Comments

with Staff Replies and Recommendations on School Library Programs - Standards and Guidelines for Texas, Proposed Sections 4.4 - 4.7


General Comments

Commenter strongly supports the standards and sees them as support to prepare students to handle the glut of information available in various formats. She states that the Acceptable level is reasonable, while higher levels are ideal and give schools something to strive to attain. "To dismiss the standards as costly, unnecessary, and/or a burden is and would be a great disservice to our students."

Commenter stated that she found the ‘acceptable’ standards to be reasonable and should be attained by schools that wish to educate information literate students. "The fact that some find them too stringent or too expensive is an indication of the degree to which library services to students have been neglected in the past." She further states, "I do believe that if each school library in the state were to attain the ‘acceptable’ level, we would have a library program second to none in the country."

Commenter feels that rating library services as "exemplary," "recognized," and "acceptable" will be confused with TEA’s accountability rating system.

Both advisory committees recommended paralleling the TEA system because it was already familiar to school staff. The SBOE Committee on Instruction supported the use of parallel terminology and indicated their interest in having TEA to look at ways to incorporate library programs into the accountability rating system.

Commenter states that the proposed standards are a step in the right direction. She cites the case of a small school district near her district that has only para-professional staff running their libraries. Staff called upon her to answer simple questions.

Commenter supports the proposed standards and states that with the growth in information technology support and funding of libraries is necessary to deliver information to students. Although her district is considered to be one of the best in the state, the proposed standards are already helping them make gains and provide a course to follow.

Commenter states his opposition to a school campus library rating system. He feels that this action will be interpreted by the public as mandatory and will result in effect as an unfunded mandate on schools. He supports and recommends minimum standards for materials, volumes, and services but questions the need for a certified librarian on every campus. His reasons include that his district has raised student performance in the past three years without a certified librarian. With limited funds for salaries and a shortage of certified librarians in rural areas, rural districts that have the desire to increase staffing will never have the resources. Action by the Commission "may provide the legislative advocates of elimination of small school districts with further justification to close small and rural schools to the devastation of small towns and communities."

Minimum standards have typically been interpreted by many districts as being enough. Four levels permit flexibility for local citizens to determine the quality of service they want to or can provide, while at the same time providing a yardstick for improvement. Library programs are more than just the materials—qualified staff is needed to teach students how to use library resources and inspire children to read and enjoy literature. There is a shortage of certified librarians in Texas, but that shortage will never be reduced if standards do not encourage having appropriate staff available for students. For the three schools in the commenters district, each would be required to have a librarian, but only the elementary school would have to have a para-professional (.5) to be considered acceptable. "Acceptable" was deemed by both advisory committees to be "minimum" standards. Research demonstrates the role libraries play in educational achievement; while short-term gains may be made without sufficient and appropriate staff, long-term gains come only with appropriate support.

A commenter questioned the use of the word "support" and cautioned that "In school settings sometimes ‘support’ equals subordinate."

This comment was written based on a presentation on the proposed standards. Within the standards, support is used in the context of "support staff," "funds to support," and "materials to support." The commenters concern seems to be that the standards be a tool to elevate the general opinion of librarians and that library use and teaching of library skills be seen as an integral part of the school program. This concern is addressed throughout the standards.

Two people are concerned that the standards are titled as being for "school library services." They are concerned that use of the word "service" has the connotation of being "an add-on" or "support" program. They recommend that the title for the standards be "School Library Programs: Standards and Guidelines for Texas."

The word "service" is used exclusively within the legislative mandate and so was used in the development of the standards. "Program" describes more accurately the pro-active role of the school library.

Staff recommends changing the title of the regulations to


"School Library Programs."

With regard to the standards, a commenter stated, "In a time when some states are weakening their support for quality school libraries, it would be a signal to the rest of the country that Texas continues to move forward in providing exemplary public education. Another commenter stated that she is "interested in keeping the standards for Texas’ school libraries up. If education in…Texas is to get better, we must maintain high expectations for school libraries."

