Texas Commission on Special Education Funding – November 14, 2022

The Texas Commission on Special Education Funding met on November 14, 2022 to review draft recommendations and hear from panels on the SPED Educational Savings Accounts (ESAs). A copy of the agenda can be found here. An archive of this meeting can be found here.

This report is intended to give you an overview and highlight of the various topics taken up. It is not a verbatim transcript of the discussions but is based upon what was audible or understandable to the observer and the desire to get details out as quickly as possible with few errors or omissions.

 

Item 1: Call to Order

 

Item 2: Chair’s Opening Remarks

• Welcome to 7^th public hearing
• Discussion for this meeting is if ESAs designed for SPED students is something they would want to include in recommendations
• They will take an official vote on recommendations at their last meeting in December
• Huberty – in 2018 Commission they did not deal with Special Education formulas, please as they read through the draft recommendations that there are meaningful and real recommendations for special education formulas; hope is committee will vote specifically on special education formula funding and not policy driven like ESAs
• Gonzalez – thankful for recommendations created and in line with what Rep. Huberty said, consider what was the committee created for and what can they agree on that will be transformative or they could allow the process to be politicized
• Jetton – they have an opportunity today to shine a light on all the ways they can provide services to special education students, believes ESAs should be on the table and appreciates the opportunity for discussion

 

Item 3: Review of Draft Recommendations

Justin Porter, Associate Commissioner and CPO of Special Populations, TEA

• Non-formula based funding recommendations include evaluation cost offset, SPED educator stipends, and SPED certification grants
  • Grant should range from $25M per year to $100M per year
  • Stipends should range $1k to $2,500 per SPED educator
  • SPED certification grants range from $500k to $1.2M per year
• Non-formula based funding recommendations con’t:
  • SSES Program, waitlist funded at $100M and an increase of $15M per year to continue program
  • Grants to non-profits, 10-40 non-profits ($2M-$10M per year)
  • CCMR outcomes, increase the bonus $4k per student
• Non-formula based funding recommendations con’t:
  • Day placement program capacity should fund between 8-10 to 16-20 programs ($4M-$8M per year)
  • Residential and day facility cost regulation, adding transparency and allow TEA to set maximum rates at facilities, etc
• Non-formula based funding recommendations con’t:
  • SPED Educators Retire/Rehire, grant program to LEAs to help offset cost should range from $2M-$12M
  • Increase SPED educator pipeline, grow your own ($5M-$50M per year)
• SPED Formula Funding Recommendations
  • SPED transportation allotment for per mile rate increased from $1.08 to $1.28-$1.38 ($5M-$15M per year)
• SPED allotment formula recommendation
  • Funding model is comprised of 7 weighted funding tiers; intensity of service needs increase as one goes up the tiers and the weights increase; would eliminate the need for high-cost fund and residential placements; see slideshow for specific information regarding tiers
  • Estimates based on current data and conversations with districts shows that 56% of children would be in Tier 1; 11% in Tier 2; 3% in Tier 3; 12% in Tier 4; 17% in Tier 5; <1% in Tier 6; 1% in Tier 7
  • Estimated $100 M-$1.6 B increase per year (TBD by statue/GAA)
  • Timeline aligned with biennium; biggest hurdle is data implementation system; could begin as soon as legislation passes and would occur through August of 2024
• Funds flow roughly in the 2024-2025 biennium
• For a couple years LEAs would have to give both old system and new system data; strong sense that shift is necessary in special education and giving both types of data would be worth this
• Heard that assistant technology is very expensive but very helpful for some kids; annual funding for student could offset cost to district; some funding for a dedicated staff member for multiple reasons; half day funding for level 3 and full day for level 4
• Huberty- Would be important to include actual cost in report
  • Can provide what has been described as reasonable range but won’t be able to give definitive number because every IEP is so different
• Huberty- Thinking about who to include for salary; including paraprofessionals is important; SPED certifications grant aren’t permanent right?
  • No, sir
• Huberty- Would love to continue on those grants; think they are beneficial and should be highlighted to stand up dyslexia and autism programs
• Huberty- SES program waitlist question; seen roughly 9,000 families not able to access this even though they are eligible?
  • Yes, weight list of 7,000 right now
• Huberty- If we provide services to someone and it isn’t a one time deal we should be thoughtful about that demand with such a long waiting list; don’t want people to be told you already got you’re money and aren’t eligible again
• Huberty- On SPED transition allotment, my recollection on this is that the transportation cost wasn’t funded in HB 3 for a variety of reasons; don’t have a choice and must get a kid no matter how far; is there a different approach to pay for higher costs in rural communities?
  • No sir
• Huberty- Dyslexia allotment in tier 1 is not in lieu of other allotments for dyslexia; is important thing to address in report
  • Every child is put into a tier and then the funding groups are in addition to that and not every child is put into a funding group
• Gonzalez- Having a guarantee of number would be very helpful; should identify the priority funding, especially teacher funding or state that recommendations are not in priority order; range of cost is too big, should find a more suitable number

