BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                       AB 575


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          ASSEMBLY THIRD READING


          AB  
          575 (O'Donnell and Atkins)


          As Amended  June 2, 2015


          Majority vote


           ------------------------------------------------------------------- 
          |Committee       |Votes |Ayes                |Noes                  |
          |                |      |                    |                      |
          |                |      |                    |                      |
          |----------------+------+--------------------+----------------------|
          |Education       |5-2   |O'Donnell, McCarty, |Chávez, Kim           |
          |                |      |Santiago, Thurmond, |                      |
          |                |      |Weber               |                      |
          |                |      |                    |                      |
          |----------------+------+--------------------+----------------------|
          |Appropriations  |11-5  |Gomez, Bonta,       |Bigelow, Chang,       |
          |                |      |Calderon, Daly,     |Gallagher, Jones,     |
          |                |      |Eggman,             |Wagner                |
          |                |      |                    |                      |
          |                |      |                    |                      |
          |                |      |Eduardo Garcia,     |                      |
          |                |      |Gordon, Holden,     |                      |
          |                |      |Quirk, Rendon, Wood |                      |
          |                |      |                    |                      |
          |                |      |                    |                      |
           ------------------------------------------------------------------- 


          SUMMARY:  Requires the governing board of each school district and  
          the governing body of each county office of education (COE) to  
          adopt and implement a best practices teacher and administrator  








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          evaluation system by July 1, 2018.  Specifically, this bill:  


          1)Requires the best practices teacher evaluation system to be  
            negotiated with the local collective bargaining unit; and,  
            specifies if the certificated employees of the school district  
            or COE do not have an exclusive bargaining representative, the  
            governing board of the school district or COE shall adopt  
            objective evaluation and support components, as applicable.
          2)Specifies that a best practices teacher evaluation system has  
            the following attributes:


             a)   Each teacher is evaluated on the degree to which he or she  
               accomplishes the following objectives:
               i)     Engages and supports all students in learning,  
                 evidence of which may include, but is not limited to, high  
                 expectations and active student engagement for each  
                 student; 
               ii)    Creates and maintains effective environments for  
                 student learning;


               iii)   Understands and organizes subject matter for student  
                 learning, evidence of which may include, but is not limited  
                 to, extensive subject matter, content standards, and  
                 curriculum competence;


               iv)    Plans instruction and designs learning experiences for  
                 all students, evidence of which may include, but is not  
                 limited to, use of differentiated instruction and practices  
                 based on student progress and use of culturally responsive  
                 instruction, including, but not limited to, incorporation  
                 of multicultural information and content into the delivery  
                 of curriculum to eliminate the achievement gap;


               v)     Uses student assessment information to inform  








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                 instruction and improve learning, evidence of which shall  
                 include, but is not limited to, the use of formative and  
                 summative assessments to adjust instructional practices to  
                 meet the needs of individual students; and, specifies that  
                 for certificated employees who directly instruct English  
                 learner pupils in acquiring English language fluency, the  
                 assessment information shall include the results of the  
                 English language development test;


               vi)    Develops as a professional educator, evidence of which  
                 may include, but is not limited to, consistent and positive  
                 relationships with students, parents, staff and  
                 administrators, use of collaborative professional practices  
                 for improving instructional strategies, use of  
                 participation in identified professional growth  
                 opportunities, and use of meaningful self-assessment to  
                 improve as a professional educator; and, 


               vii)   Contributes to student academic growth based on  
                 multiple measures which include state and local formative  
                 and summative assessments that are applicable to the  
                 teaching assignment being evaluated, and as available and  
                 applicable for the grade level and subject taught, shall  
                 also include but are not limited to, classroom work, other  
                 local and state assessments, student grades, classroom  
                 participation, student presentations and performance, and  
                 student projects and portfolios; specifies for certificated  
                 employees who directly instruct English learner pupils in  
                 acquiring English, measures shall include the degree to  
                 which pupils acquire the English language development  
                 standards for the purpose of improving a pupil's English  
                 proficiency; and, specifies that pupil data used for  
                 purposes of teacher evaluation shall be confidential in the  
                 same manner as all other elements of a teacher's personnel  
                 file.










