GC NYC submits public comment on forthcoming Civic Readiness Index
Public comment on the New York Commissioner’s Proposed ESSA regulations around the College, Career, and Civic Readiness Index and the creation of a state-wide civics seal
On August 13, 2018 Generation Citizen New York City submitted public comment to the Commissioner of the New York State Education Department regarding the civic readiness aspect of the Career, College and Civic Readiness Index being developed as part of New York’s implementation of Every Student Succeeds Act. Read on!
August 13, 2018
Commissioner Mary Ellen Elia
New York State Education Department
89 Washington Avenue
Board of Regents, Room 110 EB
Albany, New York 12234
Dear Commissioner Elia:
Generation Citizen New York City (GCNYC) appreciates the opportunity to
share our comments regarding the civic readiness component of Career,
College and Civic Readiness Index (CCCRI) contained in the
Commissioner’s proposed emergency regulations to implement the Every
Student Succeeds Act (ESSA).
Generation Citizen is a nine-year-old national organization that partners with
teachers and schools to help them implement a comprehensive, high-quality
Action Civics education program. Our goal is to ensure that every student in
the United States gains the knowledge and skills necessary to participate in
our democracy as active, lifelong citizens. Generation Citizen New York City
(GCNYC) is the largest Action Civics education provider in New York City.
We have educated and empowered more than 18,000 students citywide
since 2011, providing them with the knowledge and skills for lifelong civic
participation in our twenty-first century democracy.
Civic Engagement Gap
New York, like the nation, has a civic participation problem. New York
ranked 41st out of 50 states in voter turnout during the 2016 election: just
57% of eligible voters cast ballots. According to the Corporation for National
and Community Service, in our broader region, only 5.62% of residents
attended a public meeting of any kind in 2015, and only 17.4% of residents
volunteered, ranking the NYC/NJ/Long Island metropolitan statistical area
(MSA) 49th out of 51 measured.
GCNYC is working to address the decline of civic participation among young
people by reinvigorating civics education through a new, engaging
pedagogy: Action Civics. Action Civics is a “student-centered, project-based
approach to civics education that develops the individual skills, knowledge,
and dispositions necessary for 21st century democratic practice”. Students
learn about democratic structures and processes by examining their
community, building consensus around an issue, conducting research,
engaging local policy makers, and reflecting on the experience.
We intentionally focus on bringing Action Civics to under-performing and
under-resourced schools to produce equitable access to civic engagement.
We seek to reduce the prevalence of “civic deserts” in rural communities
where there are few opportunities for civic learning and engagement, and
close the “civic engagement gap” — the disparity that exists in civics
education between affluent communities and low-income communities. As a
result of these disparities and lack of opportunities, rural and low-income
communities demonstrate lower rates of voting and civic participation
alongside higher levels of distrust for institutions and government, and lower
overall measures of postsecondary success. For instance, more than half of
students in the United States report they never participate in mock trials or
simulations and less than twenty percent of fourth, or eighth grade teachers
report organizing visits from members of the community or report that their
students participate in community projects. Supporting Action Civics in every
classroom can begin to fill this gap and enable equitable opportunities for
student success and civic engagement — a foundational need of our
Defining the Civic Readiness Index
GCNYC applauds the Board of Regents, Commissioner Elia, Deputy
Commissioner Infante-Green, and the New York State Education
Department for establishing the CCCRI in the state’s Every Student
Succeeds Act plan and recognizing civics education as a critical component
of ensuring students receive a well-rounded education. While the CCCRI
establishes a baseline for holding schools accountable for ensuring
students’ civic readiness, the proposed regulations do not establish a civic
readiness standard. We recommend that the State Education Department
adopt regulations to define civic readiness.
We were excited to learn recently of the Board’s plan to create a “civics
seal”. Many states, including New York, already have a seal of biliteracy;
however, students in advanced courses are better prepared to attain this
seal based on the current point system. We urge the Board to establish
equitable standards when deciding the prerequisites to earn a civics seal in
order to incentivize more students rather than widen the civic engagement
gap. We believe that the civics seal prerequisites should, at minimum,
include two capstone projects to be sequenced in eighth grade social
studies and the existing Participation in Government course, which includes
these Action Civics elements: community examination, issue identification,
research, strategizing, taking action, and reflection.
To that end, we believe that, in tandem with the civics seal, the state must
allocate funding to districts to provide teachers with the necessary
professional development that aligns to implementing these changes. We
recommend that the majority of those funds be allocated towards Title I
schools. Without this targeted funding, the very notion of a civic seal risks a perpetuation of the civic engagement gap and civic deserts as it will not
ensure that all students, particularly the state’s most underserved students,
will be offered a sufficient opportunity to meet the seal’s pending standards.
This professional development should include providing teachers with
resources, supports for coaches and administrators, and examples of how
and where to find resources independently.
Understanding that what we are advocating cannot be accomplished
immediately and buy-in from teachers and other education stakeholders is
important to the success of the CCCRI, we believe that there are certain
steps that can be taken now towards the goal of ensuring that all students
receive an effective Action Civics education. The existing Participation in
Government course provides a sound explanation of government structures;
however, Unit G, which requires students to conduct research on a policy
issue and suggest solutions, is known to be optional. We believe providing
teachers with curriculum resources for students to debate, build consensus,
research and analyze the root causes of their issue, and develop an action
plan to present to community leaders will make this portion of the class more
We appreciate the opportunity to share our recommendations with the Board
and Commissioner. We look forward to working with the Board and
Commissioner to ensure that the CCCRI is a robust national model, which
includes a strong definition of civic readiness and equitable standards for a
civic seal in the Commissioner’s final regulations.
We are available at your convenience to answer any questions.
Thank you in advance for considering our comments.
New York City Executive Director
Brian C. Hoff
Policy & Advocacy Fellow
Leadership for Educational Equity
cc: Members of the New York State Board of Regents