BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 343
                                                                  Page  1

          Date of Hearing:   April 22, 2009

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Julia Brownley, Chair
                    AB 343 (Saldana) - As Amended:  April 14, 2009
          
          [This bill is double referred to the Assembly Judiciary  
          Committee and will be heard as it relates to the issues under  
          its jurisdiction]
           
          SUBJECT  : Pupils: military families

           SUMMARY : Enacts the Interstate Compact on Educational  
          Opportunity for Military Children (the Compact).  Specifically,  
           this bill  :

          1)States the intent and purpose of the Compact, and defines  
            terms specific to the Compact.

          2)Requires that the provisions of the Compact apply only to the  
            children of:

             a)   Active duty members of the uniformed services, including  
               members of the National Guard and reserve on active duty  
               orders.

             b)   Members or veterans of the uniformed services who are  
               severely injured and medically discharged or retired for a  
               period of one year after medical discharge or retirement.

             c)   Members of the uniformed services who die on active duty  
               or as a result of injuries sustained on active duty for a  
               period of one year after death.

          3)Requires that the provisions of the Compact apply to local  
            education agencies (LEAs).

          4)Requires sending schools, the school in the state from which  
            an eligible pupil is sent or brought, to furnish: 

             a)   Unofficial records, to the extent feasible, to parents  
               to give to receiving schools until official records can be  
               released.

             b)   Official records, to the extent practicable, within ten  








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               days of a request from a receiving school.

          5)Requires receiving schools, the school in the state to which  
            an eligible pupil is sent or brought, to:

             a)   Place eligible pupils on the basis of unofficial records  
               until the official records are obtained.

             b)   Request official records of an eligible pupil from the  
               sending school immediately upon enrollment of the pupil.

             c)   Allow 30 days for transferring students to obtain  
               necessary immunizations or to begin a required series of  
               immunizations.

             d)   Allow transferring students to continue their enrollment  
               at their grade level in the sending state, regardless of  
               age.

             e)   Allow a pupil who has completed a grade level at the  
               sending school to enroll in the next highest grade level at  
               the receiving school.

             f)   Accept and honor course. If such courses are offered and  
               space is available, and program placements made at the  
               sending school, including courses such as Honors, Advanced  
               Placement, International Baccalaureate, vocational,  
               technical and career pathways courses, and programs such as  
               gifted and talented, and English as a Second Language.

             g)   Initially provide comparable services to transferring  
               students with disabilities and make reasonable  
               accommodations and modifications to address the needs of  
               incoming students with disabilities.

             h)   Accept special power of attorney, relative to the  
               guardianship of a child of a military family and executed  
               under applicable law as sufficient for the purposes of  
               enrollment and all other actions requiring parental  
               participation and consent.

             i)   Grant extra excused absences for any student whose  
               parent has been called to duty for, is on leave from or has  
               immediately returned from deployment to a combat zone or  
               combat support posting, at the discretion of the  








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               superintendent of the LEA.

             j)   Accept exit or end-of-course examinations for graduation  
               from the sending state, but requires passage of  
               California's high school exit examination in order to  
               receive a diploma issued by a California high school.

          6)Requires state and local education agencies to facilitate the  
            opportunity for transitioning military children's inclusion in  
            extracurricular activities, regardless of application or  
            tryout deadlines, to the extent they are otherwise qualified  
            and space is available as determined by the school district.

          7)Allows receiving schools to perform subsequent evaluations to  
            ensure appropriate placement.

          8)Prohibits a LEA from charging local tuition to a transferring  
            student in the care of a non-custodial parent or other person  
            acting as the parent who lives in a jurisdiction other than  
            that of the custodial parent.

          9)Allows a transferring student, who is placed in the care of a  
            non-custodial parent or other person acting as the parent who  
            lives in a jurisdiction other than that of the custodial  
            parent, to continue to attend the same school they previously  
            attended.

          10)Requires LEA administrative officials to use best efforts to  
            waive courses required for graduation if a transferring  
            student has completed similar coursework.  If a waiver is not  
            granted, the LEA is required to provide an alternative means  
            of acquiring required coursework in time to allow for an  
            on-time graduation.

