oversight: Imbedded in the proposed regulations is the requirement that our school must report to the local public school leadership, on an ongoing basis, all changes in our curriculum, leadership and staffing, and any other changes that are requested by the local public school officials.
 
Security Risk: Test scores, report cards, teacher lesson plans, as well as sensitive and proprietary information used to design curricula, would potentially be subject to public disclosure under the new regulations, jeopardizing confidential relationships between our school and families.
 
I appeal to all members of our community to formally submit a comment in support of amending the regulations to include a statement that all NYSAIS accredited schools are already substantially equivalent. This would eliminate the aforementioned problems for our school while enabling NYSED to focus reviews on unaccredited schools. This would realize significant time and cost savings. A better use of tax dollars benefits everyone.
    
Click here for instructions to submit your comments and view sample letters. It is imperative that you direct each letter to all three of the following addresses:
  1. Christina Coughlin (seregcomments@nysed.gov)
  1. Regent Collins, the Regent for our district (Regent.Collins@nysed.gov)
  1. NYSAIS (regulations@nysais.org)
 
Thank you for your assistance with this critical issue. With your help, we hope to deliver a strong response that will compel NYSED to revise the regulations to allow our school to fulfill our mission to our students and their families. With all of our voices heard, we hope our collective influence ultimately leads to improving education for all children.
 
Best regards,
Jeremy Besch
Head of School
 
To view the NYSED regulations, please click here

https://www.dos.ny.gov/info/register/2019/jul3.pdf
Founded in 1912, The Park School of Buffalo has the distinction of being one of the oldest Progressive schools in the country. Park is an independent, co-educational school serving approximately 300 students enrolled in prekindergarten (3 and 4 year olds), lower school (kindergarten through grade 4), middle school (grades 5 through 8), and upper school (grades 9 through 12). Park is uniquely situated on 34 beautiful acres in Amherst, New York. The School’s campus – formerly a farm – includes a pond, marsh, gardens, and a greenhouse while being located just minutes from downtown Buffalo and easily accessible from many communities throughout Western New York. Park’s educational philosophy embraces active, student-centered learning, delivered by exceptional teachers who design and continuously update a robust curriculum. Faculty members approach each student as an individual within the context of a kind and respectful community. From the preschool years through college preparation, The Park School of Buffalo helps learners realize their own unique potentials and prepares them to be confident, successful, life-long learners.

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