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NCL Comments on the WIOA Draft Regulations

JC
Jeff Carter
Tue, Jun 16, 2015 2:40 AM

Members,

Greetings from a hotel room in NYC, where for the second time in six days I am stranded overnight due to plane cancellations.

All day today I have been sporadically attempting to take one last try at pulling together a set of recommendations on the WIOA draft regs to submit on behalf of NCL. Even my fallback plan, which was to submit a summary as an individual, and not on behalf of NCL per se (since it’s too late to get coalition approval on what I’ve been writing) is going to fall through.

We simply don’t have the capacity to what I was attempting, and it was a poor decision on my part to volunteer to try to do it by myself. I went through some of the members' comments with a very experienced colleague in government relations yesterday and was told quite frankly that to do what I was attempting to do would in their opinion take a full-time government relations relations staff person weeks to complete, working full time.

But I don’t think we should simply drop the matter and move on. Tomorrow as promised I will add links to the comments submitted by individual members of NCL to our Web site via a blog post. I think, if you read them, that you will agree with me that there is a lack of cohesion among the issues raised by the different members that submitted. That was why, in the end, it would have taken a Herculean effort to distill them into one set of comments. But I think it’s worrying that while there are a few broad areas of concern shared by most members (support for low-level learners for example, clarification on ELL provisions), there was, as far as I could see, no single issue that was in fact shared by all. It’s clear that there are also areas of disagreement on what the implications of these regulations mean.

Members also raised a lot of issues not addressed by the state directors, who among all the groups focused on Title II, had the most exhaustive set of comments. And finally, I’m very worried about comments being submitted by groups about Title II that have less understanding and experience with Title II programs on the ground that NCL members do. All the more reason why I strongly recommend we continue to discuss the implications of WIOA in the coming months and try to better understand the differing points of view on several key issues.

Thank you for your understanding. More tomorrow.

Jeff

Members, Greetings from a hotel room in NYC, where for the second time in six days I am stranded overnight due to plane cancellations. All day today I have been sporadically attempting to take one last try at pulling together a set of recommendations on the WIOA draft regs to submit on behalf of NCL. Even my fallback plan, which was to submit a summary as an individual, and not on behalf of NCL per se (since it’s too late to get coalition approval on what I’ve been writing) is going to fall through. We simply don’t have the capacity to what I was attempting, and it was a poor decision on my part to volunteer to try to do it by myself. I went through some of the members' comments with a very experienced colleague in government relations yesterday and was told quite frankly that to do what I was attempting to do would in their opinion take a full-time government relations relations staff person weeks to complete, working full time. But I don’t think we should simply drop the matter and move on. Tomorrow as promised I will add links to the comments submitted by individual members of NCL to our Web site via a blog post. I think, if you read them, that you will agree with me that there is a lack of cohesion among the issues raised by the different members that submitted. That was why, in the end, it would have taken a Herculean effort to distill them into one set of comments. But I think it’s worrying that while there are a few broad areas of concern shared by most members (support for low-level learners for example, clarification on ELL provisions), there was, as far as I could see, no single issue that was in fact shared by all. It’s clear that there are also areas of disagreement on what the implications of these regulations mean. Members also raised a lot of issues not addressed by the state directors, who among all the groups focused on Title II, had the most exhaustive set of comments. And finally, I’m very worried about comments being submitted by groups about Title II that have less understanding and experience with Title II programs on the ground that NCL members do. All the more reason why I strongly recommend we continue to discuss the implications of WIOA in the coming months and try to better understand the differing points of view on several key issues. Thank you for your understanding. More tomorrow. Jeff
GS
Gail Spangenberg
Tue, Jun 16, 2015 10:58 AM

Jeff, Please don't feel bad about this nearly impossible task.  In fact, I don't think the NCL needs to submit its own comments.  I think it's better, as you note, to report in the NCL published news the comments member institutions have submitted and endorse and try to make use of them. A number of NCL members have submitted comments, which by their nature are bound to emphasize different priorities according to their organizational missions -- which I see as a strength.  Also, it's easier for policy-oriented organizations who are deeply familiar with the WIOA legislation and its history to comment I imagine.  :-)  Gail

On Jun 15, 2015, at 10:40 PM, Jeff Carter jeffcrtr@gmail.com wrote:

Members,

Greetings from a hotel room in NYC, where for the second time in six days I am stranded overnight due to plane cancellations.

