First, some background

The process to adopt new academic standards in Kentucky’s schools is somewhat involved.

After the Kentucky Department of Education develops a proposal (or, in the case of Next Generation Science Standards, grabs proposed standards from somewhere else), the Kentucky Board of Education must vote to approve a regulation adopting the new standards twice in two separate meetings. Then, the standards incorporating regulation is put out for a public comment period. If comments are received, the Kentucky Board of Education must then approve a “Statement of Consideration” of those public comments, deciding if more work is needed on the standards or if they are ready for a final review. That final review involves hearings and a vote on the regulation in two separate committees of the Kentucky Legislature.

The administrative regulation to adopt the highly controversial Next Generation Science Standards (704 KAR 3:303) is going through this process right now. The Board of Education completed its steps. Although it received thousands of comments, the board elected not to make a single change in the NextGen Science Standards, voting in early August to approve a very disappointing “Statement of Consideration” of those comments. In the process, the board thumbed their noses at those members of the public who pointed out a number of areas where NextGen Science isn’t ready for prime time in Kentucky.

So, the action now shifts to the Kentucky Legislature.

The first hearing on NextGen Science takes place on September 11, 2013 at 1 PM in Room 154 of the Capitol Annex in Frankfort. Very likely, NextGen is going to face a considerably more intense examination than the perfunctory consideration it got from the Kentucky Board of Education.

Legislators may also be concerned about the board’s not very interested handling of the public’s comments. It seemed like the board was ready to jump on any excuse to avoid having to think more carefully about the science standards. You can draw your own conclusions about the board’s attitude by watching the video of the meeting, on line here (Note: This is in a new HiDef video format and may require an advanced viewer like the VLC Media Player).

The board's discussion on 704 KAR 3:303 starts at 1 hour and 4 minutes into the webcast. Note in particular that the questions were prematurely cut off when the governor arrived to celebrate the new Age 18 dropout legislation. Although there was a promise to return to questions, that never happened, and the vote was taken without a continuation of the questions.

The board should have asked more questions. In the end, some of the board’s approved Statement of Consideration’s excuses simply don’t stand up to reasonable examination. To learn more about that, click the “Read more” link.

Let’s examine some of the poor excuses found in the Board’s Statement of Consideration for 704 KAR 3:303.First of all, there seem to be plenty of problems with the Next Generation Science Standards. The most extensive analysis of the NextGen Science to date, “Final Evaluation of the Next Generation Science Standards,” was released by the Thomas B. Fordham Institute on June 13, 2013. To put it succinctly, Fordham is not impressed.

Overall, Fordham gave the new standards a mediocre “C” score, not much better than the “D” Fordham gave Kentucky’s old science standards. Fordham made a point that many states already have much better science standards than NextGen offers. Fordham digs deep in their 67-page report, discussing numerous specific deficiencies in NextGen Science.

Even if you only agree in part with Fordham, NextGen Science needs lots more work. Thus, it was no surprise that Fordham was cited by a number of submissions during the public comment period on 704 KAR 3:303.That created a problem for the department and the board because the Kentucky Department of Education and the board made it clear they didn’t want to make any changes to NextGen Science. Thus, in order to sidestep Fordham’s issues, the Kentucky Department of Education decided to attack the Fordham’s study. The department did that in a particularly inept way.

On Page 118 of the Statement of Consideration, the department argues that because Fordham’s 2012 grades for state science standards don’t agree well with the various states’ most recent performance on the 2011 National Assessment of Educational Progress Grade 8 Science Assessment, the department is justified in concluding that “Fordham’s report does not accurately evaluate the Next Generation Science Standards.”

But, hold on!

There is a huge problem with the department’s faulty line of reasoning. And, this is a classic, Statistics 101 error. That error is assuming that just because Fordham’s grades for state science standards don’t correlate well to the National Assessment of Educational Progress (NAEP) scores, that this is conclusive evidence that Fordham’s grades for science standards are invalid.

Any freshman statistics student should laugh at such nonsense.

Stat 101 students learn a fundamental truth: correlation between two sets of data cannot establish a causational relationship. The truth is, a state could have great science standards, but the people writing the curriculum could mess up. Or, both the standards and the curriculum might be superior, but classroom instruction could fall down.

On the other hand, good classroom teachers can save their students from both bad standards and bad curriculum.

In any of these cases, the quality of the standards will have no relationship to test scores.

To reiterate, the Kentucky Board of Education’s Statement of Consideration for 704 KAR 3:303 trips over some very basic, Statistics 101 “stuff.”

I find it disturbing that such correlational nonsense wound up in the Statement of Consideration for a regulation that will have very important consequences for every public school student in Kentucky and could put the state at a serious economic disadvantage in the future.

Furthermore, this logically flawed argument does not provide evidence that Fordham and the critics of 704 KAR 3:303 are wrong. That makes the department’s defense of NextGen Science found around Page 118 in the Statement of Consideration invalid, as well.

Thus, the Statement of Consideration for 704 KAR 3:303 fails to address very real concerns from the public regarding Fordham’s rather thorough, and rather unfavorable, analysis of NextGen Science Standards. Because the public’s comments did not receive fair consideration, this regulation needs to be sent back to the Kentucky Board of Education for more work.