          11)Allows LEA administrative officials to waive pre-requisite  
            courses or other pre-conditions for course placement of  
            eligible pupils. 

          12)Allows a student to receive a diploma from the sending school  
            should that student meet the requirements for graduation at  
            the sending school, but not at the receiving school; also  
            requires both sending and receiving LEAs to make best efforts  
            to ensure this.

          13)Requires a member state to facilitate the pupil's receipt of  








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            the sending school diploma in time for on-time graduation if  
            the sending state has not adopted this Compact.

          14)Requires each member state to create a state council to  
            provide for the coordination among its agencies of government,  
            local education agencies and military installations, and  
            specifies the membership of that state council.

          15)Requires the state council to appoint a military family  
            education liaison to assist military families and the state.

          16)Creates a compact commissioner, appointed by the governor or  
            as otherwise determined by each member state, responsible for  
            the administration and management of the state's participation  
            in the Compact.

          17)Requires that the military family education liaison and the  
            compact commissioner be ex-officio, if not voting, members of  
            the State Council.

          18)Requires that the Compact is dissolved when there is only one  
            member state.

          19)States that the compact does not prevent the enforcement of  
            any other law of a member state.  However, all other member  
            states' laws that conflict with the compact are superseded to  
            the extent of the conflict.

          20)Requires the executive, legislative and judicial branches of  
            the member states to enforce the Compact and take all  
            necessary actions to carry out the rules promulgated as a  
            result of the Compact.

          21)Creates the Interstate Commission on Educational Opportunity  
            for Military Children (the Commission) and specifies its  
            duties and powers.

          22)Requires the Commission to:

             a)   Consist of one representative from each member state,  
               that representative being a state's compact commissioner,  
               who is entitled to one vote on the Commission.

             b)   Adopt bylaws to govern its conduct to carry out the  
               purposes of the compact including electing by a majority  








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               vote a chairperson, a vice-chairperson and a treasurer and  
               specifies their duties.

             c)   Meet at least once during each calendar year, and  
               provide for open meetings and records.

             d)    Resolve disputes between member states and nonmember  
               states at the request of a member state. 

             e)   Pay, or provide for the payment of, the reasonable  
               expense of its establishment, organization and ongoing  
               activities. 

             f)   Keep accurate accounts of all receipts and disbursements  
               to be audited yearly by a certified or license public  
               accountant. 

             g)   Create the Executive Committee of the Commission with  
               specific duties and authority.

             h)   Collect data related to the transition of military  
               families under this Compact.

             i)   Establish a process for the reporting of violations of  
               the provisions of this Compact.

             j)   Enforce the provisions and rules of the Compact.

          23)Grants the Commission's executive director, employees, and  
            Commission representatives immunity from suit and liability  
            relating to the performance of their Commission duties.

          24)Specifies the rule making authority and process of the  
            Commission.

          25)Requires the Commission to promulgate rules to bring about  
            the goals of the Compact, and establishes that these rules  
            have the force of law over all member states unless overturned  
            by legislation approved individually by a majority of member  
            states. 

          26)Outlines the process the Commission must follow if it  
            determines a member state has defaulted in the performance of  
            its obligations and responsibilities under the Compact,  
            including, but not limited, to the use of judicial process.








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          27)Allows the Commission to levy and collect an annual  
            assessment from each member state to cover the cost of the  
            operations and activities of the Commission, but authorizes  
            the Superintendent of Public Instruction (SPI) to accept  
            nonstate funding to offset these costs.

          28)Prohibits the Commission from incurring obligations of any  
            kind prior to securing the funds adequate to meet the same.   
            The Commission cannot pledge the credit of member states  
            without the member states' permission.

          29)Allows the Commission to propose amendments to the compact  
            for enactment by unanimous consent of the member states.

          30)Allows member states to withdraw from the compact by  
            repealing the statute and specifies the withdrawal process.

          31)Contains a severability clause, requiring the remaining  
            provisions of the Compact to be enforceable, if any other  
            provision is deemed unenforceable.

