April 26, 15
Dear Deputy Commissioner Tangorro, Jr. and Deputy Commissioner D’Agati,
Re: Proposed Amendments to Section 80-4.3 of the Regulations of the Commissioner of
Education Relating to the Supplementary Bilingual Education Extension, and
Section 80-5.18 of the Regulations of the Commissioner of Education Relating to
Supplementary Certificates for English to Speakers of Other Languages (ESOL)
I am an ESOL teacher in New York State. I was duly certified under the existing regulations. I
am opposed to the proposed amendment for Section 80-4.3 of the Regulations of the
Commissioner of Education relating to the issuance of the Supplementary Bilingual Education
Extension and Section 80-5.18 of the Regulations of the Commission of Education relating to
the issuance of the Supplementary Certificates for English Speakers of Other Languages
(ESOL).
These amendments are being made in response to the concerns of school districts that fear that
they may not be able to comply with Section 154-2 of the Commissioner’s Regulations which
establishes standards for English language learners beginning with the 2015-2016 school years.
Under Section 80-4.3 of the Commissioner’s Regulations certificated teachers are allowed to
obtain a supplementary bilingual education extension. Regulation 80-5.18 allows certificated
teachers to obtain a supplementary certificate in English as a Second Language to obtain a
supplementary certificate. This certificate requires six semester hours in the content area of the
certificate and six hours in literacy.
I feel that the needs of the English Language Learners (ELLs) must be considered, first and
foremost, when proposing changes to the teacher preparation programs. Educational decisionmaking must be driven by data. The data demonstrates that these learners are struggling, even
under the guidance of qualified, fully certified and licensed bilingual and ESL teachers. Allowing
teachers who are not appropriately trained in second language teaching methods, linguistics,
and cross-cultural issues, to teach our ELLs will further impede the progress of these learners.
With respect to the ESOL supplementary certificate, the State is also presenting two additional
pathways to the Board for its consideration. Candidates who have satisfactorily completed the
ESOL CST and who have taken or are enrolled in a three credit course in teaching English as a
second language at the elementary or secondary level would be eligible for the ESOL
supplementary certificate. The candidate would have three years to complete the remaining
coursework, which includes three additional semester hours in methods of second language
teaching in the elementary and secondary grades, and six semester hours of coursework in
teaching literacy skills.
Pathway II allows a candidate who has achieved a satisfactory level of performance on the
ESOL CST to submit evidence of having two years of satisfactory experience teaching English
to speakers of other languages in lieu of the coursework requirements in methods of second
language teaching in the elementary and secondary grades, and in teaching literacy skills. The
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candidate would have three years to complete the balance of the currently required coursework,
as outlined above.
The recommendation further specifies that these additional pathways for the supplementary
bilingual education extension and the ESOL supplementary certificate be available for a threeyear period, to conclude on June 30, 2018. If an extension of the time period for these changes
becomes necessary, the State will make a subsequent recommendation to the Board to extend
the availability of these pathways prior to expiration of these changes.
The above proposals are not the answer for the shortage of qualified Bilingual and ESL
teachers. Teachers who are to work with our ELLs must be highly qualified and competent in
lesson plan designs that meet the variety of needs our ELLs have, from those with interrupted
formal schooling to those with age-appropriate skills in their home languages. Qualified teachers
will understand the role the first language and culture plays in the development of the second.
Qualified teachers will understand the difference between academic literacy and social,
communicative competence in the new language. In fact, in my opinion, the present proposed
pathways will slow the progress of our ELLs by not providing them with teachers who are aware
of the latest research-based instructional strategies, the development of content and language
goals, and the adaptation of the Common Core Learning Standards. It is simply impossible to
amass all this knowledge from a 3-credit, or even a 6-credit course.
I believe that more effective ways to increase the number of duly-certified Bilingual and ESOL
teachers is to work with universities to develop programs to offer content area certification to
provide ESL/BE teachers through content-specific course work. Also, universities should be
offering courses to provide certification to ESL/BE teachers to become ELA and Early Childhood
Education certified. Some districts may develop partnerships with local universities to expedite
these courses. Incentives should be considered for teachers to enter the ESL/BE field by
tuition-reduced courses of study.
Sincerely yours,
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