All day today I have been sporadically attempting to take one last try at pulling together a set of recommendations on the WIOA draft regs to submit on behalf of NCL. Even my fallback plan, which was to submit a summary as an individual, and not on behalf of NCL per se (since it’s too late to get coalition approval on what I’ve been writing) is going to fall through.

We simply don’t have the capacity to what I was attempting, and it was a poor decision on my part to volunteer to try to do it by myself. I went through some of the members' comments with a very experienced colleague in government relations yesterday and was told quite frankly that to do what I was attempting to do would in their opinion take a full-time government relations relations staff person weeks to complete, working full time.

But I don’t think we should simply drop the matter and move on. Tomorrow as promised I will add links to the comments submitted by individual members of NCL to our Web site via a blog post. I think, if you read them, that you will agree with me that there is a lack of cohesion among the issues raised by the different members that submitted. That was why, in the end, it would have taken a Herculean effort to distill them into one set of comments. But I think it’s worrying that while there are a few broad areas of concern shared by most members (support for low-level learners for example, clarification on ELL provisions), there was, as far as I could see, no single issue that was in fact shared by all. It’s clear that there are also areas of disagreement on what the implications of these regulations mean.

Members also raised a lot of issues not addressed by the state directors, who among all the groups focused on Title II, had the most exhaustive set of comments. And finally, I’m very worried about comments being submitted by groups about Title II that have less understanding and experience with Title II programs on the ground that NCL members do. All the more reason why I strongly recommend we continue to discuss the implications of WIOA in the coming months and try to better understand the differing points of view on several key issues.

Thank you for your understanding. More tomorrow.

Jeff


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Members@lists.national-coalition-literacy.org
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Gail Spangenberg
Founder & Managing Director
Adult Learning Partners, LLC
440 East 23rd Street - Ste. 11c
New York, NY 10010

Jeff, Please don't feel bad about this nearly impossible task. In fact, I don't think the NCL needs to submit its own comments. I think it's better, as you note, to report in the NCL published news the comments member institutions have submitted and endorse and try to make use of them. A number of NCL members have submitted comments, which by their nature are bound to emphasize different priorities according to their organizational missions -- which I see as a strength. Also, it's easier for policy-oriented organizations who are deeply familiar with the WIOA legislation and its history to comment I imagine. :-) Gail On Jun 15, 2015, at 10:40 PM, Jeff Carter <jeffcrtr@gmail.com> wrote: > Members, > > Greetings from a hotel room in NYC, where for the second time in six days I am stranded overnight due to plane cancellations. > > All day today I have been sporadically attempting to take one last try at pulling together a set of recommendations on the WIOA draft regs to submit on behalf of NCL. Even my fallback plan, which was to submit a summary as an individual, and not on behalf of NCL per se (since it’s too late to get coalition approval on what I’ve been writing) is going to fall through. > > We simply don’t have the capacity to what I was attempting, and it was a poor decision on my part to volunteer to try to do it by myself. I went through some of the members' comments with a very experienced colleague in government relations yesterday and was told quite frankly that to do what I was attempting to do would in their opinion take a full-time government relations relations staff person weeks to complete, working full time. > > But I don’t think we should simply drop the matter and move on. Tomorrow as promised I will add links to the comments submitted by individual members of NCL to our Web site via a blog post. I think, if you read them, that you will agree with me that there is a lack of cohesion among the issues raised by the different members that submitted. That was why, in the end, it would have taken a Herculean effort to distill them into one set of comments. But I think it’s worrying that while there are a few broad areas of concern shared by most members (support for low-level learners for example, clarification on ELL provisions), there was, as far as I could see, no single issue that was in fact shared by all. It’s clear that there are also areas of disagreement on what the implications of these regulations mean. > > Members also raised a lot of issues not addressed by the state directors, who among all the groups focused on Title II, had the most exhaustive set of comments. And finally, I’m very worried about comments being submitted by groups about Title II that have less understanding and experience with Title II programs on the ground that NCL members do. All the more reason why I strongly recommend we continue to discuss the implications of WIOA in the coming months and try to better understand the differing points of view on several key issues. > > Thank you for your understanding. More tomorrow. > > Jeff > _______________________________________________ > National Coalition for Literacy Members mailing list > Members@lists.national-coalition-literacy.org > To unsubscribe: http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org Gail Spangenberg Founder & Managing Director Adult Learning Partners, LLC 440 East 23rd Street - Ste. 11c New York, NY 10010
DK
Deborah Kennedy
Tue, Jun 16, 2015 3:14 PM

