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AFT-NH Testimony on Feb 15, 2024  Initial Proposal for Minimum Standards for Public School Approval: ED 306

From Debrah Howes, President AFT-NH

Thank you, Chairman Cline and Members of the State Board of Education, for taking listening to my public comment today.

My name is Debrah Howes. I am president of the American Federation of Teachers – New Hampshire.

I am here to speak on behalf of our 3700 members across the state. Our members include preK through 12 public school educators and support staff, university faculty as well as town employees. We work with close to 30,000 students every day in public schools in various districts across the Granite State. I am here today to talk about the Initial Proposal for the Minimum Standards for Public School Approval. 

It is vitally important to get these standards correct because they have a huge impact on the way the 160,000 students who rely on our local public schools access their public education. These standards set a floor for what sort of facilities they have, what programs are offered, whether class sizes are kept small, even whether they have a school nurse on site. What you approve in the ED 306 Rules will affect almost every aspect of their educational experience, for good or bad, yet to date there has been no systematic outreach to public school parents and students to find out what they like, value, and even cherish about their public schools and what they want to see improved. How can you know what needs to be kept and what needs to be changed if you haven’t asked this basic question of the most important stakeholders?

The changes that have been made to the minimum standards in this initial proposal are concerning and could have a large impact on students’ educational experiences in their public schools. I will highlight just a sample here:

  • Changing “instruction” to “learning opportunities” de-emphasizes the role of the professional, credentialed teacher in planning and organizing a series of lessons and units of study to make sure students learn and can demonstrate all the required competencies, don’t have gaps in their knowledge and can build on previous learning. If not led by a professional, certified teacher, will all those “learning opportunities be good quality, cover all of the required competencies, and have academic rigor? Or will students be left with a jigsaw puzzle of scattered competencies with many missing pieces so that the picture never comes together? Will some of the “learning opportunities” mentioned in the draft consist of watching a series of short videos and answering multiple choice questions that require no analysis, synthesis or any other higher level thinking be called good enough? Also, if professional, credentialed  teachers providing “instruction” are replaced with “learning opportunities, then cash strapped districts will cut positions, students will have fewer trained professional educators to support them when they struggle with anything academically, or when they need a challenge.
  • Removing class size limits in Grades K-12, as this draft does, will negatively impact students’ educational experience. More students in each classroom means less opportunity for individual attention from the teacher, less help for struggling students and less challenge for gifted and talented students. It means less opportunity for differentiated instruction to meet students’ learning needs. Again, the districts with the tightest budgets will end up with the highest number of students in each classroom.
  • Eliminating the requirement for certified art, music and physical education teachers in elementary school means that in districts with tight budgets, those positions will be cut. Studies have shown that art and music are not only beneficial to building students’ memory, visual skills and imagination, but also improve math skills. Physical Education is important for developing healthy life habits as well as learning fair play and sportsmanship. Yet in chronically underfunded districts, the choice might become whether to have the regular classroom teacher add art, music and physical education to everything else she teaches, without the wealth of knowledge to teach those subjects,  or use a series of videos.
  • Relaxing the requirement to have a school nurse and replacing it with having a staff person trained in first aid could have life threatening consequences. With all of the students requiring prescriptions administered while at school, all the playground accidents, as well as the fevers, stomach bugs and other issues that schools deal with every day while students are in their care, a nurse is not a luxury and should not be removed from the minimum standards.

These are just a few examples of changes under this draft of the proposed Minimum Standards for Public School Approval. Lowering or eliminating these standards would increase the disparities between school districts, which is against the NH Constitution’s guarantee of  the opportunity for an equally robust public education to every Granite State child through their local school district and would just invite even more lawsuits. Every Granite State child deserves a full range of academic, arts and career and technical education courses. They deserve small class sizes, academic, behavioral, and emotional support services and hands-on and experiential learning opportunities that will help them become productive members of society. The Minimum Standards for Public School Approval are the place through regulations that ensure every public school student gets at least that constitutionally guaranteed equal opportunity for a public school education through their local school district whether they live in Berlin or Bedford. Don’t adopt minimum standards that will get in the way of students receiving their constitutionally guaranteed right for an opportunity of a robust public education.


Debrah Howes

President, AFT-New Hampshire



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