 

Item 4: SPEC Educational Saving Account

A: Panel 1

Prof Kevin G. Welner, Director at National Education Policy Center

• Vouchers are a harmful and misguided policy; don’t attach a lot of strings to taxpayer money; ESA model is described as a sort of debit card which is extremely unregulated; large body of research about conventional vouchers
• Outcomes for voucher recipients show uneven outcomes with changes in outcomes over the past decade
• Using a voucher in Ohio or Louisiana resulted in a negative impact on student math scores, much more than COIVD-19 pandemic and Hurricane Katrina; In D.C. and Indiana math learning losses that are less extreme; see link
• Some studies with positive results are very small and outdated; counting studies don’t include limitation studies, not reputable; no such thing as an experimental voucher study; lack of internal and external validity in these studies
• Majority of voucher users in some states have never attended a public school and vouchers subsidize tuition for students who already attend pricey private schools; see link
• Attainment studies have become more recent; tease out effect of vouchers on high school graduation rates and college attendance; most studied by voucher advocates and cherry picked for positive outcomes; problems with casual inference
• Competition studies have causal inference problems and not worth the paper they are printed on; few high-quality ones including one from Indiana with positive short-term impacts
• Problem with incentives in market aren’t always aligned with what we want in terms of public policy; for example, in charter schools incentives aren’t even and some schools try to avoid special education students because of the fiscal hit
• Bettencourt- Benefit in Texas is that we can design a program based on outcomes by ensuring bill is for switchers and not students already enrolled in private school
• Jetton- Any data on impact of vouchers for special education?
  • Issue that policies are designed to be extremely unregulated; lack of transparency with some report that there is misspent money; don’t have data to do a study on this
• Jetton- Not all SPED students are the same; they have different needs so if a parent has more than one school available to teach children wouldn’t it be good to have multiple ESA programs?
  • Tend to see that lawmakers have to struggle with tradeoffs including putting additional money into program to provide parents with wide range of options, but options are limited based on voucher amount
• Private markets don’t allow families protections
• Jetton- Parents that have special education students have to go through a long process and are in tune with specific needs of their children; if limiting factor is financials, is it not beneficial for child to have ESA to get education there?
  • Definite benefit for parents who know their children’s needs; if able to have data to study long term would see that educational outcomes have decreased based on numerous studies
  • Kids are not getting good educations through these vouchers
• Gonzalez- You said greater harm than COVID and Katrina when kids participated in voucher program; can you unpack that?
  • Outcomes with math are unexpectedly negative; don’t know exactly what is going on but expect that the quality of the private schools that are participating in voucher program and students are choosing is not very good
• Can regulate these policies better but have not seen any proposal for a voucher policy with protections like in the Individuals with Disabilities Education Act (IDEA), which does not apply to private schools

 

