Consider reverting to the pre-2007 endorsement requirements for ESL. During that time-frame, individuals who completed an academic major in ESL were considered eligible to be hired. Now, even with a major, unless the person has the required 24 semester hours, one could be considered ineligible for the endorsement and cannot be hired without requesting a waiver from the DOE. Considering the difficulty in finding qualified ESL teachers, making this revision would be a small but needed change.

At the same time, should the DOE keep the changes now listed in the proposed regulations, I would also recommend that rather than counting the six semester hours required for reading as content course work, you would make those six semester hours a professional studies requirement thereby reducing the content requirements to 18 semester hours. This would be in line with the reading requirements for both elementary and special education.