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As the U.S. Department of Education prepares to fine-tune its , officials face objections from many states, school districts, and teachers鈥� unions that the federal government is seeking to apply a one-size-fits-all approach to its education improvement efforts.

But Secretary of Education Arne Duncan isn鈥檛 likely to budge from his strong stance that this $4 billion in coveted discretionary aid is his lever to push states toward what he calls common-sense reforms. Chief among them: using data to track students and improve their achievement; spreading uniform, rigorous academic standards across states; improving teacher quality; and turning around the worst-performing schools.

鈥淲e鈥檙e just saying that there are some fundamental building blocks. How you get from A to B will be different. We expect a lot of variation among states,鈥� Mr. Duncan said in an interview at the department today.

He disagrees with critics who say the 鈥攚hich will be doled out through a strictly voluntary competition鈥攊s too prescriptive. Rather, he said, 鈥渢his is a way of challenging the status quo in a much more tough-minded way.鈥�

Still, he has asked all of his senior staff members to read some of the formal public comments submitted about the proposed Race to the Top Fund regulations so they can get a feel for how the education community has reacted.

During the 30-day comment period on the proposed rules, which ended Aug. 28, the department received on 19 criteria by which states would be judged, from how friendly their charter school climates are to how they reward good teachers. For a time, the proposed regulations made it onto the 鈥淲hat鈥檚 Hot鈥� list on the , ranking among the top 10 most-visited filings.

The Race to the Top program is an education reform competition for states made possible by $4 billion from the $787 billion economic-stimulus package Congress passed in February. Details are still pending on a separate, $350 million grant competition through the Race to the Top Fund to help states鈥� efforts to adopt common assessments.

Joanne Weiss, the department鈥檚 Race to the Top Fund director, said her team will make any needed changes in time to have the final regulations issued by early November. That鈥檚 also when the department expects to outline the scoring rubric that will explain how much weight the different criteria will receive. The department hopes to award the first of two phases of grant money to states early next year. (鈥溾�楻ace to Top鈥� Guidelines Stress Use of Test Data,鈥� July 23, 2009.)

Wide Spectrum

The comments submitted by individuals and organizations range from those cheering the Education Department鈥檚 principles for school improvement to those who say its approach is overbearing.

鈥淭he primary concern is the overall prescriptive nature of the guidelines, including rigid definitions and the emphasis placed on charter schools as the major tool of innovation,鈥� wrote North Carolina Gov. Beverly E. Perdue, a Democrat, on behalf of her office and several education organizations in her state.

However, the message from the Rodel Foundation of Delaware, which supports its state鈥檚 public schools, was this: 鈥淗old the line. ... [T]his historic opportunity cannot be weakened by the whims of politics.鈥�

While the vast majority of commenters said they support the overall goals of the Race to the Top program, each of the 19 criteria seemed to draw its share of critics鈥攁long with those who felt their interests were not represented at all.

For example, more than a dozen comments came from representatives of arts-related organizations, accusing the department of leaving their subject area out of the mix. State officials from Colorado and Kentucky, along with foundations such as the Pew Charitable Trusts, are encouraging the Education Department to ask states to integrate early learning and pre-K programs into their Race to the Top applications.

Some of the most heated comments focused on the department鈥檚 effort to improve teacher effectiveness, such as emphasis on merit-pay plans for educators and alternative routes to teacher certification.

The heavy-hitters from the national teachers鈥� unions weighed in: The 3.2 million-member National Education Association, for example, came out in opposition to core elements of the criteria. (鈥淣EA at Odds With Obama Team Over 鈥楻ace to the Top鈥� Criteria,鈥� Sept. 2, 2009.)

Meanwhile, the 1.4 million-member American Federation of Teachers declared that the Race to the Top initiative 鈥渨ould simply layer another top-down accountability system on top of the current faulty one.鈥�

But some of the strongest criticism came from local union affiliates, who especially objected to the emphasis on charter schools and merit pay.

The Massachusetts Teachers Association, an NEA affiliate, described the 19 proposed criteria this way: 鈥渂ureaucratic, top-down, one-size-fits-all requirements: tight on goals and tight on methods.鈥�

Eric Feaver, the president of the Montana Education Association-Montana Federation of Teachers, a merged affiliate of the AFT and NEA, went so far as to say: 鈥淚f such criteria remain, MEA-MFT will do everything in our power to insist that Montana does not apply for these funds.鈥�

Other groups, however, felt the criteria didn鈥檛 go far enough toward improving teacher effectiveness.