Jeff,

I agree completely with Gail's perspective on this. As a national coalition, our mission is to make connections between our members and policy makers, so that members' voices are heard and policy makers can take advantage of the knowledge and insights that our members bring to the table. So adding links on our website is the right approach. Thanks for doing that.

Deborah

From: Members [mailto:members-bounces@lists.national-coalition-literacy.org] On Behalf Of Gail Spangenberg
Sent: Tuesday, June 16, 2015 6:58 AM
To: Jeff Carter
Cc: National Coalition for Literacy Members List
Subject: Re: [NCL Members] NCL Comments on the WIOA Draft Regulations

Jeff, Please don't feel bad about this nearly impossible task.  In fact, I don't think the NCL needs to submit its own comments.  I think it's better, as you note, to report in the NCL published news the comments member institutions have submitted and endorse and try to make use of them. A number of NCL members have submitted comments, which by their nature are bound to emphasize different priorities according to their organizational missions -- which I see as a strength.  Also, it's easier for policy-oriented organizations who are deeply familiar with the WIOA legislation and its history to comment I imagine.  :-)  Gail

On Jun 15, 2015, at 10:40 PM, Jeff Carter <jeffcrtr@gmail.commailto:jeffcrtr@gmail.com> wrote:

Members,

Greetings from a hotel room in NYC, where for the second time in six days I am stranded overnight due to plane cancellations.

All day today I have been sporadically attempting to take one last try at pulling together a set of recommendations on the WIOA draft regs to submit on behalf of NCL. Even my fallback plan, which was to submit a summary as an individual, and not on behalf of NCL per se (since it's too late to get coalition approval on what I've been writing) is going to fall through.

We simply don't have the capacity to what I was attempting, and it was a poor decision on my part to volunteer to try to do it by myself. I went through some of the members' comments with a very experienced colleague in government relations yesterday and was told quite frankly that to do what I was attempting to do would in their opinion take a full-time government relations relations staff person weeks to complete, working full time.

But I don't think we should simply drop the matter and move on. Tomorrow as promised I will add links to the comments submitted by individual members of NCL to our Web site via a blog post. I think, if you read them, that you will agree with me that there is a lack of cohesion among the issues raised by the different members that submitted. That was why, in the end, it would have taken a Herculean effort to distill them into one set of comments. But I think it's worrying that while there are a few broad areas of concern shared by most members (support for low-level learners for example, clarification on ELL provisions), there was, as far as I could see, no single issue that was in fact shared by all. It's clear that there are also areas of disagreement on what the implications of these regulations mean.

Members also raised a lot of issues not addressed by the state directors, who among all the groups focused on Title II, had the most exhaustive set of comments. And finally, I'm very worried about comments being submitted by groups about Title II that have less understanding and experience with Title II programs on the ground that NCL members do. All the more reason why I strongly recommend we continue to discuss the implications of WIOA in the coming months and try to better understand the differing points of view on several key issues.

Thank you for your understanding. More tomorrow.