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             b)   Multiple observations of instructional and other  
               professional practices conducted by evaluators who have  
               received appropriate training and calibration and who have  
               demonstrated competence in teacher evaluation, as determined  
               by the school district. 
               i)     Specifies that multiple observations may include, but  
                 are not limited to, classroom observations, one-on-one  
                 discussions, and review of classroom materials and course  
                 of study.
               ii)    Specifies the observations shall be conducted using a  
                 uniform tool for use in observing the teacher for the  
                 purpose of conducting an evaluation.


               iii)   Specifies that prior to each observation, the observer  
                 shall meet with the teacher to discuss the purpose of the  
                 observation and after each observation, the observer shall  
                 meet with the teacher to discuss recommendations, as  
                 necessary, with regard to areas of improvement in the  
                 performance of the teacher.


               iv)    Nothing shall prohibit evaluators from conducting  
                 unscheduled classroom visits.


             c)   A minimum of three performance levels for the evaluation  
               of teacher performance.
          3)Evaluations at least once each school year for probationary  
            personnel; at least every other year for personnel with  
            permanent status; or, except as may be provided in the best  
            practices teacher evaluation system that is negotiated with the  
            local collective bargaining unit, at least every three years for  
            personnel with permanent status who have been employed at least  
            10 years with the school district, and are highly qualified  
            under the federal No Child Left Behind Act; requires the  
            evaluator to conduct at least one unscheduled observation per  
            year during a year when the certificated employee does not  
            receive a formal performance evaluation and assessment.








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             a)   Authorizes a locally negotiated evaluation process to  
               designate certificated employees to conduct, or participate  
               in, evaluations of other certificated employees for the  
               purposes of determining needs for professional development or  
               providing corrective advice for the certificated employee  
               being evaluated, as specified.  
             b)   Specifies a best practices teacher evaluation system shall  
               not omit any of the attributes specified.


          4)Requires the evaluation to include recommendations, if  
            necessary, as to areas of improvement in the performance of the  
            employee as follows:
             a)   If an employee is not performing his or her duties in a  
               satisfactory manner according to the standards prescribed by  
               the governing board of the school district or the governing  
               board of the COE, the employing authority shall notify the  
               employee in writing of that fact and describe the  
               unsatisfactory performance.
             b)   The employing authority shall thereafter confer with the  
               employee making specific recommendations as to areas of  
               improvement in the employee's performance and endeavor to  
               assist the employee in his or her performance.


             c)   If a permanent certificated employee has received an  
               unsatisfactory evaluation, the employing authority shall  
               annually evaluate the employee until the employee achieves a  
               positive evaluation or is separated from the school district  
               or COE.


             d)   An evaluation that contains an unsatisfactory rating of an  
               employee's performance in the area of teaching methods or  
               instruction may include the requirement that the certificated  
               employee shall, as determined necessary by the employing  
               authority, participate in a program designed to improve  








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               appropriate areas of the employee's performance and to  
               further pupil achievement and the instructional objectives of  
               the employing authority.


             e)   If a school district or COE participates in the California  
               Peer Assistance and Review Program for Teachers, a  
               certificated employee of that school district or COE who  
               receives an unsatisfactory rating on an evaluation shall  
               participate in the California Peer Assistance and Review  
               Program for Teachers.


          5)Specifies the administrator evaluation shall include, but not be  
            limited to, all of the following attributes:
             a)   Promoting the success of all pupils by facilitating the  
               development and implementation of a vision of pupil learning,  
               including, but not limited to, communicating with parents,  
               pupils, and the community regarding the importance of a  
               standards-based education and high expectations for all  
               pupils.
             b)   Advocating and supporting a safe, nurturing school culture  
               that sustains a quality instructional program conducive to  
               pupil learning and staff professional growth, including, but  
               not limited to, all of the following:


               i)     Promoting equity, fairness, and respect among staff,  
                 pupils, and members of the school community with  
                 acknowledgment of the role cultural attributes have in  
                 pupil learning.
               ii)    Supporting professional development opportunities for  
                 staff that encourage collaboration and effective  
                 instructional practice with the goal of improving outcomes  
                 for all pupils.


             c)   Ensuring the management, organization, and operation of a  
               safe and successful learning environment, as evidenced by the  








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               establishment of effective practices for personnel and  
               resource management, campus safety, and school climate,  
               including, but not limited to, supporting curricular and  
               management leadership in all of these areas and successfully  
               implementing a best practices teacher evaluation system.
             d)   Collaborating with parents and the community to establish  
               an inclusive school environment, including, but not limited  
               to, embracing and recognizing that diversity strengthens a  
               learning environment and promotes meaningful parent and  
               community engagement, for the development of the local  
               control and accountability plan.


