The Language Opportunity Coalition strongly objects to the proposed regulation 603 CMR 31.07 that establishes the award criteria for the State Seal of Biliteracy. We ask the Board of Education not to approve the regulation in the current form.

1. The proposed award criteria do not follow national guidelines for proficiency levels for the Seal of Biliteracy.
2. The proposed award criteria for English proficiency based solely on 10^th grade ELA MCAS scores will inequitably exclude English learners, former English learners, and other students.
3. The proposed award criteria do not allow English Learners the same amount of time to develop language proficiency as world language learners: Proficiency in English has to be demonstrated in 10^th grade, while proficiency in a world language does not need to be demonstrated until 12^th grade.
4. The proposed award criteria do not implement the multi-tiered award structure developed by the Massachusetts Seal of Biliteracy Pilot Project to promote and reward long term and sustained language study.

The award criteria defined for the Massachusetts Seal of Biliteracy Pilot Project (2014-18) were designed to be a motivational and inclusive award that recognizes the language attainment of as many students as possible. Our goal in supporting establishment of the Seal of Biliteracy is to 1) support and reward long-term and sustained language study of English, native languages, and world languages, and 2) recognize and reward the linguistic assets that multilingual students bring to our schools. The proposed regulations will exclude many students, especially students whose native language is not English.

The LOOK Act requires that the Department consider national standards and the local work of the Seal of Biliteracy Pilot Project in developing criteria for the award. Massachusetts is in a unique position because we can learn both from the local three-year Seal of Biliteracy Pilot Project and from emerging research on implementation of the Seal of Biliteracy nationally. We ask that the Department consult with the Language Opportunity Coalition and members of the Seal of Biliteracy Pilot Project to revise the regulations to ensure equity and opportunity for all students pursuing language study.

View the Coalition’s full public comment submission on the LOOK Act regulations, including the Seal of Biliteracy.

Comment is open on the proposed regulations until May 18. See these links to give public comment.