Jeff


National Coalition for Literacy Members mailing list
Members@lists.national-coalition-literacy.orgmailto:Members@lists.national-coalition-literacy.org
To unsubscribe: http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org

Gail Spangenberg
Founder & Managing Director
Adult Learning Partners, LLC
440 East 23rd Street - Ste. 11c
New York, NY 10010

Jeff, I agree completely with Gail's perspective on this. As a national coalition, our mission is to make connections between our members and policy makers, so that members' voices are heard and policy makers can take advantage of the knowledge and insights that our members bring to the table. So adding links on our website is the right approach. Thanks for doing that. Deborah From: Members [mailto:members-bounces@lists.national-coalition-literacy.org] On Behalf Of Gail Spangenberg Sent: Tuesday, June 16, 2015 6:58 AM To: Jeff Carter Cc: National Coalition for Literacy Members List Subject: Re: [NCL Members] NCL Comments on the WIOA Draft Regulations Jeff, Please don't feel bad about this nearly impossible task. In fact, I don't think the NCL needs to submit its own comments. I think it's better, as you note, to report in the NCL published news the comments member institutions have submitted and endorse and try to make use of them. A number of NCL members have submitted comments, which by their nature are bound to emphasize different priorities according to their organizational missions -- which I see as a strength. Also, it's easier for policy-oriented organizations who are deeply familiar with the WIOA legislation and its history to comment I imagine. :-) Gail On Jun 15, 2015, at 10:40 PM, Jeff Carter <jeffcrtr@gmail.com<mailto:jeffcrtr@gmail.com>> wrote: Members, Greetings from a hotel room in NYC, where for the second time in six days I am stranded overnight due to plane cancellations. All day today I have been sporadically attempting to take one last try at pulling together a set of recommendations on the WIOA draft regs to submit on behalf of NCL. Even my fallback plan, which was to submit a summary as an individual, and not on behalf of NCL per se (since it's too late to get coalition approval on what I've been writing) is going to fall through. We simply don't have the capacity to what I was attempting, and it was a poor decision on my part to volunteer to try to do it by myself. I went through some of the members' comments with a very experienced colleague in government relations yesterday and was told quite frankly that to do what I was attempting to do would in their opinion take a full-time government relations relations staff person weeks to complete, working full time. But I don't think we should simply drop the matter and move on. Tomorrow as promised I will add links to the comments submitted by individual members of NCL to our Web site via a blog post. I think, if you read them, that you will agree with me that there is a lack of cohesion among the issues raised by the different members that submitted. That was why, in the end, it would have taken a Herculean effort to distill them into one set of comments. But I think it's worrying that while there are a few broad areas of concern shared by most members (support for low-level learners for example, clarification on ELL provisions), there was, as far as I could see, no single issue that was in fact shared by all. It's clear that there are also areas of disagreement on what the implications of these regulations mean. Members also raised a lot of issues not addressed by the state directors, who among all the groups focused on Title II, had the most exhaustive set of comments. And finally, I'm very worried about comments being submitted by groups about Title II that have less understanding and experience with Title II programs on the ground that NCL members do. All the more reason why I strongly recommend we continue to discuss the implications of WIOA in the coming months and try to better understand the differing points of view on several key issues. Thank you for your understanding. More tomorrow. Jeff _______________________________________________ National Coalition for Literacy Members mailing list Members@lists.national-coalition-literacy.org<mailto:Members@lists.national-coalition-literacy.org> To unsubscribe: http://lists.national-coalition-literacy.org/mailman/listinfo/members_lists.national-coalition-literacy.org Gail Spangenberg Founder & Managing Director Adult Learning Partners, LLC 440 East 23rd Street - Ste. 11c New York, NY 10010
ES
Emily Sheketoff
Tue, Jun 16, 2015 9:42 PM

Sorry it took so long, but here are the comments ALA filed on WIOA NPRM

From: Members [mailto:members-bounces@lists.national-coalition-literacy.org] On Behalf Of Jeff Carter
Sent: Monday, June 15, 2015 10:41 PM
To: National Coalition for Literacy Members List
Subject: [NCL Members] NCL Comments on the WIOA Draft Regulations

Members,

Greetings from a hotel room in NYC, where for the second time in six days I am stranded overnight due to plane cancellations.