Laura Colangelo, Executive Director of Texas Private Schools Association

• Support idea of ESAs; approximately 50 accredited private schools that serve special education student’s exclusively; approx. 87% of all private schools serve students with special needs of some kind according to new survey
• Private school accountability to parents and to accreditation commissions which ensures education is equivalent to or greater than those in public schools
• Explains process of accreditation
• Individuals with Disabilities Education Act (IDEA) not applicable in private schools; parents and private schools reach agreement in enrollment contract
• Any legislation that includes parental choice needs to be specific with strings and requirements of IDEA considered
• Chart from Louisiana and Ohio are from states with the most poorly structured choice programs that regulate schools in inappropriate ways
• When talking with special needs private school heads they described they were eager to participate in this type of program if it passes
• Huberty- Comment on IDEA, you reference protection of parent when it is actually the student; concern because protection is for the student; would be thoughtful that IDEA needs to have place in legislation because money is sent to parents
• Huberty- Any requirements right now with Every Student Succeeds?
  • No, also don’t mean IDEA isn’t important, just that it is more relevant in public school context
• Huberty- Don’t know how many seats are available for SPED population?
  • No
• Huberty- Do you have a median income for private school families?
  • I don’t
• Huberty- Do you know enrollment of special education schools?
  • Roughly 5,000 students
• Huberty- Let’s say a student gets expelled; what is the procedure for a child getting an education?
  • There are other public and private school options; definitely a last resort situation
• Gonzalez- You said it isn’t relevant for IDEA to be in private schools, why?
  • Not appropriate setting in private schools; school has contract with parent to serve child’s needs
• Gonzalez- Knowing students with disabilities are more likely to have disciplinary actions brought against them, what happens when a contract is voided if the kid is kicked out?
  • Usually, a quarterly basis checkup for child to get funding if enrolled; wouldn’t keep the money if child is not enrolled
• Gonzalez- How many private schools have to partner with public schools for services?
  • Depends; there are third party therapists who come in through Child Find and help child in private school; all private schools are eligible for Child Find but limited by what school district can provide to child; interest varies across state
• Gonzalez- Would be good to see how many private schools use public school services
• Gonzalez- Any protections if a private school refuses to provide services to a child?
  • Every contract is different; contract says this is what we can provide your child; protections through IDEA is specific to public schools
• Gonzalez- In the private school system if we notice a student might have disabilities is there a requirement to test them?
  • Depends on school because every contract is different and stipulations established in enrollment contract are different
• Jetton- IDEA to ensure every student has access to public education; sounds like IDEA process is burdensome; what is like when a student comes to a private school with disabilities?
  • If school can’t meet the needs of the child, they will explain to family and not accept the students
• 25% of our private schools say that they are dealing with teacher shortage; special need schools aren’t having those issues because teachers get to work more with students because they don’t have burden of IDEA paperwork
• Bettencourt- What does your association think of rural areas with very few private schools?
  • Heads of school at accredited private schools near rural areas have some plans to plant micro schools in rural areas because of the voucher program if it passes
• TPSA would never support a bill that would harm public schools, quality improves in areas with school choice

 

*Panelists from other panels were moved up in the schedule due to time constraints

 

Dr. Veronica Alonso, Associate Superintendent of Catholic Schools at the Diocese of Dallas, Texas Catholic Conference of Bishops

• Catholic schools are good for communities not just Catholics; have rigorous accreditation that exceeds TEA expectations
• Each school has at least one dyslexia specialist
• Highlights Notre Dame School of Dallas that specializes in children with intellectual and developmental disabilities; groups student according to age and development within their age group; independent living and job skills highlighted in school
• ESAs would empower families with options and allow families to choose specific schools for specific outcomes and tools
• Some students not receiving services and have third party ready to provide services so hoping to meet needs quickly
• Would hire more learning specialist if have additional students
• 89% of schools identify serving students with special needs, 108 schools said 11% of students had special needs; many schools considering participation
• Catholic schools are an affordable option for special needs students

 

Cara Candal, ExcelinEd

• Vouchers and ESAs are not the same; first speaker made claims about ESAs that I believe are false; ESA administrators in many states that we work with have data on how families are using these ESAs; post-pandemic use of ESAs is changing
• Assumptions that people with access to vouchers are comparatively privileged; most ESAs are for means tested or special needs students
• ExcelinEd convened ESA administrator network two years ago and meet with them yearly; provides network of peer-to-peer support for best practices and to collect data and info on how programs work and make sure they are transparent
• Programs growing across the country and many states moving towards ESAs because parents are demanding these programs
• ESAs and microgrants can help create more diverse landscapes of private and public providers which show that surrounding districts in a competitive environment have better outcomes and more groups pop up in state over time to meet needs
• Texas already running highly successful microgrant program and has enrolled more students than all ESA programs in states combined and parent satisfaction is high
• Funding should be weighted, and state should continue to allow diverse and robust population of providers including public school districts; currently happening with great success in New Hampshire
• Chair Combest- Do parents have a restricted debit card and how do states monitor financial fraud?
  • Parent’s are awarded ESA and funds are put into account that state oversees and parent chooses service on state platform; the amount is then deducted from account; some scenarios where this is not the case and sometimes states send funds directly to private school
  • Providers are vetted and preapproved by the state on the state’s platform; some states require student portfolio of work
• Zaffirini- What is compliance rate and rate of fraud?
  • Fraud rates are very low especially with state platforms
• Zaffirini- Who determines if there has been misuse of state funds?
  • Sometimes the administrators or the education agency itself; usually a reporting and auditing process