          32)Establishes an immediate effective date once 10 states have  
            enacted the Compact.

          33)Authorizes the SPI to develop procedures for training LEA  
            employees on the implementation of the Compact.

           EXISTING LAW  :

          1)Provides the Education Code that places requirements on  
            pupils, their families, local education agencies and the state  
            related to the provision of education in the state of  
            California, including as it relates to issues of enrollment,  
            attendance, pupil records, graduation requirements, and  
            transfer between school districts.

          2)Allows, through permissive authority granted in the Education  
            Code, for the governing board of any school district to  
            initiate and carry on any program, activity, or otherwise act  
            in any manner which is not in conflict with or inconsistent  
            with, or preempted by, any law and which is not in conflict  
            with the purposes for which school districts are established.

          3)Requires, in the state Constitution, that the state reimburse  








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            local agencies and school districts for certain costs mandated  
            by the state.

           FISCAL EFFECT  : Unknown costs related to potential reimbursable  
          state-mandated local programs, and to the appointment and  
          maintenance of the State Council, the military family liaison  
          and the state compact commissioner.  Unknown costs related to  
          the annual assessments levied on the member states to be  
          determined by the Interstate Commission.

           COMMENTS  :   Interstate compacts are contracts between two or  
          more states creating agreements on how to address particular  
          policy issues, setting standards, or establishing cooperation on  
          regional or national matters; by their nature compacts deal with  
          public policy matters that extend beyond the boundaries of one  
          state.  Most states are a party to a number of interstate  
          compacts.  Most of these address corrections issues, such as  
          offender supervision and treatment of juveniles, natural  
          resource management, multi-state taxation, transportation, or  
          professional accreditation.

          Frequently, these agreements create a new governmental agency  
          which is responsible for administering or improving some shared  
          resource such as a seaport or public transportation  
          infrastructure.  Examples of agencies created by compacts in  
          which California is a participant are the Tahoe Regional  
          Planning Agency , the Pacific States Marine Fisheries  
          Commission, and the Education Commission of the States.  In some  
          cases, a compact serves as a coordination mechanism between  
          independent authorities in the member states; an example of this  
          is the Colorado River Compact, that ws adopted by California.   
          Many of the earliest compacts, dating as far back as the late  
          1780s, were designed to settle boundary disputes.

          Interstate compacts are authorized under Article I, Section 10  
          of the United States Constitution, which states: 

               "No State shall, without the Consent of Congress, lay  
               any duty of Tonnage, keep Troops, or Ships of War in  
               time of Peace, enter into any Agreement or Compact  
               with another State, or with a foreign Power, or engage  
               in War, unless actually invaded, or in such imminent  
               Danger as will not admit of delay."

          Individual states are free to adopt or decline to adopt any  








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          compact; states ratifying compacts are bound to observe the  
          terms of the agreement until the compact is formally renounced  
          by the state. Compact provisions take precedence over  
          conflicting state laws and inconsistent provisions of existing  
          laws of a compact state.

          Military families move between postings on a regular basis, and  
          these reassignments can be required and/or advantageous for  
          career personnel, they often create educational disadvantages  
          for the children of military families. While the armed services  
          has taken steps to ease the transition of personnel, their  
          spouses and children, the realities of frequently moving subject  
          these children to divergent policies, rules, and procedures at  
          both the state and local level.  The intent of the Compact is to  
          ensure that the children of military families are afforded the  
          same opportunities for educational success as other children and  
          are not penalized or delayed in achieving their educational  
          goals by sometimes inflexible administrative and bureaucratic  
          practices as they move from state to state or within a state.

          The average military student faces transition challenges more  
          than twice during high school, and most military children will  
          have six to nine different school systems in their lives from  
          kindergarten to 12th grade. With more than half of all military  
          personnel supporting families, the impacts of reassignment and  
          long deployments are a key consideration when making life and  
          career choices.

