Education commissioner speaks publicly about minimum standards revision, but faces skepticism

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MANCHESTER, NH – After an hour-long public conversation with the commissioner of the NH Department of Education, school board members in Manchester – the state’s largest school district–  remained frustrated by a lack of clear answers and unconvinced that proposed revisions to the state’s minimum standards for public schools, known as the 306s, will improve education in the Granite state. 

Despite that, the state Board of Education plans to finalize the revisions as soon as next month. 

“It’s problematic that [the commissioner] often said that the revisions raised the bar on education, and yet the feedback from hundreds of constituents all agree that in fact it lowers the bar,” said Sean Parr, a member of the Manchester Board of School Committee. “That’s a real problem, when there’s this big disconnect between that claim and what is actually in the revisions.”

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The 306s are undergoing a once-in-a-decade update, a process that educators say has lacked transparency and resulted in a document that could weaken public education in the state. The Manchester school board echoed those points in a March letter announcing its opposition to the current draft of the revisions. The board invited Edelblut to Monday’s meeting to respond. 

“It’s important to acknowledge we’re not the only ones who are concerned about these rule changes,” Parr said at the Monday meeting. “Hundreds and hundreds of citizens have expressed the same concerns.”

After more than an hour of questions, James O’Connell, vice chair of the school committee, said he remains “distrustful of the process,” and asked the commissioner to express his commitment to the state’s public education system. 

“In the end, we want a great public education system, and Mr. Edelblut… you’re not always viewed as the greatest champion of public education,” O’Connell said.

In reply, Edelblut demurred. 

“I am a champion of children,” he said. 

Commissioner of the New Hampshire Department of Education Frank Edelblut. File Photo/Carol Robidoux

Downplaying concerns

Throughout the session, Edelblut seemed to downplay concerns, saying, “This is just one of those processes that can be noisy.” 

He said that some worries expressed in public comments were “not germane” to the discussion of the revisions. He also dismissed concerns outlined by Reaching Higher NH, a nonpartisan nonprofit dedicated to education in the Granite State, as “generalities” that weren’t “actionable.” 

Most concerning to Parr, he said, was that “there was no guarantee from [Edelblut] that the public would see the final draft before it was submitted” for formal approval and implementation. 

The state board released a draft document on Feb. 18, and has since held public comment sessions, but has not made a revised document public. Despite that, lawyers with the Office of Legislative Services are already reviewing a draft of the document to ensure it complies with the law. 

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“Process-wise, what actually might be revised at this point, because we’re all concerned about a lot of the changes there?” Parr asked at the meeting. 

The commissioner deflected.

“The bottom line is we did not get answers to our questions,” Parr said after the meeting. 

In a follow-up email, a spokesperson for the Department of Education declined to say when the public can expect to see a final draft or public feedback that was collected, but added that the Board of Education “will adopt a final proposal maybe in June or July.”

Class size requirements, equity and funding

One of the prominent concerns during Monday’s meeting was over the removal of specific class size limits. Edelblut argued that the new wording specifies that class size limits should be set locally, based on students’ needs and other factors. 

“We’re trying to say, ‘Let’s make thoughtful decisions about this,’” Edelblut said. 

Committee members pushed back, saying that with no maximum class sizes outlined at the state level, local factions on school boards could choose to increase class sizes drastically. 

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“I am concerned that there could be another instance of a small ideological faction coming into authority in one district and significantly underfunding or changing policies and standards …” said Board of School Committee member Chris Potter. “In cases like that, do you think that these are truly adequate for our students?”

Potter added that he was particularly thinking about the town Croydon, which slashed its school budget by half in 2022, a move that was later reversed after community members advocated for a revote. 

Committee member Liz O’Neil asked how the state could evaluate class sizes “with fidelity” when no maximum size is included in the standards. Edelblut replied that districts would need to prove to the board of education that their class size decisions have “a logic model behind it.”

Edelblut also addressed concerns over equity and the adjustment of some language in the document. Around equity, he said that the draft of the 306s aims to close achievement gaps without wading “into the identity politics” by listing marginalized populations. 

“If I’ve got LQBTQ+ students who are struggling, I need to help them, but if I have LGBTQ+ students who are not struggling, that are succeeding, then I don’t need to group them together … ” he said. “The grouping needs to be focused around the students who are behind, not the students based on their other identity that they may have.”

Yet, to address concerns, the board is considering changing the definition of equity to include “individuals or groupings of individuals based on their identified needs,” Edelblut said. 

Finally, Edelblut clarified the decision to switch the term “certified educator” to “licensed educator” in the document, which he said was done to keep the language in line with state statutes. 

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“People saw the word certified crossed out and maybe missed the fact that we had inserted licensure and maybe thought we had eliminated it, which is not the case,” he said. 

Committee members expressed concerns about language being shifted from “shall” to “may” –  changes that “open the door to suggest ‘may not,’” said committee member Julie Turner. If subjects including arts, physical education, social studies and electives are optional, the state may not be required to fund them as part of an adequate education, the subject of ongoing lawsuits in the state, committee members said. 

Edelblut replied that the formula for calculating an adequate education is outlined in statute, not in the minimum standards, but that answer did not satisfy the committee. 

“The funding concerns were not assuaged,” Parr said. 

In order for the 306 revisions to formally be adopted, they must be approved by the Joint Legislative Committee on Administrative Rules (JLCAR) after a final draft is submitted by the Board of Education. The JLCAR committee “has limited influence,” Parr said, but can reject rules for four precise reasons, including if the rules are not in the public’s best interest. 

“I think it’s really important, because what’s been established by the comments … is that the revisions are not in the public’s best interest,” he added.

GSNC 2 ColorThese articles are being shared by partners in the Granite State News Collaborative. For more information, visit

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About this Author

Kelly Burch

Kelly Burch is a New Hampshire-based freelance journalist whose work has appeared in The Washington PostThe Independent, Oprah magazine and more. Kelly covers personal finance, mental health and other topics. She's currently working on a memoir about traveling the United States by RV with her husband and two young children.