 

Heide Nesset, Step Up for Students, Florida

• Family empowerment scholarship in Florida served 1500 students in 2015-2016 school year; substantial growth since then driven by parent demand
• This current year will serve 60,000 students with average ESA amount of $10,000; seen expansion of education service providers in Florida, driven by online market place that vets providers
• Many families are doing “a la carte” education services; utilizing funds for different therapies and purchasing educational devices
• Unique service offerings expanded such as license to provide part time tutoring services and micro schools
• On parent side ESA starts with determining eligibility with online application then work to fund scholarship accounts and ensure that each student is only in a single scholarship program
• Provider also goes through application process to ensure providers have appropriate credentials and providing services under statutory language
• Marketplace has guardrails to ensure that the programs are preapproved and can facilitate reimbursements and out of pocket spending
• Have parent advisory board to look at purchases and flag items such as laptops for additional documentation if purchase more than one in two years
• Programs are fully audited annually to ensure transparency in dollars spent

 

Paul Van Allen, Parent of a Special Needs Child

• Has seven-year-old son with down syndrome in first grade; difficult to find schools on internet to meet needs of students; reliance on word of mouth
• Able to send son to Rise school of Austin; only goes up to kindergarten
• Have been to three school districts in journey; good but limited resources and if you don’t have money are trapped
• With children who are non-verbal or limited verbally don’t get feedback of how the children’s’ days are

 

Kristina Baehr, Parent of a Special Needs Child

• Gives personal testimony about son being developmentally impaired due to toxic exposure and praises the Rise school that is an integrated school fir kids with development disabilities and also neurotypical children
• Had to borrow money to send children to Rise school and would have appreciated the ESA; will grade out of school next year and wish there were more options for his son
• Hope ESA will create an ecosystem of parents and educators starting special programs and allowing parents freedom to choose best school
• Jetton- How many parents are out there with the same needs as your family?
  • Van Allen- Word gets around by word of mouth; some resources not available for underprivileged
  • Baehr- Many parents at Rise School are in discussions about where to send their kids; would be helpful to hear from them
• Gonzalez- Resources y’all are discussing don’t exist in some communities that are more rural; some parents wouldn’t have ability to navigate the ESA system especially low-income and bilingual
  • Baehr- ESA being used for public schools would be very important; talk of program at Doss that will be integrated and look like the Rise School at Austin ISD
• Gonzalez- Thank you; also need to have diverse perspectives on this issue

 

B: Panel 2

Steve Aleman, Senior Policy Specialist at Disability Rights Texas (DRT)

• IDEA only applies in public schools and scope of the commission only applies to public schools
• IEP should include behavioral intervention plan
• For students with autism state requires above and beyond planning; not just about IDEA also about joining state law that goes above and beyond which disappears when you move to a private setting
• Systemic impact on public schools with ESAs is financial, believe every student with a disability deserves all of those dollars; problematic that there will be competition for these students
• Shouldn’t take expertise from public schools to private schools because it systemically undermines public special education
• From a macro standpoint ESAs pose many problems currently and ask that commission focus on their charge

 

Andrea Chevalier, Director of Governmental Relations, Texas Council of Administrators of Special Education (TCASE)

• Represent over 1,100 special education administrators and oppose taking public funds to private schools
• Members want accountability and are concerned with lack of rights that students and parents would have in a private setting; opens them up to discrimination and segregation
• Appreciate draft recommendations and the service intensity model; Will an ESA improve funding systemically?
• Variability in how programs advertise how students would have changes their rights going to private school and some have inaccurate information
• No blanket guarantees about what rights parents and students will have in private schools; many factors are unclear
• Lack of transparency and accountability because there is no public data on how the schools serve students with disabilities
• Would you want private schools to administer the STAAR, place cameras in classrooms, etc
• Peer-reviewed study about education privatization that focused on charter schools that shows that charter schools enroll less students receiving special educations services; students with more severe disabilities are underrepresented in charter schools
• ESAs could increase proportion of students with more severe disabilities in public schools as those with less severe disabilities go to private schools and charter schools

