Regarding the proposed amendment to 8VAC20-390-80 (Rules Governing Division Superintendent of Schools), please know that as a superintendent of a large school division, the petitioner’s request would impose an unnecessary burden on the Office of the Superintendent, the Division, the Virginia Department of Education, and the taxpayers of the Commonwealth.

Documenting each visit to my schools, with notations for the date and time of the visit, including a summary of the visit, would be improbable, if not impossible, given the realities of my responsibilities.  With 93 schools I could be documenting a half-dozen or more visits a day, or very few at all, as my responsibilities vary from minute to minute and day to day.  Please know that I am in touch with our staff, and in one or more of our schools, on a daily basis. In fact, since becoming Superintendent in 2005, I have visited every school each year because I am highly supportive of maintaining a high visibility with staff, students, and parents.

Furthermore, to retain such information, and then submit same to the Department of Education on an annual basis, constitutes not only an unfunded mandate, but a document retrieval and retention nightmare. Additional bureaucratic constraints and forms would not enhance my ability to make school visits.

Please do not hesitate to contact me if you have questions I might answer.

I encourage you to reject this petitioner’s request.