NATIONAL

ASSOCIATION OF STATE BOARDS OF EDUCATION

1575 SHERMAN • SUITE 604 DENVER, COLORADO 80203 •

303/825-3573

Dr. Sidney Marland

Commissioner of Education
U. S. Office of Education
400 Maryland Avenue, S. W.
Washington, D. C. 20202

Dear Commissioner Marland:

Members of the National Association of State
Boards of Education continue to have serious concerns
regarding at least two aspects of the proposed Edu-
cation Revenue Sharing Act of 1971. They are con-
cerned that the proposals to date do not explicitly
designate state boards of education "or those bodies
legally responsible for public elementary and
secondary education" as the agencies for the receipt
and administration of any special revenue sharing
funds for education. They are not comfortable with
any wording allowing the possible appointment of some
new or competing agency. Secondly, they question the
efficacy of another advisory board. As you well know,

Tay boards of education were originally created to
guarantee that the people will continue to have juris-
diction over education matters. NASBE members are
confident that they are capable of exercising prudent
and temperate judgments in educational matters.

Enclosed is a copy of the resolution recently adopted at the Northeast Area Conference of NASBE. As you will note, its wording pertains directly to the two points mentioned in my letter.

I would appreciate receiving comments from you regarding these matters. I would very much like to keep my membership informed about how their views are received.

Very cordially,

Dartfor

David T. Tronsgard
Executive Secretary

DTT/blp

Cc:

House and Senate Education Committee members
Representative Wilbur Mills

Resolution Adopted at the Northeast Area Conference

of the

National Association of State Boards of Education
April 27, 1971

The Northeast Area Conference of the National Association of State Boards of Education comprised of the States of Maine, Vermont, New Hampshire, Massachusetts, Rhode Island, Connecticut, New York, Pennsylvania, New Jersey, Maryland, and Delaware examined fully the legislation entitled "Education Revenue Sharing Act of 1971", forwarded by the President to Congress under the date of April 6, 1971. Particular attention was paid to and detailed discussion was held about the language of those portions of the bill relating to the duties and powers of the governors and of the proposed advisory councils.

The Northeast Area Conference of the National Association of State Boards of Education unanimously moved and seconded:

"complete endorsement of the concept of revenue sharing
in a form which will result in more adequate financial
support for education; and

that all funds from the federal government for the sup-
port of elementary and secondary education be admin-
istered by the legally constituted state education
agency."

Concern was also expressed regarding the lack of provision for maintenance of state financial efforts for public educational programs.

This will summarize the Nevada State Department of Education's point
of view with reference to proposed actions regarding grant consolida-
tion legislation and "special educational revenue sharing".

At a meeting in Miami Beach, Florida, the Honorable Elliot L.
Richardson made a presentation to all chief state school officers
which was very much appreciated because of its candor and the strong
references he made to the key roles of state education agencies.
Subsequent regional meetings conducted by the U. S. Office of Education
have disclosed more of the thinking behind "special educational
revenue sharing", and I have become somewhat concerned regarding the
directions toward which enabling legislation appears to be headed.
Let me therefore reiterate special elements of concern in the whole
matter of grant consolidation and "special educational revenue sharing".

1. The term "special educational revenue sharing" is ill-defined
and misleading.

2. The proposed legislation seeks to circumvent legally constituted authority and responsibility for education, namely the state boards of education and state education agencies.

3. The proposed legislation could conceivably fragment and
disorganize educational efforts.

4. It proposes no new assistance.

still an apple.

An apple by another name is

5. The "no loss" provision will not protect allocations for
Nevada in future years, as long as these are to be based on
populations alone.

6. The incentive proposals will provide less money for states
less able to increase tax revenues.

In previous years I have indicated to you that the Nevada State Depart-
ment of Education favors consolidation of aid programs with similar
characteristics and purposes. This would permit consolidation of
administration at the state level and most likely reduce recording
and reporting requirements. The proposed legislation does not provide
for reasonable or judicious consolidation.

The Honorable Alan Bible

2.

The appended paper presents the rationale for the position of the
Department in this matter.

I feel that all of us in the various states should be provided with preliminary legislative specifications issued prior to meetings and regional conferences so that each of us would thereby have an opportunity to review and comment upon those specifications before the legislation is finally submitted.

I very much appreciate all of your past efforts on behalf of education and also this opportunity to present the preceding position statement for this department.

BL:ms

Enc.

Sincerely,

Burnell Larson,
Superintendent of

Public Instruction

REVENUE SHARING

and the

PROPOSED SPECIAL EDUCATIONAL

REVENUE SHARING ACT

Consolidation vs. Revenue Sharing

The Special Educational Revenue Sharing Act proposed by the U. S. Office of Education at regional meetings held the week of March 8-12, 1971 does not represent the concept of revenue sharing. The proposed Act provides for the consolidation of several federal grant-in-aid programs and the title of the act should be changed to more accurately reflect its purpose.

The distinction between program consolidation and revenue sharing is extremely important to those concerned about the need for additional fiscal resources for public education. The distinction is equally important as an indication of the philosophy and intent of the President and the Congress in setting National priorities for education.

The Concept of Consolidation Is Not New

The purpose of program consolidation is to simplify and otherwise improve the administration of categorical grant-in-aid programs designed to solve educational problems of national significance. Categorical legislation recognizes that new problems do evolve in a rapidly changing, complex society and that these new problems demand additional (supplementary) fiscal resources if they are to be solved. The concept of pro