Jolene Sanders-Foster, Advocacy Director, Coalition of Texans with Disabilities (CTD)

• IDEA gives parents important rights such as nothing can be done without parental written consent and that parents can disagree; these empower parents
• Caution thinking numbers equate success, number of students on waitlists more indicative of need for funding in public schools
• Idea of cobbling together a program for a student is a lot harder than it sounds and not feasible for working families
• Provisions under IDEA for private placement and proportionate share
• Idea that more competition will be better but there’s been studies that when programs are adopted suddenly lower quality private schools rush to access the money
• Many families unaware that they will be relinquishing rights
• Commission should consider reconciling the ESA amount with actual cost of private services including additional costs such as enrollment fees and evaluation fees
• Limitations in terms of ages and performance assessments and IQ thresholds or diagnosis requirements even in private schools in big cities
• Private schools specifically for special education negates inclusion for special ability children
• Private schools don’t need to be accredited, have certified teachers, or have background checks; special needs children are at high risk for neglect and abuse
• Concern of confidentiality because private schools don’t have to adhere to FERPA and that records are released with parental written consent under limited circumstances
• Would like to see how many special needs children are able to retain placement in private schools
• Representation of people with disabilities is important; missing self-advocates with disabilities; ask that this group is asked about how they feel about this matter
• Gonzalez- The panel is saying there are real concerns about furthering ESAs for students with disabilities now and in the future, yes?
  • Aleman- I’ll add that this has been articulated by the national council of administrators of special education as well
• Gonzalez- Could you each provide one reason why this is not the pathway we should take?
  • Aleman- Charge to commission to improve special education funding in public schools should be the focus of the recommendations and report
  • Chevalier- It’s dangerous for student’s to not have protections
  • Sanders-Foster- Want students to experience inclusion which comes down to funding public schools
• Chair Combest- Clarified hearing the ESA topic based on case law and statute, they have 10 non-formula recommendations so just as grants can increase options then ESAs could serve as a possible educational service option
• Combest – the decision to have the discussion was not made lightly and does not feel this is out of statutory authority/charge of commission
• Huberty – intent of legislation as bill author was to fix the formula funding, understand discussion but intent was to address formula funding

 

Ezzard Castillo, Administrator, River City Christian School

• In State of Texas, they do finger printing and have to follow do-not-hire list
• Walks through process in his school, they serve as last hope and many students arrive with multiple diagnosis
• Provides an example of an autistic student in his school, who graduated from them and went on to community college
• Provides additional examples of student success stories
• They have a shoestring budget, only charge $11,500 per year, and teachers are underpaid but they are determined to not let students fall through the cracks

 

Steve Wells, Southland Baptist in Houston

• Has students and families both in public and private schools
• Discusses a student he knew that was on the waiting list for years
• Personal story of his son having debilitating migraine headaches and panic attacks
  • They put his child in a private school and the school disenrolled his student and did not refund the tuition
  • Have no redress for financial loss
  • Houston ISD put a team of people around his son and got him through high school
  • Son graduated from Baylor and is gainfully employed today
• “Give public schools $11,500 per student and watch what will happen,” they will change the world
• Should tax dollars support a certain religious private school, why not fully fund every public school and every need
• Huberty – legislature is going to have these discussions, agrees special education was underfunded, there is a balancing act
• Huberty – once had caps and did not fund special education, now having a meaningful discussion on it

 

Panel 4

Tracy Bailey, Executive Director of Special Education for Aldine ISD

• Against ESAs for several reasons
• Number of students served in special education has increased but funding is not commensurate
• Aldine ISD provides a continuum of services
• Private schools do not have to abide by the state accountability standards
• Against ESAs, will take away funds from an already strained program
• Funding should be provided so all students can have the best service possible

 

Gwen Coffey, Assistant Superintendent for Special Education for Katy ISD

• They are significantly underfunded for Special Education
• Work with community to support them
• Works in a highly regulated system, private sector is not subject to the same regulations that are in place in public school
• What would be due process system if ESA doesn’t work and how will we ensure students get services
• Public education has promoted and shared details on micro-grants, public education does child find to help locate and identify students
• There is a staffing shortage, lack of educators and support personnel
• Don’t put so many constraints on the public education system where it is broken entirely

