Can’t get enough of public comments about proposed accountability rules under the Every Student Succeeds Act? We’ve got you covered.

This week, we’ve highlighted several commenters from key groups that have weighed in on the draft ESSA regulations covering accountability. But of course, we didn’t have room in that story to touch on all the notable organizations that have shared their thoughts with the U.S. Department of Education through June and July. So we’re serving you another helping of comments.

And let’s note that since we compiled noteworthy comments on the proposed ESSA accountability rules on this blog earlier this month, the number of comments published has grown and now tops 21,000. So, way to go, ESSA commenters. Now, on to some more comments:

National Association of Elementary School Principals, and National Association of Secondary School Principals: The two principals’ groups say they’re concerned that “several proposed regulations will stifle this landmark movement towards greater state and local flexibility” that ESSA represents to them. They also say that while they support the draft rules’ requirement for using at least three performance levels to judge schools, the law’s emphasis on gathering multiple measures of schools’ performance and the draft regulations’ requirement for a single summative score are contradictory.

“Taking the multi-metric approach and then producing a single summative score for each school goes against the notion of robust accountability systems that the law is [prodding] states to create,” the two groups state. (The department disagrees with this, by the way, saying that requiring three performance levels for school performance by extension requires summative scores for each school.)

NAESP and NASSP also urge the Education Department to assist schools in helping flesh out definitions of student growth, which the groups say should be an important consideration for accountability under ESSA.

National PTA: On the issue of parents opting their children out of standardized tests and how states should respond to districts with low test-participation rates, the national parents’ group doesn’t level direct criticisms at the department for being too heavy-handed or prescriptive. Instead, the PTA stresses the important information assessments can provide and how low participation rates can hurt students and schools. The group does, however, think states should take the lead in such situations.

“It is essential that states in conjunction with parents and other stakeholders are empowered to design and determine the interventions and supports for schools and school districts that do not meet the required participation rate,” the National PTA states.

The organization is pleased with the department’s proposed rule that school district report cards be developed after consulting with parents. Like several other groups, however, it believes schools should have more time as they transition to new accountability systems and methods of identifying struggling schools.

Vermont Secretary of Education Rebecca Holcombe: In the first of her two submitted comments, Holcombe identifies several problems her state has with the draft rules. She says the way states must categorize school performance is too narrow as defined by the proposed regulations, and shouldn’t include a requirement for a single summative score for each school. And the draft rules for opt-out, she says, don’t make much sense, even when they provide options for states to deal with the issue.

“The options outlined by USED are the equivalent of assigning a student a zero for a test when they are caught plagiarizing; yes there needs to be a consequence for the lapse, but linking it to performance leads to a misidentification of the school’s performance level,” Holcombe wrote.

In the second of Holcombe’s submitted comments, she says the new reporting requirements for state and local per-pupil spending figures aren’t really feasible for her state at this time. The reason? Her state has a unique system for governing schools that does not lend itself well to disaggregation of school finance along the lines the department requires.

“Vermont intends to seek a waiver of this provision given the information shared above. Other states will likely find themselves in a similar situation as the accounting procedures and data collection required to comply do not yet exist, and expending limited resources on poor data analysis is inefficient,” Holcombe wrote to the department.

Dignity in Schools: Noting that it opposed ESSA to begin with, the advocacy group that works to end the school-to-prison pipeline and improve disciplinary policies for various students and school environment says the department must spell out more clearly what states must do to include school climate in reporting and accountability systems.

“We urge the Department to provide more guidance by requiring states to define school climate and safety and use multiple means of measuring outcomes,” the organization says.

Dignity in Schools also says that states should be required to make LGBT students a separate subgroup whose performance is factored into their accountability systems.

National Indian Education Association: The NIEA joins with the National Council of La Raza in telling the department that states should set a maximum timeline of five years for students to reach English-language proficiency.

The organization states that the minimum number of a particular group of students at a school for that group of students to be included for accountability purposes should be lowered. The ESSA draft rules don’t mandate a minimum number for this requirement (known in wonk-speak as “n-size”) but does say that states wishing to use a number larger than 30 have to explain to the department why they want to do so. NIEA says this threshold should be low because Native students in many schools would be left out if the “n-size” is 30 or larger.

And along similar lines, NIEA says it supports the department’s approach to test participation.

“Native students often make up less than 50 percent of the students in a school and often have been ignored or overlooked in evaluation of school performance. Making sure Native students in every school receive the instruction they need to achieve requires knowing how well they are progressing in meeting state standards,” NIEA states.