          The Council of State Governments has worked with the U.S.  
          Department of Defense Office of Personnel and Readiness to draft  
          the Compact, addressing the educational transition issues of  
          children of military families.  A variety of federal, state and  
          local officials as well as national organizations representing  
          interested education groups and military families worked from  
          July 2006 through early 2008 to develop the Compact that the  
          Legislature is requested to adopt in this bill.  While the  
          Compact is not exhaustive in its coverage, it does address the  
          key issues encountered by military families: eligibility,  
          enrollment, placement and graduation. In addition, the Compact  
          provides for a detailed governance structure at both the state  
          and national levels with built-in enforcement and compliance  
          mechanisms.

          To date, the Compact has been enacted by 14 states, including  
          Arizona, Colorado, Connecticut, Delaware, Florida, Iowa, Kansas,  








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          Kentucky, Michigan, Mississippi, Missouri, North Carolina,  
          Oklahoma, and Virginia.  The Compact became operable, and thus  
          obligated those adopting states, once its language was adopted  
          by 10 states.  Bills proposing that the state enact the Compact  
          are currently pending in 16 additional states; this includes  
          California where this bill is that vehicle.  Four states,  
          including California, have chosen to create a task force  
          examining the issues related to enacting the Compact; California  
          and Washington have completed the task force process and have  
          bills pending in their respective legislatures, Illinois will be  
          introducing an enactment bill, and North Dakota is beginning the  
          task force process. Two additional states, New York and Ohio,  
          may be introducing bills in the near future.  In all 34 states  
          are engaged at some point in the process of enacting or  
          considering enactment of the Compact.  The U.S. Department of  
          Defense (DOD) expects 26 or 27 states to introduce bills for  
          Compact adoption in 2009. 

          According to the author, "There are about 60,000 school-age  
          military dependents between the ages of 5 and 18 years old in  
          California.  Unfortunately, military families encounter  
          significant school challenges when dealing with enrollment,  
          eligibility, placement, and graduation of their children.   
          Twenty-five percent of the students lose their course credits  
          due to multiple school transfers from out-of-state and  
          out-of-country DOD schools to California schools."  Based on  
          2008 counts, over 582,000 children of military families would be  
          covered by the provisions of this compact; slightly over 61,000  
          of those school-aged children reside in California.

          The author introduced a bill in the prior legislative session  
          that was substantially similar to this bill; AB 1809 (Saldana)  
          was held in the Assembly Appropriations Committee in 2008.  When  
          that bill was heard in the Assembly Education Committee, the  
          Committee staff recommended that the Committee consider an  
          alternative approach to immediate ratification of the Compact,  
          an approach that had been suggested in other states and that  
          would lead to the formation of a task force to comprehensively  
          examine the potential impacts and costs stemming from the  
          adoption of the Compact.  Given the potential impacts on  
          legislative authority and the fiscal impacts, particularly in a  
          year in which the state was facing a poor financial picture, the  
          proposed analyses that the task force would bring seemed to be a  
          prudent course.  The author later amended another bill, AB 2049  
          (Saldana), Chapter 589, Statutes of 2008, to require the SPI to  








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          convene and support a task force to review and make  
          recommendations regarding the Compact.

          The 15-member task force that was established by AB 2049  
          (Saldana) included individuals representing four legislators,  
          DOD, Navy Region Southwest, Marine Corps Installations West,  
          California Secretary of Education, Office of Planning and  
          Research, State Board of Education, one county office of  
          education, two school districts, one school board, and the SPI.   
          The task force met three times between November 2008 and  
          February 2009.  During the meetings, the task force heard  
          testimony from the military representatives about the  
          educational issues faced by military dependents and from school  
          representatives about issues faced by their organizations with  
          respect to student transfers, reviewed and discussed state and  
          federal laws that correspond to the Compact provisions,  
          discussed potential issues that may arise if the Compact were  
          adopted, and discussed other issues that arose during the task  
          force's deliberations.  The preliminary findings of the task  
          force are summarized in the two tables below taken from the  
          preliminary report of the task force.  The first table notes  
          issues of general concern that cut across numerous articles of  
          the Compact.  The second table addresses specific articles and  
          sections of the Compact, and provides a recommendation with  
          respect to that issue.