Commenter stated that her library would probably never meet the standards to be exceptional but that a high standard would provide her with a fixed direction and a reason to push harder. She stated, "Exceptional standards must be difficult to reach—otherwise we can continue to pat ourselves on the back for achieving uniform mediocracy."

Commenter addresses concerns that the standards are unfunded state mandates. She states, "It is difficult for me to see that these standards are unfunded mandates any more than the proposed TEKS or the Texas Reading Initiative." She also states that, "If we develop standards which everyone believes they can afford, we will be aiming for the lowest common denominator."

Commenter stated that the standards would help the elementary schools in her district tremendously because of wide discrepancies between schools.

Library Learning Environment

Commenter indicated support for strong language in favor of flexible scheduling and access for all students.

Another commenter indicted support for the clear descriptions of the learning atmosphere described in the standards.

One person stated that "flexible scheduling is great for the larger districts, but presents a problem for small districts like my four schools as the library aide is pulled out for other duties and I am circulating among four school districts not just schools within one district." She indicated that until there is more money for library personnel or until it there are sanctions for not meeting the standards, smaller schools will not comply.

The standards call for at least one full-time staff member in every school library. Even a "below standard" library with less than 350 students must have a full-time para-professional. The standards do not support having one librarian cover several schools or multiple districts. A library that is below standard limits access to scheduled times because of lower staffing levels. Flexible scheduling is needed to permit curriculum integration and library use at the point of need.

Commenter indicated support for strong language in favor of flexible scheduling and access for all students.

Another commenter indicated support for the clear descriptions of the learning atmosphere described in the standards.

One person stated that "flexible scheduling is great for the larger districts, but presents a problem for small districts like my four schools as the library aide is pulled out for other duties and I am circulating among four school districts not just schools within one district." She indicated that until there is more money for library personnel or until it there are sanctions for not meeting the standards, smaller schools will not comply.

The standards call for at least one full-time staff member in every school library. Even a "below standard" library with less than 350 students must have a full-time para-professional. The standards do not support having one librarian cover several schools or multiple districts. A library that is below standard limits access to scheduled times because of lower staffing levels. Flexible scheduling is needed to permit curriculum integration and library use at the point of need.

A librarian expressed concern about extending library services. Her contract is for a specific number of days and her clerk would have to be given comp time to stay after school. She is concerned about scheduling problems.

The standards recommend extended hours on a regular basis at the Recognized and Exemplary levels. These could include electronic access to resources or physical access to the collection. At the Acceptable level extended access is recommended on an occasional basis, such as during exams or when research papers are assigned.

Curriculum Integration

A person stated that "Incorporation of and support of the model…by school districts would be a giant step toward appropriate utilization of school libraries and librarians." She expressed concern that "lack of compelling counsel against the use of librarians" to cover teachers’ mandated planning periods, "as well as TSLAC lack of power to enforce these standards…leads me to suspect that very little will change."

The standards address the use of librarians to cover teacher planning periods by stipulating that students must have access to staff at the point of need, by promoting flexible scheduling, and by recommending curriculum integration. These practices can not occur if librarians are covering teacher planning periods.

Resources

Commenter requested clarification as to the difference between entry level access to the Internet and real time access. Her superintendent wants the library to meet the Exemplary criteria within three years.

This commenter was reading from a draft which did not include definitions. Real time access is defined in the final draft.

A person stated that his district would need $330,000 for staffing just to meet the acceptable level of library service. He feels that the standards are not realistic and will not be given serious consideration.

This district has a total operating budget of $44 million. Acceptable staffing levels call for one certified librarian at every campus except the largest and from .5 to 2 para-professionals, based on campus size. For students to know how to access and use information, staff must be available throughout the instructional day.