             e)   Providing ethical and professional leadership that fosters  
               effective instructional practice as evidenced by promoting  
               quality teaching and instructional strategies and provides  
               relevant, effective feedback that leads to pupil learning.   
               School administrators shall be held accountable for the  
               academic growth of pupils over time and academic growth shall  
               be based on multiple measures that may include pupil work as  
               well as pupil and school longitudinal data. Multiple measures  
               shall include state and local formative and summative  
               assessments. For school administrators who supervise  
               certificated staff that directly instruct English learner  
               pupils acquiring English, assessment information shall  
               include the results of assessments adopted pursuant to  
               Chapter 7 (commencing with Section 60810) of Part 33 of  
               Division 4 of the Education Code.  Multiple measures may  
               include, but are not limited to, benchmark, end-of-chapter,  
               end-of-course, advanced placement, international  
               baccalaureate, college entrance, or performance assessments.   
               Pupil data used for purposes of an administrator evaluation  
               shall be confidential in the same manner as all other  
               elements of an administrator's personnel file.


             f)   Providing professional leadership by understanding,  
               responding, and influencing the larger social, political,  
               cultural and legal context with the goal of ensuring pupil  








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               success, as evidenced by working in collaboration with the  
               governing board of the school district, bargaining units, and  
               local school, school district, and community leaders.


             g)   Specifies the administrator evaluation system shall not  
               omit any of the attributes specified.


          6)Requires the governing board of a school district to identify  
            who will conduct the evaluation of each school administrator and  
            specifies the following:
             a)   A school administrator shall be evaluated annually for the  
               first and second year of employment as a new administrator in  
               a school district.  The governing board of the school  
               district may determine the frequency at regular intervals of  
               evaluations after this period.
             b)   Additional evaluations that occur outside of the regular  
               intervals determined by the governing board of the school  
               district shall be agreed upon between the evaluator and the  
               administrator.


             c)   Evaluators and administrators shall review school success  
               and progress throughout the year. This review should include  
               goals that are defined by the school district, including, but  
               not limited to, the goals specified in the local control and  
               accountability plan approved by the governing board.


          7)Requires the following sections of the Stull Act to become  
            inoperative July 1, 2018:
             a)   Legislative intent that governing boards establish a  
               uniform system for evaluation and assessment;
             b)   The requirement that the governing board shall, in  
               developing and adopting the guidelines, avail itself of the  
               advice of the certificated instructional personnel in the  
               district as part of a locally negotiated collective  
               bargaining agreement; and,








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             c)   The authorization for a school district, by mutual  
               agreement between the local bargaining unit and the district,  
               to include objective standards from the National Board for  
               Professional Teaching Standards or the California Standards  
               for the Teaching Profession.


          8)Specifies that the teacher evaluation system and the  
            administrator evaluation system cannot be waived for a school  
            district or county office of education by the State Board of  
            Education (SBE). 
          9)Authorizes the SBE, in consultation with the Superintendent of  
            Public Instruction and appropriate education stakeholder groups,  
            to adopt nonregulatory guidance to support the implementation of  
            a best practices teacher evaluation system. 


          10)Requires the following public hearings:


             a)   On or before May 1, 2016, or May 1 of the year that  
               precedes the year in which an existing collective bargaining  
               contract will expire, whichever is later, the governing board  
               of a school district and the governing body of a COE, at a  
               regularly scheduled public hearing, seek comment on the  
               development and implementation of the teacher and  
               administrator evaluation system. 
             b)   On or before May 1 of each year before local negotiations,  
               the governing board of a school district and the governing  
               board of the COE, at a regularly scheduled public hearing,  
               seek comment on the teacher and administrator evaluation  
               system. 


             c)   Both during and before the final agreement of local  
               negotiations, the governing board of each school district and  
               the governing board of the COE shall seek public comment on  








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               the teacher and administrator evaluation system.


             d)   If, by mutual agreement between a school district or COE  
               and the collective bargaining unit, an intermediate mid-year  
               agreement is reached regarding a best practices teacher  
               evaluation system or administrator evaluation system, the  
               negotiation timeline shall allow time for the governing board  
               of the school district or the governing board of the COE to  
               hold a public hearing to seek comment on the teacher and  
               administrator evaluation system.


             e)   Consistent with Government Code Section 3547 and no more  
               than 30 days after the local negotiations, the governing  
               board of each school district and the governing board of the  
               COE shall disclose the provisions of the best practices  
               teacher evaluation system and administrator evaluation system  
               at a regularly scheduled public hearing.