 

Jennifer Green, Research and Accountability for LaPorte ISD

• No private schools locally around their district
• No guarantee a parent could find a school of choice with ESA, may be a better fit for those parents that could move or transport their child
• Member on virtual – money could also be used for limited transportation, books, etc; thoughts
  • Anything a student uses to access FAPE is provided already
• Gonzalez – any thoughts on transformative use of funding?
  • Coffey – put money into public education, “we will see most band for buck”
  • Green – public schools all in competition to recruit highly qualified individuals
• Member joining virtually – if we had funds, could provide truly what students need, like the idea of tiered funding models

 

Dr. Benjamin Scafidi, Prof. of Economics and Director of the Education Economics Center at Kennesaw State University

• ESAs more flexible than vouchers or scholarships
• 32 states have education choice programs, 14 of these states have choice programs targeted to special needs students
• Points out Ford signing statement in 1975 which include funding levels not possible
• “IDEA sets up an inherently adversarial relationship between families and public schools”
• Argues ESAs give families an “exit” option
• “The feds initially promised they would fund 40% of the cost of educating special needs students. They never have.”
• Argues not as many lawsuits on a special needs voucher vs all choice programs
• ESAs allow for the ability to choose smaller settings or different settings
• Studies on effects of education choice – https://www.edchoice.org/research-library/?report=the-123s-of-school-choice-2#report
• No study finds private school choice harms graduation rate, 25 studies that show academic benefits from school choice
• 68 out of 73 studies find positive impact of school choice programs
• Argues ESA awards could be made equal to state enrollment driven funds per special needs students
• Argues district gets to retain funds for students they no longer serve (dollars not FTE-driven, most federal funds, all locally generated funds)
• Argues “students who remain in public schools have MORE resources devoted to their education”
• Florida’s McKay Scholarship program student showed satisfied parents – https://www.tandfonline.com/doi/abs/10.1207/S15327930pje8101_3
• Combest – what is different between ESA and voucher?
  • Voucher can only be used to offset tuition payments, ESAs can be used for other state approved educational services

 

Michele Barba, Policy Director for K-12 Education at The Texas Public Policy Foundation

• Walks through slides presented to the committee
• Three topics in slide deck, current situation in Texas, Florida situation and then principles they recommend
• Given students in special education, anticipate 80% performing on grade level but currently only 20% of special education students are on grade level
• Summarizes Texas funding model and adds students in each of the various educational settings
• Florida funds special education as a service, not as a setting
• There are 8 categories of expenses funds can be used for which include: college, curriculum, instructional materials, public services, specialized services, testing, private tuition, and tutoring
• Noted slides show parents customizing education for students and rural families have more frequent and customized purchases
• Principles they recommend include:
  • special education is a service, not a setting
  • empower families to support unique needs and abilities
  • consider data from Supplemental Special Education Services program
• Combest – asked about waitlist, 7k is for what is needed now and not an interest list?
  • Yes, believes so
  • Huberty – believes it was oversubscribed, thinking its 9k that would be interested
  • Huberty – do they fully fund the waitlist and then for ones that got funded is there continuation of funding
  • SSES has an indefinite waitlist, so student may not be eligible by the time funding opens up so suggest a regular application period
  • Will check on homeschool process for curriculum
  • Jetton – asked about college savings
    • Research shows small percentage using fund for 529
  • Bettencourt – waitlist reason is clear, substantial amount of students on autism spectrum
  • Bettencourt – if you applied the Florida model to Texas, any opinion on the size of the population that would need to be addressed
    • SSES is much larger
  • Huberty – waiting list is no longer 9k but 17k
  • Huberty – Florida’s data is comparable to ESA, supplemental education services program we now have that now has 17k waitlist and a supplement to services they are already receiving may not match
  • Bettencourt – confirms waitlist would be 72k in Texas
    • 72k served by SSES
  • Huberty – asked for Florida numbers, special education population and those using the program…guesses about 10%
    • Does not have that number
    • Bettencourt – numbers need to come from TEA, programs will have overlap
  • Huberty and witness discuss the various populations in programs, witness will also pull the numbers he has

 

Closing Remarks

Chair Combest – thanked everyone for testifying, next time they will take up language for recommendations, can be submitted and voted at next meeting in December sometime in week of the 12^th