| Educators’ Letter to NYS Ed Dept |
| With the deadline fast approaching, we respectfully request your urgent attention to the message below, as well as any assistance you might be willing to provide in passing this message on to colleagues. We also extend our sincere appreciation to the 140+ educators who have added their signatures to this letter since its posting on Friday afternoon. ————————————- As you have certainly heard by now, the New York State Education Department is currently considering new regulations that would significantly extend the powers of the local public school system over nonpublic schools in general and yeshivos in particular. In compliance with state law, the Department is currently holding a 60-day public comment period, ending May 31. (For more information about these proposed regulations or to submit personal comments in opposition, please visit voice.agudah.org.) In cooperation with Agudath Israel of America and Torah Umesorah, we are asking education professionals of all kinds who possess recognized credentials (degrees, licenses, or certifications) to join in signing the letter copied below. Yeshiva-educated teachers, special ed providers, speech teachers, general studies principals, curriculum coordinators, school psychologists, guidance counselors, therapists working in an educational setting, college professors, administrators, or any other credentialed educators are invited to join by adding their names and credentials at the following site: https://agudah.org/substantial-equivalency-opposition-comment-by-educators/ As the public period is ending in just a few days, we request your urgent assistance in passing along this message to colleagues and friends who may share these convictions and wish to sign this letter. Your participation and assistance are greatly appreciated. Sincerely, Educators Letter organizers ————————————- May 17, 2022 Ms. Christina Coughlin89 Washington Ave., EBA Room 1078SORIS, SE Regulation Comments Albany, NY 12234 [email protected] Educators Oppose the Proposed Addition of Part 130 to Title 8 NYCRR (Rule ID# EDU-13-22-00025-P) to Strictly Regulate Private Schools Dear Ms. Coughlin and Honorable Members of the Board of Regents: We, the undersigned, are professional educators. We serve in a variety of settings as teachers, principals, curriculum specialists, consultants, special education specialists, school psychologists, and guidance counselors. Our ranks include lecturers and professors at the undergraduate, graduate, and post-graduate levels. Our qualifications include master’s or doctoral degrees in education or other fields, and state teacher’s licenses or comparable credentials. We are also all proud graduates of yeshivas — Jewish elementary and high schools that maintain distinctive academic programs incorporating both Judaic and general elements. The overlap of our personal and professional experiences uniquely qualifies us to comment upon the proposed rules and methods for determining instructional equivalency. In our view, the assessment rubric contained in the present proposal is an inadequate measure of the value of yeshiva education as compared to public-school instruction. By arbitrarily excluding content taught in a language other than English, the rubric virtually guarantees results of extremely limited validity when applied to schools where significant educational content is conveyed through readings in other languages. Even if implemented in full good-faith, the proposed assessment rules fails to meaningfully consider the beliefs and purposes that inform our schools’ educational philosophies, omitting any metrics or mechanisms that might accurately capture the advanced intellectual, interpersonal and self-regulation skills whose acquisition lies at the heart of yeshivas’ unique educational model. And good faith is not guaranteed: the assessment process can be triggered by frivolous or even malicious complaints, and the proposal lacks robust mechanisms for assuring the impartiality or cultural competency of the personnel conducting these high-stakes audits. Our role as educators has also shown us, in our own considerable collective experience, that yeshiva students and graduates thrive. They are consistently among the most intellectually curious, studious, and respectful students we have taught. We urge you not to interfere with a system that has produced such laudable results. The targeted nature of these regulations is of particular concern at a time when public education is undergoing a major reckoning. Schools and education officials are working seriously to develop culturally responsive teaching and assessment tools for students hailing from minority ethnicities and nationalities. In this context, we find the present proposal’s failure to ascribe academic value to Judaic studies inconceivable. Our society is at present grappling with the legacy of its past sins; it is shocking that the recapitulation of some of these — forcible acculturation of minority children and disadvantaging traditional language and methods of instructions — is being contemplated in the Empire State once again. These draft regulations, intended to provide guidance to State and district personnel evaluating nonpublic-school instruction, in fact appear to describe a backdoor school licensure regime. They provide very little specification of the guardrails and limitations to which these personnel are subject, and very little to assist in the thorny but critical problems surrounding meaningful cross-cultural school evaluation. Explicit guidance on the civil rights guaranteed to individuals and families, or detailed best practices to ensure ensuring valid and ethical cross-cultural evaluation, are almost entirely absent; any future version of this guidance must focus on its intended purpose of regulating the conduct of State and district personnel, over whom it has clear and direct authority, instead of families and nonpublic schools, over whom it does not. The instruction that we received enabled us to successfully pursue higher education at the undergraduate, graduate, and — in some cases — doctoral levels. In our own experience, instruction in generalized academic studies was provided at a high level by the schools we attended. More critically: the Judaic studies that form the core of yeshiva education are neither sinister nor a mere distraction from education, as implied by the proposed assessment rubric. On the contrary, we believe that instruction in the rich and challenging texts of the Judaic literature constitutes a unique and irreplaceable educational and developmental experience. Together with the moral framework and inspiration they imbue, the skills obtained through Judaic studies — close reading of texts, literary analysis, logical reasoning, business law, history, and civics, to name a few — have directly contributed to our own subsequent academic, professional, and personal success. We fail to understand this Department’s years’-long, single-minded focus on reforming yeshiva education. History documents that yeshivas have been part of the educational and social fabric of New York life for well over a century. The first one, Etz Chaim Talmudical Academy, was organized in 1886 at 85 Henry Street on the Lower East Side of Manhattan by refugees fleeing anti-Jewish riots in the Russian Empire in the wake of Czar Alexander’s assassination. Judaic education has flourished and developed between that time and the present day. We urge you to reject the present proposal. The interests of children are best protected by loving parents and educators who know and care for them and understand their individual needs. The intervention of the State is harmful, except in genuinely exigent circumstances, and in a manner free from prejudice and cultural bias. We call upon this Department to initiate study of legislative proposals that could provide help and remediation to underperforming nonpublic schools, as is done for failing public schools, in lieu of the punitive measures and the threat of jail for their parent body contained in the present proposal. We ask you to respect our language, literature, and intellectual tradition, and look forward to collaborating with you in furthering the education of our communities’ children. Sincerely yours, cc: The Honorable Members of the Board of Regents |