          11)Specifies that this bill does not supersede or invalidate a  
            teacher evaluation system that is locally negotiated and that is  
            in effect at the time this bill becomes operative.  If a locally  
            negotiated teacher evaluation system is in effect at the time  
            this bill becomes operative, the teacher evaluation system shall  
            remain in effect until the parties to the agreement negotiate a  
            successor agreement.  A memorandum of understanding shall not  
            extend the adoption of a locally negotiated teacher evaluation  
            system that is in effect at the time this section becomes  
            operative.
          12)Adds the best practices teacher evaluation system and the  
            administrator evaluation system to the mandate block grant and  
            specifies that it is the intent of the Legislature to provide  
            adequate resources to train evaluators, continue robust  
            beginning teacher induction programs, and support struggling  
            educators. 










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          13)Makes legislative findings and declarations that teaching is a  
            professional endeavor, one in which effective practice is driven  
            by an understanding of knowledge in the field and a commitment  
            to all students and their families; excellent teaching requires  
            knowledge, skills, artistry, passion, and commitment; effective  
            teachers integrate ethical concern for children and society;  
            extensive subject matter competence; thoughtfully selected  
            pedagogical practices; a depth of knowledge about their  
            students, including knowledge of child and adolescent  
            development and learning; an understanding of their individual  
            strengths, interests, and needs; and, knowledge about their  
            families and communities; effective teachers share a common set  
            of professional and ethical obligations that includes a profound  
            and fundamental commitment to the growth and success of the  
            individual students within their care as well as to the  
            strengthening and continual revitalization of our democratic  
            society; certificated, non-instructional employees share the  
            same deep commitment to children, families and communities, and  
            they provide essential support and services; and, the primary  
            purpose of an evaluation system is to ensure that teachers meet  
            the highest professional standards of effective teaching thereby  
            resulting in high levels of student learning.


          EXISTING LAW:  


          1)Establishes the Stull Act, enacted in 1971, which governs  
            certificated employee evaluations and requires school districts  
            to evaluate and assess teacher performance as it reasonability  
            relates to pupil performance on criterion referenced tests,  
            teacher technique and strategies, curricular objectives, and the  
            maintenance of a suitable learning environment.  Specifies that  
            in the development and adoption of evaluation guidelines and  
            procedures, the governing board shall avail itself of the advice  
            of the certificated instructional personnel in the district's  
            organization of certificated personnel pursuant to collective  
            bargaining statutes.  Specifies that a school district may, by  
            mutual agreement between the exclusive representative of the  








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            certificated employees of the school district and the governing  
            board of the school district, include any objective standards  
            from the National Board for Professional Teaching Standards or  
            any objective standards from the California Standards for the  
                                                                                 Teaching Profession.  Specifies that teacher evaluations shall  
            be made on a continuing basis at least once each school year for  
            probationary personnel; at least every other year for personnel  
            with permanent status; and, at least every five years for  
            personnel with permanent status who have been employed at least  
            10 years with the school district, are highly qualified, if  
            those personnel occupy positions that are required to be filled  
            by a highly qualified professional, and whose previous  
            evaluation rated the employee as meeting or exceeding standards,  
            if the evaluator and certificated employee being evaluated  
            agree.  Specifies that an employee who receives an  
            unsatisfactory rating in the area of teaching methods or  
            instruction may be required to participate in a program designed  
            to improve appropriate areas of the employee's performance; and,  
            requires if a school district participates in the Peer  
            Assistance and Review Program for Teachers (PAR), employees who  
            receive an unsatisfactory rating shall participate in PAR.   
            (Education Code Section 44660 et. seq.)


          2)Establishes the Principal Evaluation System by authorizing the  
            governing board of a school district to identify who will  
            conduct the evaluation of each school principal.  Specifies a  
            school principal may be evaluated annually for the first and  
            second year of employment as a new principal in a school  
            district.  The governing board may determine the frequency at  
            regular intervals of evaluations after this period.  Additional  
            evaluations that occur outside of the regular intervals  
            determined by the governing board may be agreed upon between the  
            evaluator and the principal.  Criteria for effective school  
            principal evaluations may be based upon the California  
            Professional Standards for Educational Leaders. 