          
           ----------------------------------------------------------------- 
          |              Table I.  General Concerns Identified              |
           ----------------------------------------------------------------- 
          |---------------+-------------------------------------------------|
          |    Concern    |                                                 |
          |               |                 Review Finding                  |
          |               |                                                 |
          |---------------+-------------------------------------------------|
          |State          |                                                 |
          |Sovereignty    |The Compact does not "divest" local school       |
          |               |boards and school administrators of their        |
          |               |authority. A closer examination of the text of   |
          |               |the Compact, as has been conducted by the 11     |
          |               |states which have enacted it and many of those   |
          |               |states considering the legislation, will reveal  |
          |               |that the Compact provisions have been broadly    |
          |               |drafted with the intent to avoid conflict with   |
          |               |existing state education codes as far as         |








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          |               |possible. The Compact language in the four (4)   |
          |               |substantive areas in which uniformity is sought  |
                                                             |               |(enrollment, placement, eligibility, and         |
          |               |graduation) does not seek to abrogate state      |
          |               |control over education policy or procedure, but  |
          |               |only to impose a duty of reasonable              |
          |               |accommodation of the unique needs of children of |
          |               |military members in these four (4) areas.        |
          |               |                                                 |
          |---------------+-------------------------------------------------|
          |Application to |                                                 |
          |Only Military  |The experiences gained in administering this     |
          |Dependents     |Compact would be instrumental to creating a      |
          |               |later program applicable to other transfer       |
          |               |students, if the Legislature wished to do so.    |
          |               |                                                 |
          |---------------+-------------------------------------------------|
          |Data           |                                                 |
          |Requirements   |Data collection is the Interstate Commission's   |
          |               |responsibility (Article IX, I). The Interstate   |
          |               |Commission would need to obtain a unanimous vote |
          |               |from the member states to establish new data     |
          |               |collection requirements or to increase fees for  |
          |               |data collection. The first commission meeting    |
          |               |did not discuss and took no action on this       |
          |               |issue.                                           |
          |               |                                                 |
           ----------------------------------------------------------------- 

                            


           ----------------------------------------------------------------- 
          |              Table II.  Specific Issues Identified              |
           ----------------------------------------------------------------- 
          |-----------+--------------------------+--------------------------|
          |  Compact  |      Review Finding      |      Recommendation      |
          | Provision |                          |                          |
          |-----------+--------------------------+--------------------------|
          |           |                          |                          |
          |Article    |Current state law         |Make a non-material       |
          |IV,        |delegates to local school |amendment to Article IV,  |
          |Section A  |districts procedures for  |Section A, by adding the  |
          |           |the release of            |phrase "to the extent     |
          |           |educational records. EC   |feasible" after           |








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          |Unofficial |49069 and California Code |"Interstate Commission"   |
          |or         |of Regulations, Title 5,  |in the first sentence.    |
          |"hand-carri|Section 431 (c)(1)        |                          |
          |ed"        |specify that parents      |                          |
          |education  |currently have the right  |                          |
          |records.   |to review and copy        |                          |
          |           |student records within    |                          |
          |           |five days of their        |                          |
          |           |request. EC 49065 allows  |                          |
          |           |districts to charge       |                          |
          |           |parents for the cost of   |                          |
          |           |copying student records.  |                          |
          |           |This language seems to    |                          |
          |           |complement the language   |                          |
          |           |in the Compact, therefore |                          |
          |           |the Compact would not be  |                          |
          |           |creating a new mandate.   |                          |
          |           |Also note that EC 49069.5 |                          |
          |           |(d) requires that schools |                          |
          |           |provide records for       |                          |
          |           |transferring foster youth |                          |
          |           |within two business days, |                          |
          |           |supporting the precedent  |                          |
          |           |of districts providing    |                          |
          |           |records rapidly for       |                          |
          |           |certain students.         |                          |
          |           |                          |                          |
          |-----------+--------------------------+--------------------------|
          |           |                          |                          |
          |Article    |Current state law is      |Make a non-material       |
          |IV,        |similar but not identical |amendment to Article IV,  |
          |Section B  |to the Compact provision. |Section B, by adding the  |
          |           |The Compact requires that |phrase "to the extent     |
          |           |the school in the sending |practicable in each       |
          |Official   |state process and furnish |case."                    |
          |education  |the official education    |                          |
          |records/   |records to the school in  |                          |
          |transcripts|the receiving state       |                          |
          |.          |within ten days. However, |                          |
          |           |this timeframe could be   |                          |
          |           |changed by the Interstate |                          |
          |           |Commission.               |                          |
          |           |                          |                          |
          |-----------+--------------------------+--------------------------|
          |           |                          |                          |








