At the outset of his remarks, Terence M. Zaleski (TMZ) noted the pressure that the Bureau was under in issuing suggested rule changes in a very short time frame. The recently enacted legislation contained a mandate directing the State Education Department to begin discussing proposed regulations with the schools within 30 days. Howard Goldsmith met this time schedule and is to be commended for his efforts, along with Dave Sherwood, and the other Bureau personnel who participated in this process.

TMZ stressed in his introductory remarks that he applauded the sentiment of Advisory Council Acting Chair Anthony Stanziani that the regulations as proposed were to be seen as a starting point for further discussions. Because of the mandated time pressure, the draft regulations were rapidly produced without the possibility of input from the schools. This meeting was the first opportunity for the schools to come together as a group to voice their feelings and concerns. It is important that their remarks and positions be considered and impact the regulations proposed. TMZ stressed that the Bureau must not have any particular pride in authorship for any provisions, but that everything should be open for discussion and consideration.

As Executive Director of the COALITION, TMZ indicated that he had heard from many schools of all sizes and types concerning the proposed regulations. Before presenting in detail the substance of their concerns and issues, he expressed some of the tangible feelings that had been expressed to him by school owners and directors during meetings and long telephone conferences.

TMZ noted that there was skepticism expressed about the motivations behind some changes and he suggested that the Bureau keep this in mind when presenting its positions. Some schools expressed their belief that increased fees for various licenses were back-door tax increases, designed merely to raise funds for the Bureau's operations as opposed to enhancing quality. Some schools expressed their belief that some of the proposals reflected an

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undercurrent of mistrust of school operations that was unwarranted. All the schools were concerned that the Bureau is not vested in the regulation changes as proposed, and that it be truly open to work with the schools in an ongoing processs of review, consideration and modification before they are ultimately adopted by the Regents.

TMZ raised several issues that COALITION member schools had shared with him.

The principal concerns are outlined below:

1. Documentation of Entrance Requirements. Section 5002 of the Education Law requires that students at our schools possess a high school diploma or equivalent, or demonstrate an ability to benefit. It does not specify the tangible proof necessary for documenting this requirement. The intent of the proposed rule is to open greater possibilities for acceptable documentation than presently exists under IPM-37. The proposed language may not sufficiently capture that intent and some revision would be appropriate.

2. Dismissal Requirement. All schools expressed great concern about the change from the present 80/20 % attendance standard to 85/15 % regardless of whether the student is maintaining satisfactory academic progress. Schools expressed their concern that this regulation would hurt students and reduce student options. It was also seen as an excessively paternalistic treatment of students that created an additional disincentive compared to education opportunities in community colleges or other settings.

3. Directors and Teachers Licenses. All schools expressed concerns about the replacement of permanent licenses with full licenses. There was great suspicion that this was a backdoor tax, as opposed to an attempt to improve quality. Much uncertainty was voiced about how administrative or instructional competence would be judged. It was felt that these concepts should be further defined. The amount of time required to submit the proposed license renewals is too long at 90 days. Also, it was noted that the state should be required to notify of renewals before they come due.

4. Eliminating Requirement to Provide Written Reasons for Denial of a New School

License. This proposal is unfair to schools seeking their first license. If a denial is issued, there should be a formal communication listing the reasons so the school may have a checklist to use in a subsequent application.

5. Definition of nationally recognized vendor. The definition should be broad enough so that it can apply in many curriculum categories, not just computer training programs. This will help speed the curriculum approval process, and assist the Bureau by reducing the burden of sending these curricula to experts and separately reviewing well-established and recognized curricula.

6. Quarters Evaluation Procedure. Many schools expressed their desire to modify regulations or procedures concerning quarters review so as to achieve greater uniformity in the review process.