Another commenter also expressed concern about the additional cost for staff and materials to meet the acceptable or recognized levels. While conceding that libraries need more staff and materials, he pointed to other pressing needs schools face (classroom space, salary increases for teachers, improved services for disabled students). He stated that they simply cannot afford to do it all. A related concern was that his district has limited district-wide positions and the community would rather concentrate funds on students and teachers rather than on district-level mid-management positions. Providing para-professionals to support library work would not be looked on favorably by teachers, who are not provided assistants. He recommends dropping guidelines for the highest levels and reducing district-wide and para-professional requirements. He also suggested that the Commission set a price tag for the standards and lobby the Legislature for full funding.

Good service and qualified staff do cost. The standards provide descriptions of levels of service. That the district and community have to make decisions about how limited dollars will be spent does not obviate the value of high standards. Teachers certainly would benefit from having aides in the classroom, and many do; but librarians deal with every student in the school and juggle a variety of responsibilities and tasks throughout the day. Para-professional staff in the library allows the librarian time to assist teacher.

A comment was made concerning the definition of "selection policy." The person feels that while the definition is correct it should go further and state that this policy is "developed by library staff and approved by the school board."

The definitions provide meaning to words and phrases that may not have meaning to the general public. Prudent practice supports having all policies endorsed by the governing authority but do not have to be by definition. Indeed many libraries have selection policies that have never been reviewed by their governing authority. The standards specify, "district-adopted, board-approved selection policies" for all levels except "below standard." A library that is below standard may still have a selection policy but it may not have been approved by the governing authority.

Commenter indicated that she was sorry that the standards do not make the recommendation to purchase one new book per year per student and to have an amount of money equal to the average cost of a new book for audio-visual items.

Research does not support using the cost of a book as the basis for funding. With increased use of technology and networked information sources, it is difficult to state unequivocally that the library should purchase one new book per student every year. The standards were developed to allow local flexibility to meet local needs which may vary from year to year.

One person asked for an explanation of the difference between electronic resources and software. She also wanted to know if videos would be considered as part of the collection since they are not included in "books, software, and electronic resources." Other questions pertained to how discs in the Accelerated Reader program and whether having a full-text periodical programs such as EBSCO would reduce the number of periodical subscriptions needed.

"Software" is considered by most people to include videos and other audio-visual material such as cassettes and recording as well as computer programs. The Accelerated Reader is a tool for determining whether or not a student has read a book; as such the discs provide no information and would not be counted as a resource. The standards call for access to a full-text periodical database at the "recognized" and "exemplary" levels. These databases offer substantial support for student research but do not eliminate or reduce the need to have hard copies of periodicals for browsing, leisure reading, and current events. A range is given for subscriptions to adjust for local need based on school size (where multiple subscriptions to the same title may be needed) and for other available resources. With a full-text periodical database available, hard copies of periodicals are generally considered ephemeral and should be available for current use rather than relied on for research.

Commenter feels that the staffing levels for certified librarians and para-professional staff are directed towards employment opportunities. The commenter recommends that the standards be revised to assure that every campus is supervised by a certified librarian rather than directing numbers of staff to be employed.

Schools in most areas of the state typically have more school librarian positions available than can be filled. Typically, students in Texas Woman’s University’s school library program have jobs prior to completing their studies. It will be difficult to for most districts to meet staffing levels for certified librarians until more librarians are available. Para-professional staff is available and is needed so that the certified librarian can perform the professional functions set forth by the standards. Supervision of a campus library by a certified librarian does not ensure that every student has access to professional services throughout the instructional day. Many certified librarians currently "supervise" three or more campuses, leaving the daily management to para-professional staff. Curriculum integration and cooperative planning of learning activities can not be carried out if the librarian is on campus only a day or two each week.

Commenter expressed concern about staffing levels. She indicated that faculty will expect exemplary output from library staffs, but administrations will fund lower staffing. She recommends that a campus of 701-1050 ADA should be staffed by 2 certified librarians and 2 para-professionals to be considered recognized and by 1 librarian and 2 para-professionals to be acceptable. She urged the Commission not to acquiesce to pressure from school administrators and school boards.