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          |Article V, |Course placement is at    |Make a non-material       |
          |Section A  |local school district     |amendment to Article V,   |
          |           |decision.                 |Section A, by adding "and |
          |           |                          |there is space available, |
          |Course     |                          |as determined by the      |
          |placement  |                          |school district" at the   |
          |           |                          |end of the first          |
          |           |                          |sentence, after "if the   |
          |           |                          |courses are offered."     |
          |           |                          |                          |
          |-----------+--------------------------+--------------------------|
          |           |                          |                          |
          |Article V, |Program placement is at a |Make a non-material       |
          |Section B  |local school district     |amendment to Article V,   |
          |           |decision.                 |Section B, by adding      |
          |           |                          |"provided that the        |
          |Educational|                          |program exists in the     |
          | program   |                          |school and there is space |
          |placement  |                          |available, as determined  |
          |           |                          |by the school district"   |
          |           |                          |at the end of the first   |
          |           |                          |sentence, after "in like  |
          |           |                          |programs in the sending   |
          |           |                          |state."                   |
          |           |                          |                          |
          |-----------+--------------------------+--------------------------|
          |           |                          |                          |
          |Article    |The California            |Make a non-material       |
          |VI,        |Interscholastic           |amendment to Article VI,  |
          |Section B  |Federation (CIF) rules    |Section B, by adding "and |
          |           |pertaining to transfer    |space is available, as    |
          |           |students who want to      |determined by the school  |
          |Eligibility|participate in sports are |district" at the end of   |
          | for       |largely consistent with   |the sentence, after "to   |
          |extracurric|this Compact provision.   |the extent they are       |
          |ular       |However, the LEA          |otherwise qualified."     |
          |participati|application deadlines for |                          |
          |on         |sports or activities may  |                          |
          |           |be more restrictive than  |                          |
          |           |the Compact.              |                          |
          |           |                          |                          |
          |-----------+--------------------------+--------------------------|
          |           |                          |                          |
          |Article    |School districts do not   |Make a non-material       |
          |VII,       |have the authority to     |amendment to Article VII, |








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          |Section A  |waive state course        |Section A (2), by adding  |
          |           |requirements for          |"use best efforts to"     |
          |           |graduation. Districts do  |after "shall."            |
          |Graduation |have discretion to        |                          |
          |- Waiver   |analyze course content    |                          |
          |requirement|and determine if it meets |                          |
          |s          |graduation requirements.  |                          |
          |           |                          |                          |
          |-----------+--------------------------+--------------------------|
          |           |                          |                          |
          |Article    |California law requires   |Make a non-material       |
          |VII,       |passage of the California |amendment to Article VII, |
          |Section B  |High School Exit Exam     |Section B, by adding "    |
          |           |(CAHSEE) in order to      |(4) In California, the    |
          |           |graduate.                 |passage of the CAHSEE is  |
          |Exit exams |                          |required to graduate if   |
          |           |                          |the diploma is to be      |
          |           |                          |issued by a California    |
          |           |                          |public school, as long as |
          |           |                          |it is a requirement in    |
          |           |                          |California."              |
          |           |                          |                          |
          |-----------+--------------------------+--------------------------|
          |           |                          |                          |
          |Article    |School districts          |Make a non-material       |
          |VII,       |currently have discretion |amendment to Article VII, |
          |Section C  |regarding whether or not  |Section C, by adding      |
          |           |they work with the        |"make best effort to"     |
          |           |out-of-state district to  |between "shall" and       |
          |Transfers  |obtain a diploma from the |"ensure."                 |
          |during     |sending district and      |                          |
          |senior     |whether they work with    |                          |
          |year       |districts to which        |                          |
          |           |California students have  |                          |
          |           |transferred.              |                          |
          |           |                          |                          |
          |-----------+--------------------------+--------------------------|
          |           |                          |                          |
          |Article    |The Interstate Commission |At its first meeting, the |
          |XIV, B     |may levy on and collect   |Interstate Commission     |
          |           |an annual assessment from |established the state fee |
          |           |each member state to      |at $1 per military child  |
          |Financing  |cover the cost of the     |per year. In California,  |
          |of the     |operations and activities |there are currently 61,   |
          |Interstate |of the Interstate         |552 military children.    |








