Ms. Angelica Infante-Greene 
Deputy Commissioner for Instructional Support
NYS Department of Education
89 Washington Avenue, 2M West
Albany, NY 12234
August 22, 2016
Re:  Public Comment on Emergency Action to Amend Section 100.5 Regulations – New Local Diploma Pathway for Students with Disabilities
Dear Ms. Infante-Greene,
On behalf of NYS Allies for Public Education, I would like to commend the Board of Regents for offering this new pathway for students with disabilities.  It is imperative that the Board of Regents and NYSED hold public hearings around the state to hear the public concerns regarding New York State’s current high-stakes Regents’ exam graduation requirement system.  Over sixty percent of states across the nation do not require any exit exams to graduation while still maintaining the integrity of a graduation diploma.  
Opportunities to show mastery of skills other than a standardized test such as New York Performance Standards Consortium which offers authentic project based learning have been a successful model for student success and improving students’ ability to succeed in college or a career after high school.  These schools only require one Regents exam in English Language Arts and all other topics have presentations in literature, science, mathematics, and social studies, developed over time in order for the student to cultivate and then demonstrate mastery of a subject. It is vital that the Board of Regents reopen the application process for the consortium schools and allow all high schools to apply to be a public consortium school using authentic project based assessments.
We would welcome the opportunity to assist in coordinating these hearings.
The following are recommendations to modify the emergency regulation for determination of a local diploma for students with disabilities: 
  • Require the Committee on Special Education (CSE) to meet with all committee members and make a recommendation to the superintendent which the superintendent must consider when making a determination.
  • Permit the parent and student to decline a local diploma based on a superintendent determination and remain in school to earn a Regents or local diploma through other pathways or a CDOS skills credential in addition to diploma.
  • Permit the parent and student to refuse the local diploma based on superintendent’s determination and remain in school to continue to receive education and special education transition services.
  • Permit the parent and student to defer the award of a local diploma until the student reaches the age of 21 and is no longer eligible for special education services 
  • Make ALL pathways to a local diploma available to all students, regardless of disability. 
Thank you and we can be reached at 917.414.9190 or
Sincerely yours,
Lisa Rudley

Executive Director, NYSAPE
c: The NYS Board of Regents
    Commissioner MaryEllen Elia
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