          FISCAL EFFECT:  According to the Assembly Appropriations  








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          Committee:


          1) Proposition 98 (1988)/General Fund state mandated reimbursable  
          costs to school districts and COEs, likely in excess of $60  
          million, to create and implement teacher and administrator  
          evaluation programs starting July 1, 2018.  According to the  
          Commission on Teacher Credentialing, there are approximately  
          288,000 teachers in California.  New mandated costs include:  
          annual evaluation costs to increase evaluation frequency from once  
          every five years to once every three years (likely for more than  
          100,000 teachers); multiple observations of each teacher;  
          collective bargaining costs related to negotiating the new  
          evaluation system; training of educators who will be conducting  
          the evaluations and cost pressures to provide robust beginning  
          teacher induction programs and support to struggling educators.


          2) General Fund administrative costs of approximately $265,000 to  
          the California Department of Education, annually over two years,  
          to adopt non-regulatory guidance to support the implementation of  
          the evaluations


          COMMENTS:  This bill replaces the existing teacher evaluation  
          system, known as the Stull Act, with a new teacher and  
          administrator evaluation system that requires specific components,  
          such as state and local formative and summative assessment data  
          and observations.  While existing law requires school districts to  
          collectively bargain many of these elements, this bill requires  
          these components to be included in a uniform educator evaluation  
          system.  According to the author, the goal is to establish a fair,  
          transparent, and comprehensive teacher evaluation system  
          accountable to pupils, parents and teachers.  California's 1,000  
          school districts serve diverse pupil populations, employees, and  
          communities.  What works in Los Angeles Unified School District  
          does not necessarily work in the Eureka City Unified School  
          District.  While this measure does require specific components to  
          be part of teacher and administrator evaluations, it allows  








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          individual school districts the flexibility to determine how these  
          elements will be implemented to meet the needs of their pupils,  
          teachers, administrators, and parents.


          Research on the Current Teacher Evaluation System:  According to  
          the author, the state's current teacher evaluation system is  
          inconsistent, unclear, and does little to foster a culture of  
          continuous improvement for teachers.  According to a 2010 report  
          released by the National Board Resource Center at Stanford  
          University, "While evaluation processes across the state vary  
          widely, many of them look very much the same as they did in 1971?  
          In sharing their own experiences with evaluations, Accomplished  
          California Teachers members revealed some common challenges: a  
          system that teachers do not trust, that rarely offers clear  
          direction for improving practice and that often charges school  
          leaders to implement without preparation or resources."  


          Several research studies detail the essential principals and  
          components of a strong teacher evaluation system.  The National  
          Comprehensive Center for Teacher Quality argues a strong  
          evaluation system must:  "involve teachers and stakeholders in  
          developing the system; use multiple indicators; and give teachers  
          opportunities to improve in the areas in which they score poorly."  
           Likewise, the New Teacher Project states "evaluations should  
          provide all teachers with regular feedback that helps them grow as  
          professionals, no matter how long they have been in the classroom.  
           The primary purpose of evaluations should not be punitive.  Good  
          evaluations identify excellent teachers and help teachers of all  
          skill levels understand how they can improve."


          The Use of Assessments in Evaluation:  This bill requires both  
          state and local formative and summative assessments to be included  
          in educator evaluation.  Formative assessments are developed  
          locally and are used by teachers to continually inform instruction  
          in the classroom throughout the school year.  Summative  
          assessments can be developed locally or state-wide and assess a  








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          student's performance at a point in time.  Summative assessments  
          can include end of unit quizzes, end of course tests, or  
          standardized tests.  


          Evaluation Frequency:  This bill requires probationary teachers to  
          be evaluated at least every year and permanent teacher to be  
          evaluated at least every other year; and, it reduces the  
          authorization for teachers with more than 10 years experience to  
          be evaluated every five years, and instead authorizes evaluation  
          every three years.  By reducing the five-year evaluation cycle to  
          a three-year evaluation cycle for experienced teachers, this bill  
          will require experienced teachers to be evaluated more frequently.  
           It is unclear how many teachers are currently evaluated every  
          five years and thus it is unclear how this bill will affect  
          administrator work load to complete the increased number of  
          evaluations.  