                                                                  AB 343
                                                                  Page  15

          |Commission |Commission and its staff  |                          |
          |           |which must be in a total  |                          |
          |           |amount sufficient to      |Should the state be       |
          |           |cover the Interstate      |unable  to appropriate    |
          |           |Commission's annual       |these funds, the task     |
          |           |budget as approved each   |force recommends that     |
          |           |year. The aggregate       |provision be made in      |
          |           |annual assessment amount  |legislation for the state |
          |           |shall be allocated based  |to accept outside funding |
          |           |upon a formula to be      |to offset the cost of the |
          |           |determined by the         |annual assessment and/or  |
          |           |Interstate Commission,    |delegate the authority to |
          |           |which shall promulgate a  |accept outside funding to |
          |           |rule binding upon all     |a local educational       |
          |           |member states.            |agency (LEA), with the    |
          |           |                          |agreement of the LEA.     |
          |           |                          |Such delegation would not |
          |           |                          |imply that the LEA        |
          |           |                          |accrues liability to meet |
          |           |                          |the annual assessment     |
          |           |                          |requirements or is        |
          |           |                          |required to use district  |
          |           |                          |funds to pay the fees.    |
          |           |                          |                          |
          |           |                          |                          |
           ----------------------------------------------------------------- 

          The task force has done a commendable job with its comprehensive  
          discussion of the Compact and of many of the issues raised by  
          Committee staff in its 2008 analysis of AB 1809 (Saldana).  The  
          task force has also made recommendations on many of those  
          issues, and all of those recommendations have been amended into  
          this bill.  However, the task force (as would have been the case  
          with any other group) was placed in the position of forecasting  
          the future impacts of a complex, comprehensive statutory  
          agreement and its interactions with state law.  Unfortunately,  
          forecasts do not always become reality, even for the ablest and  
          most diligent forecasters; for this reason, a number of concerns  
          must still be raised about the proposal in this bill:

          1)It remains unclear what the impact of the Compact and its  
            trumping of state law will be on the enforcement of statute  
            currently in the state's Education Code or on existing legal  
            obligations.  The breadth of the areas across which the  
            Compact provides mandates, as well as the unknown nature of  








                                                                  AB 343
                                                                  Page  16

            any rulemaking that follows enactment of the Compact, puts the  
            scope of this proposal beyond any other piece of legislation  
            in front of this Committee.  This raises a concern that too  
            little is known about that part of state law related to these  
            students' educations that will be set aside by this Compact  
            and any associated agreements coming out of the Interstate  
            Commission.

          2)This Compact may require the state to relinquish legislative  
            authority over some requirements in the Education Code that  
            have been relatively high legislative priorities, such as age  
            of entry, inter-district transfers, and graduation  
            requirements.

          3)States' experiences with other interstate Compacts indicate  
            that there will be unintended and unanticipated consequences  
            to the state from entering into this Compact.

          4)The Compact may create new programs or an expansion of  
            existing activities mandated by the state, and could thus  
            generate costs associated with the reimbursement of  
            state-mandated local costs as required by the California  
            Constitution.  Since this Compact does not stem from a federal  
            requirement and is enacted through state law, any costs  
            associated with these new or different activities would be  
            reimbursable.