All day today I have been sporadically attempting to take one last try at pulling together a set of recommendations on the WIOA draft regs to submit on behalf of NCL. Even my fallback plan, which was to submit a summary as an individual, and not on behalf of NCL per se (since it’s too late to get coalition approval on what I’ve been writing) is going to fall through.

We simply don’t have the capacity to what I was attempting, and it was a poor decision on my part to volunteer to try to do it by myself. I went through some of the members' comments with a very experienced colleague in government relations yesterday and was told quite frankly that to do what I was attempting to do would in their opinion take a full-time government relations relations staff person weeks to complete, working full time.

But I don’t think we should simply drop the matter and move on. Tomorrow as promised I will add links to the comments submitted by individual members of NCL to our Web site via a blog post. I think, if you read them, that you will agree with me that there is a lack of cohesion among the issues raised by the different members that submitted. That was why, in the end, it would have taken a Herculean effort to distill them into one set of comments. But I think it’s worrying that while there are a few broad areas of concern shared by most members (support for low-level learners for example, clarification on ELL provisions), there was, as far as I could see, no single issue that was in fact shared by all. It’s clear that there are also areas of disagreement on what the implications of these regulations mean.

Members also raised a lot of issues not addressed by the state directors, who among all the groups focused on Title II, had the most exhaustive set of comments. And finally, I’m very worried about comments being submitted by groups about Title II that have less understanding and experience with Title II programs on the ground that NCL members do. All the more reason why I strongly recommend we continue to discuss the implications of WIOA in the coming months and try to better understand the differing points of view on several key issues.

Thank you for your understanding. More tomorrow.

Jeff

Sorry it took so long, but here are the comments ALA filed on WIOA NPRM From: Members [mailto:members-bounces@lists.national-coalition-literacy.org] On Behalf Of Jeff Carter Sent: Monday, June 15, 2015 10:41 PM To: National Coalition for Literacy Members List Subject: [NCL Members] NCL Comments on the WIOA Draft Regulations Members, Greetings from a hotel room in NYC, where for the second time in six days I am stranded overnight due to plane cancellations. All day today I have been sporadically attempting to take one last try at pulling together a set of recommendations on the WIOA draft regs to submit on behalf of NCL. Even my fallback plan, which was to submit a summary as an individual, and not on behalf of NCL per se (since it’s too late to get coalition approval on what I’ve been writing) is going to fall through. We simply don’t have the capacity to what I was attempting, and it was a poor decision on my part to volunteer to try to do it by myself. I went through some of the members' comments with a very experienced colleague in government relations yesterday and was told quite frankly that to do what I was attempting to do would in their opinion take a full-time government relations relations staff person weeks to complete, working full time. But I don’t think we should simply drop the matter and move on. Tomorrow as promised I will add links to the comments submitted by individual members of NCL to our Web site via a blog post. I think, if you read them, that you will agree with me that there is a lack of cohesion among the issues raised by the different members that submitted. That was why, in the end, it would have taken a Herculean effort to distill them into one set of comments. But I think it’s worrying that while there are a few broad areas of concern shared by most members (support for low-level learners for example, clarification on ELL provisions), there was, as far as I could see, no single issue that was in fact shared by all. It’s clear that there are also areas of disagreement on what the implications of these regulations mean. Members also raised a lot of issues not addressed by the state directors, who among all the groups focused on Title II, had the most exhaustive set of comments. And finally, I’m very worried about comments being submitted by groups about Title II that have less understanding and experience with Title II programs on the ground that NCL members do. All the more reason why I strongly recommend we continue to discuss the implications of WIOA in the coming months and try to better understand the differing points of view on several key issues. Thank you for your understanding. More tomorrow. Jeff