The commenter addressed added duties that are placed on the librarian, such as monitoring the reading lab and being responsible for students so that teachers can have weekly planning days. While additional staff would be the ideal, both advisory committees put their first emphasis on having every library staffed full-time throughout the instructional day. It will be a major accomplishment for most schools to staff according to the recommendations in the standards. The standards also address having "appropriate professional and support staff to facilitate access and equity for all learners." A school that assigns additional duties outside the library or beyond the scope of traditional library services should fund staffing levels beyond the recommended levels.

One commenter questioned the funding formula. Based on the definition of instructional budget, her library materials budget would be less than $1.50 per student at the acceptable level. A second person also commented that based on the definition she would receive only $5.86 per student where she currently receives approximately $12.22. Similar comments received from (2) other persons. One person recommended providing a range (3% or $20.00 per student whichever is higher).

The definition of "instructional budget" should be amended to include salaries for instructional staff. Based on calculations performed by this commenter and others, including salaries in the base for calculation results in a more accurate and acceptable figure.

�4.1 Definitions

Staff recommends changing the definition of instructional budget to read, "Generally would include all funds budgeted for salaries and related expenditures associated with classroom teachers, aides, and assistants, and funds allocated for the purchase, lease, or acquisition of supplies and materials, reading materials, workbooks, general supplies, supplies for media and technology, consumable teaching and office items, audio-visual materials, library books and media, and other items necessary for the instruction process and/or for administration of instruction." Because it is difficult to write a definition that includes all possible sources of funds and budget codes, documents being developed to interpret and implement the standards will include per student benchmarks for materials against which the percent of funding can be validated.

Commenter supported the library as the place for central access to resources as a means of avoiding duplicate purchases and saving funds. She stated that while the Internet is a good source of information, much of the information is indiscriminate. Teachers are using the library more frequently as part of classroom instruction and linking their subjects to library resources that are centrally available.

Another person expressed concern that the amount of funding suggested, although clearly a minimum level, would not be sufficient to bring a below standard library’s collection up to the recommended size. She suggests that we might state more clearly that the proposed funding levels are for maintenance of a collection that has already reached the recommended size.

The commenter does not make a recommendation to correct this deficiency. The standards says that a "below standard" library has a collection of at least 7,200 items and has funding of less than 1% of the instructional budget to purchase materials.

�4.7. d ( 3 ) ( B )

Staff recommends that the percentage of funding for a below standard library be revised to read, "receives minimal funding, but not less than .5% of the total instructional budget annually,…." This ensures minimal funding to maintain a collection.

Library Program Management

Commenter expressed concern that "standards should reward efforts to increase accessibility of library resources and information for school children." His concerns addressed partnerships with, and support from, other agencies.

The standards do support partnerships. Formal partnerships with public and academic libraries and participation in resource sharing programs (ESCs, Texas Library Connection, ILL) and electronic connectivity will be addressed in interpretation documents that explain how to count items available to students.

Commenter supported staffing levels based on enrollment and noted that in every other area of campus staffing, people are allocated in terms of enrollment (as the campus grows more counselors, custodians, vice-principals, etc. are added). She questioned why no similar adjustment is made in library staff especially since librarians are expected to be more involved in teaching activities on campus. She also stated that because of site-based management decisions the most at-risk students and students in year-round classes are routinely short-changed by the use of unqualified and non-degreed staff who run libraries in these alternative schools.

�4.4 ( d )( 1 )Based on a comment from an advisory board member, staff recommends that the roles of the district level staff (Director/Coordinator) be strengthened to include "interprets national, state, and local standards, and recommends or establishes policy." (Also change appropriate phrasing in other level programs.)

�4.5 ( 4 ) ( C ) Staff recommends correction of an error noted. At the Exemplary level, "Funding" recommends that learners have access to a certified librarian at all times during the instructional day and some access beyond. At the Recognized level, the standards might be interpreted as recommending increased access by stating that learners will "have adequate access during and beyond the instructional day…." Staff recommends rephrasing this sentence to read "will have adequate access to a certified librarian and support staff during the instructional day and some access to staff beyond the instructional day."

Page last modified: March 2, 2011