The Orange County School Board opposes the petitioner’s request to change the wording of 8VAC20-390-80 and requests that no revision be made to the current language of the regulation.  The Orange County School Board believes that the local school board, and not the Commonwealth, should determine if the superintendent should engage in the detailed act of documenting his or her fulfillment of the duty described in the regulation.  The Orange County School Board believes very strongly that the superintendent is accountable to the local school board for any such activity.  Therefore, the Orange County School Board also opposes the petitioner’s request that local superintendents forward any record of such activity to the Virginia Department of Education.  The petition seeks an unnecessary expansion of state government authority.  Furthermore, the petition is impractical in large school divisions where the superintendent’s fulfillment of the expected duty depends heavily on his or her administrative designees.  The Orange County School Board asks the Virginia Board of Education to reject the petitioner’s request.  – Judy Carter, Chairman, Orange County School Board