Montana is formally rejecting the U.S. Department of Education’s offer for more flexibility under the No Child Left Behind Act, declaring that it doesn’t make “educational or financial” sense to apply for a waiver.

In a letter to U.S. Secretary of Education Arne Duncan, Montana cites the costs involved with implementing the “unfunded” requirements that accompany a waiver. State schools’ chief Denise Juneau also points out that by the Education Department’s own estimates, it would take her small office 336 hours to complete the waiver application. [UPDATE, 12/12, 11:58 a.m.]: Thanks to the eagle-eye Politics K-12 reader who pointed out that Montana got some important NCLB leeway back in August when the federal department allowed them to change their proficiency targets so that fewer schools failed to make AYP. In the short term, at least, this made a waiver less important for Montana.)

California officials also appear poised to reject the waiver offer, also citing costs.

So far, 11 states have applied for a waiver, with more than a dozen scheduled to submit their plans by a second-round Feb. 21 deadline. (See map below.)

Juneau said in her letter, which was also signed by organizations representing the state’s administrators, teachers, and school boards, that she didn’t want to embark on something that would be overturned by Congress when it reauthorizes the Elementary and Secondary Education Act.

And lastly, Juneau laments that Duncan didn’t make a much more simple waiver offer: that states be allowed to freeze their academic targets at current levels until Congress rewrites NCLB.