          Professional Development:  This bill specifies that teachers who  
          receive an unsatisfactory rating on their evaluation, if a school  
          district has a PAR program in place, they must refer teachers who  
          receive an unsatisfactory review to the PAR program for  
          improvement.  This bill does not specify the process if a teacher  
          continues to receive unsatisfactory evaluations after the PAR  
          program is complete.  It is unclear whether school districts  
          should begin dismissal proceedings, or provide further  
          instructional support for the teacher.  


          Evaluation Funding:  This bill specifies that is it the intent of  
          the Legislature to provide adequate resources to train evaluators,  
          continue robust beginning teacher induction programs, and support  
          struggling educators.  According to the author, appropriate  
          funding is a key component to achieving a high quality teacher and  
          administrator evaluation system, as well as necessary support  
          programs for beginning teachers and struggling teachers. 










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          Public Hearings:  This bill requires public hearings before May  
          1st of the year proceeding local negotiations, as well as public  
          hearings should a mid-year agreement be reached.  The public  
          hearing process will require a hearing before negotiations begin,  
          during negotiations, prior to the final vote on the evaluation  
          system, as well as after the evaluation has been adopted.  The  
          intent of these public hearings is to allow for parents to give  
          input on the evaluation system each time it is negotiated.  It is  
          unclear how much information is legally allowed to be shared  
          publically during the negotiation process.  The Legislature should  
          consider whether this mid-negotiation hearing is appropriate. 


          Collective Bargaining Agreements:  This bill requires the teacher  
          evaluation system to be collectively bargained, if the district or  
          COE has a collective bargaining unit.  The specific provisions of  
          this bill cannot be bargained out of the final evaluation system  
          adopted by a school district or COE.  The requirements in this  
          bill must be included in the evaluation system, they cannot be  
          weakened or omitted from the evaluation system in any way.  


          Further, this bill clarifies that the teacher evaluation system  
          does not supersede or invalidate a teacher evaluation system that  
          is locally negotiated and that is in effect at the time this bill  
          becomes operative.  If a locally negotiated teacher evaluation  
          system is in effect at the time this bill becomes operative, the  
          teacher evaluation system shall remain in effect until the parties  
          to the agreement negotiate a successor agreement.  This bill  
          further clarifies that a memorandum of understanding (MOU) shall  
          not extend the adoption of a locally negotiated teacher evaluation  
          system that is in effect at the time this bill becomes operative.   
          In other words, if a collective bargaining agreement ends, but is  
          extended by an MOU, the existing teacher evaluation system cannot  
          remain in effect indefinitely during an MOU.


          Arguments in Support:  Public Advocates supports this bill and  
          states, "In multiple ways AB 575 would strengthen the evaluation  








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          system and not just by requiring full compliance with California's  
          teaching standards which are optional under the existing law  
          (Stull Act).  AB 575 requires that any teacher evaluation system  
          must include certain elements and cannot be negotiated away,  
          including:


             1)   Increasing the frequency of the most veteran educators'  
               evaluation from once every five years to once every three  
               years,
             2)   Increasing the categories for rating teachers from two  
               (simply satisfactory and unsatisfactory) to three,


             3)   Requiring a series of classroom observations from  
               evaluators trained for the task; and


             4)   Requiring that districts receive and consider input from  
               parents, students, and community members into the development  
               of the local evaluation process,  


             5)   Requiring evidence of teachers' contribution to students'  
               academic performance through multiple measures, including  
               summative and formative assessments,


             6)   Requiring that teachers who are evaluated unsatisfactory  
               participate in a district's Peer Assistance and Review (PAR)  
               program if it has one."


          Arguments in Opposition:  The Education Trust-West opposes this  
          bill and states:  "The Education Trust - West opposes AB 575  
          because it would expand the scope of bargaining, mandate the use  
          of the California Standards for the Teaching Profession (CSTP's)  
          through a rigid scheme, and eliminate waivers allowing districts  
          to implement alternative, innovative teacher evaluation systems?  








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          The proposed scheme allows minimal flexibility to emphasize one or  
          more of the standards over the others, according to local needs,  
          and use them in combination with other measures such as parent and  
          student surveys.  This would hamper the innovative efforts of  
          school districts that are using frameworks not directly tied to  
          the CSTPs, and demonstrating improvement in teacher performance  
          and student learning." 




          Analysis Prepared by:                                               
          Chelsea Kelley / ED. / (916) 319-2087  FN: 0000816