Amy Wilkins, the vice president of government affairs and communications for the Washington-based Education Trust, which advocates on behalf of low-income and minority students, pointed out in an interview that existing law already seeks to make states and school districts distribute their highly qualified teachers more equitably among schools that serve disadvantaged and minority children.

But Ms. Wilkins said little has come from what鈥檚 already on the books. Since it may take a couple of years for states and districts to follow the department鈥檚 urging and set up systems that will allow them to measure teacher effectiveness based on growth in student achievement, she said, states should be required to show that they are making good on the language about equitable distribution of teachers that鈥檚 already in the No Child Left Behind Act.

鈥淲e are driving toward using effectiveness as the measure, [but] we aren鈥檛 there yet,鈥� Ms. Wilkins said in an interview. 鈥淚n the meantime, are we going to sit on our hands and let these kids be taught by the poorest teachers?鈥�

Flexibility, Transparency

While many of the comments focused on the broader school improvement issues entangled in the Race to the Top program, common themes on some of the finer points of the criteria emerged, too.

States and education groups are curious about whether, if they win a grant, they can award a portion of their Race to the Top money to a select group of school districts, or if they have to dole out money to all of them. State officials said they may be interested in directing part of their Race to the Top money to groups of districts where they believe the most good can be done.

In illustrating how important definitions are, many states, special education advocacy groups, and even U.S. Rep. George Miller, the California Democrat who chairs the House education committee, object to proposed language about how states should measure achievement for special education students. The criteria call for using students鈥� individualized education programs, or IEPs, as a gauge for measuring their achievement in nontested subjects. Critics pointed out that IEPs are meant to set goals, not to measure student achievement.

Several organizations that operate outside state governments wanted to hear more from the Education Department about how the competition will encourage accountability and transparency.

The Coalition for Student Achievement, which represents more than 80 education groups that organized to monitor the use of education aid under the American Recovery and Reinvestment Act, as the stimulus law is formally known, wants the department to post all of the state applications online, even before they鈥檙e approved. And the Bill & Melinda Gates Foundation wants the department to hold back some of a winning state鈥檚 grant money as leverage to make sure the state delivers on its reform plan.

Sometimes, the Education Department鈥檚 criteria don鈥檛 jibe with an ongoing effort. A case in point: the push by the National Governors Association and the Council of Chief State School Officers for common academic standards nationwide. (鈥�46 States Agree to Common Academic Standards Effort,鈥� June 10, 2009.)

Those two Washington-based groups, plus several states, noted that the timeline for states to adopt common standards is far more aggressive in the department鈥檚 criteria than in the agreement reached by states. The states agreed to adopt standards within three years; the federal criteria call for them to be adopted in just one year.

The department鈥檚 criteria also call for standards to be 鈥渋dentical鈥� across states; the states have agreed that it鈥檚 sufficient if 85 percent of their standards match.

Several state officials also converged around a complaint that the documentation required for the Race to the Top application could be too burdensome. For example, many objected to requiring that a state鈥檚 attorney general sign off on the interpretation of state laws used as evidence for meeting a criterion.

Education chiefs in Florida and Massachusetts suggested, as an alternative, that each state education department鈥檚 chief legal counsel could do that job more quickly. The governors鈥� association thinks the attorney-general requirement should be removed altogether.

Tug of War

The comments also reveal a power struggle over who in the states should control their Race to the Top applications and reform plans.

The proposed federal criteria call for a state鈥檚 governor, chief state school officer, and state school board president to sign off on the state鈥檚 application. The NGA said that some governors object to the inclusion of the state board president, saying that would have the 鈥減otential to limit gubernatorial prerogatives in proposals.鈥�

The Arlington, Va.-based National Association of State Boards of Education argued for keeping its members鈥� place at the table, since they 鈥減lay an integral role in developing and implementing state education policies.鈥� Meanwhile, the Denver-based National Conference of State Legislatures wants state lawmakers to be required to assent to the plans.

What鈥檚 more, the criteria seek to judge states on how much support their reform plans have from the community, including local school districts that plan to participate in Race to the Top-financed initiatives. The Education Department wants to see a memorandum of agreement with each participating district.

But Larry LeDoux, the commissioner of the Alaska Department of Education and Early Development, wrote that while community support is crucial, going so far as to require letters of support may 鈥渟quelch reform.鈥�

He wrote: 鈥淪ometimes the unintended consequence of consensus where accountability is concerned is mediocrity.鈥