I had to make a point to not turn my formal comments on the Common Core Standards into a grand thesis. I've got other stuff to do with my life. Here's what I knocked out and submitted:
The draft College and Career Readiness Standards for Reading, Writing, and Speaking and Listening (CCRS RWLS) are not defined and explained clearly enough to generate a valid outside evaluation.
If I had commissioned this draft, I would reject it out of hand for simply not fulfilling the assignment. The CCSSI asked for "English Language Arts" standards and received "Reading, Writing, and Speaking and Listening" standards. What is the difference? Simply to acknowledge that other disciplines are also responsible for these standards? Is English Language Arts a subset of these standards, a superset, or do they overlap?
In comparison to high quality state, international, and other comparable US ELA standards, RWLS standards are significantly narrower, often covering a half to two thirds of other ELA standards. Without knowing the relationship to ELA standards, whether or not this is grounds for a valid critique is a mystery.
The introduction to the standards states "English language arts teachers not only must engage their students in a rich array of literature..." Does this document contain a complete set of literature standards, or a fragment? The placement of narrative writing as important but outside the scope of the CCRS suggests that RWLS only partially overlaps a complete set of English Language Arts standards in writing.
The relationship between these standards and English Language Arts standards is particularly important because the draft language for the Race to the Top grant requirements states that "... a State may supplement the common standards with additional standards, provided that the additional standards do not exceed 15 percent of the State's total standards for that content area." In this case, what is the content area? English Language Arts?
What is the definition of "Career and College Ready?" It covers a broad range of possibilities. Are these standards meant to apply equally to all collegiate courses of study, from engineering to marketing to creative writing, or are some more important than others? What is "workforce training?" Does that cover on the job training for jobs requiring only a high school diploma?
What is the relationship between CCRS, graduation standards, and other standards in a high school? They are referred to in passing as skills and understandings that students must have "no later than the end of high school" under "How to Read the Document" / "Strands" / "Standards for Student Performance," but the issue is never directly confronted. Some literature on CCRS standards suggests that these will be used as a higher tier of standards than simple graduation. Elsewhere, Achieve seems to regard them as the basis for a single graduation standard. One might argue that CCRS are merely a subset of graduation standards, as the mission of schools is not limited to college and career readiness. This basic definition is never addressed.
In comparison to other high quality standards documents, specifically the ones listed and linked in the CCSSI document, the RWLS standards frequently are phrased to require simpler, lower level skills (judging by, say, Bloom's Taxonomy) than the benchmarked references. Is this intentional? Are the CCRS RWLS standards deliberately lower than the graduation standard for English Language Arts for a high-performing state or country? Or is this an accident? Incompetence? Haste? Willful deception? Does "international benchmarking" require equal rigor and scope, or simply a comparison?
For example, the introductory evidence states "The expectation that high school graduates will be able to produce writing that is logical and coherent is found throughout the standards of top-performing countries and states." Yet in these countries and states, "logical and coherent" writing is considered merely the foundation of more sophisticated expectations within the high school curriculum. Only the CCSSI standards regard this as practically sufficient for end of high school writing.
The clear long term goal of the federal Department of Education for these standards and subsequent assessments is teacher evaluation. Will subsequent tests and evaluation systems recognize the shared responsibility across content areas for meeting these standards?
Interpreting these standards is further confounded by their complex organization (compared to similar documents in ELA) and poor internal alignment between different sections.
The introduction on page i states "When reading, students demonstrate their comprehension most commonly through a spoken or written interpretation of the text." Yet no subsequent standards require a student to create an individual interpretation of a text.
The "Student Practices" section (which is itself highly idiosyncratic and not benchmarked at all) states "4. They comprehend as well as critique." But "critique" never appears in any subsequent standards.
Under "Student Practices" / "8. They use technology strategically and capably," is included "They are familiar with the strengths and limitations of various technological tools and mediums and can select and use those best suited to their communications goals." Yet there are no subsequent standards that require this selection.
Under "Range of Content of Student Reading" / "Complexity," (the range of content standards are also idiosyncratic and not benchmarked) is stated "In college and careers, students will need to read texts characterized by... subtle relationships between ideas or characters." There are no subsequent performance standards that require students to understand "subtle relationships between ideas or characters." The language in the performance standard is more limited: "6. Analyze the traits, motivations, and thoughts of individuals in fiction and nonfiction based on how they are described, what they say and do, and how they interact." These are different. Which one counts?
The "Range of Content for Speaking and Listening" / "Group and One-to-One Situations" state "The immediate communication between two people might be replaced by formal turn taking in large-group discussions." But there are no performance standards for one-to-one discussion or "formal turn taking" in discussions.
What is the practical implication of, under "Range of Content for Listening and Speaking" / "Varied Disciplinary Content," "College- and career-ready students must develop a foundation of disciplinary knowledge and conventions in order to not only comprehend the complexity of information and ideas but also to explain them." Does meeting this standard require meeting all other subject area standards (math, science, etc...)?
Without referring to definitions of the above terms, or clarifying the extensive internal misalignment of the document, it is impossible to evaluate the level or completeness of these standards. The document should either be revised to clearly explain its scope and intent, and resubmitted for public comment, or simply scrapped in favor of one of the many well regarded and vastly better developed examples of English Language Arts standards which CCSSI is well aware of, such as those of Massachusetts, Indiana, the Diploma Project, NECAP, Texas's CCRS, NCTE, or those of Finland, England, or various Canadian provinces.
With that, I will go re-caulk my tub.