          5)The Compact will generate direct costs to the state in an  
            unknown amount equal to the annual assessments levied on the  
            member states as determined by the Interstate Commission  
            (though the bill authorizes the SPI to accept nonstate funding  
            to offset these costs).  The Compact will also generate direct  
            costs to the state in an unknown amount related to the  
            appointment and maintenance of the State Council, the military  
            family liaison and the state Compact commissioner, and to the  
            activities and duties that each must perform.

          6)The Compact provisions do not apply to private schools.

          7)Every requirement or authorization in this bill, excluding the  
            governance and policing structure and requirements that bear  
            on other states, could be placed in California statute through  
            Legislative action and without encountering the issue of the  
            Legislature granting power to an outside Commission to  
            override California law.  








                                                                  AB 343
                                                                  Page  17


          The benefits that adoption of the Compact will provide to  
          school-age military dependents that are enrolled or will enroll  
          in California schools are clear and will accrue immediately; the  
          costs - fiscal, administrative, and programmatic - of adopting  
          the Compact are less clear, even though the task force has gone  
          far in providing additional review and information to the  
          Legislature, and will not become clear until after the Compact  
          has been adopted.  For this reason Committee staff recommends  
          that the Committee, if it passes this bill, consider returning  
          to the task force process at some point in the future as a  
          safeguard against unforeseen costs or impacts.  If that later  
          retrospective analysis points out substantive concerns to the  
          Legislature, then it could take action to repeal this statute  
          and thus act to withdraw the state from the compact.  

          Committee amendments: Committee staff recommends that the  
          Committee approve the following amendments; due to the double  
          referral of this bill and the impending Legislative deadlines,  
          these amendments should be provided to the Assembly Judiciary  
          Committee for adoption in that Committee.

          1)Direct the SPI after June 30, 2012 to reconvene, with its  
            original membership to the extent possible, the task force  
            that was convened pursuant to AB 2049 (Saldana); the  
            reconvened task force would review the impacts of the compact  
            on California, its school districts and its students, and  
            issue a final report regarding these impacts, including any  
            recommendations for legislative action, by December 1, 2012.

          2)Add the phrase "use best efforts to" to the waiver process  
            related to required coursework for graduation; this task force  
            recommendation was inadvertently omitted during the drafting  
            process.

          3)Replace a reference amended into the Compact to the  
            "California High School Exit Examination" with the "exit  
            examination adopted pursuant to Section 60850"; the California  
            High School Exit Examination is the test so adopted, but as a  
            specific test does not exist in statute.  Thus if the name of  
            the exit examination were changed or a new test adopted, this  
            clause of the Compact would lose meaning.

          4)Specify the membership of and the appointing authority for  
            members of the State Council that is charged with coordinating  








                                                                  AB 343
                                                                  Page  18

            efforts across all federal, state, and local agencies involved  
            in the state's participation in the Compact.

          5)Specify that the appointing authority for the state's Compact  
            Commissioner, who is responsible for the administration and  
            management of the state's participation in the compact, be the  
            SPI.

          Previous legislation:  AB 2049 (Saldana), Chapter 589, Statutes  
          of 2008, creates an urgency statute that requires the  
          Superintendent of Public Instruction (SPI) to convene and  
          support a task force to review and make recommendations  
          regarding the Interstate Compact on Educational Opportunity for  
          Military Children.  AB 1809 (Saldana), held in the Assembly  
          Appropriations Committee in 2008, was substantially similar to  
          this bill.  AB 2102 (Saldana), Chapter 608, Statutes of 2006,  
          establishes procedures, including requiring the CDE to establish  
          a formal liaison with the United States Department of Defense  
          and school districts that enroll military dependents, to  
          facilitate and smooth the transfer of school-age military  
          dependents and their school records

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          American Legion, Department of California
          Lincoln Military Housing
          Military Child Education Coalition
          San Diego Military Advisory Council
          San Diego Unified School District
          Vietnam Veterans of America, California State Council
          Michael B. Donley, Secretary of the Air Force; Donald C. Winter,  
            Secretary of the Navy; and Pete Geren, Secretary of the Army  
            (1 letter)

           Opposition 
           
          None on file
           
          Analysis Prepared by  :    Gerald Shelton / ED. / (916) 319-2087