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Mandatory Volunteerism

Posted by Jim Stergios February 25, 2012 03:13 PM

mandatory volunteerism.jpg

The last decade has seen an explosion in the number of middle and high schools mandating volunteerism. I am not a fan of forcing volunteerism, and “mandatory volunteerism” offends those who treasure meaningful language. But within a set of courses and activities aimed at rounding out children so that they will become effective participants in civil society, such requirements may make sense. That is especially so if students can choose the volunteer program and not be restricted to school-approved activities. Choosing what you are passionate about is critical to being a good citizen.

Clearly, such mandates are not things we impose on adults. Which is why it is so disconcerting to see the federal department of education treat state and local education leaders like children.

Way back in 2009, when U.S. Education Secretary Arne Duncan announced the Race to the Top competition, it was couched in closely scripted remarks about how this was a voluntary competition that would not upend 200 years of history around state and local primacy in education policy. Even as he saluted former North Carolina Governor Jim Hunt in June 2009 for supporting "common national standards when it wasn't politically popular," Sec. Duncan extolled the federalist system:

I am continually struck by the profound wisdom underlying the American political experiment. The genius of our system is that much of the power to shape our future has, wisely, been distributed to the states instead of being confined to Washington.

Our best ideas have always come from state and local governments, which are the real hothouses of innovation in America.

That hymnal was clearly distributed to national and local partners, with the National School Boards Association, Achieve, Inc., the National Governors Association's lobby and other fellow travelers who made a point of employing words like “state-led,” “voluntary,” and “partnership” to counter suggestions that the feds were driving the effort. Anyone who questioned how long this representation of intent would last was relegated to the realm of overly dramatic, a kvetcher, or a conspiracy theorist.

We are now on the second and perhaps third act of this piece of theater. In round one, legislatures made affirmative choices to expand charter schools. In round two, states only got funding if they complied with federal definitions of reform and innovation; and in all but five cases without legislative action and, frankly, without legislative awareness. Round three has the federal government directly funding the development of national assessments that explicitly come with curricular materials and instructional practice guides.

And now a number of states are getting antsy. The photo-op public announcements of federal grants long past, we are now into implementation—and state legislators are facing a rude awakening. Only now are they hearing about the mediocre quality of the national standards, the as-yet-undefined assessments, the imposition of curricular materials, the never stated costs, and the possibility that this whole effort actually breaks three federal laws. Only now are they recognizing the potential political mess to come with the feds' establishment of definitions of proficiency.

The great innovators inside the Lyndon Baines Johnson Department of Education Building did not take kindly to the barrage of reports on the mediocre quality of the national education standards (1, 2, 3, 4). Nor did they take kindly to reports showing that they are breaking three federal laws by directing and funding the development of national tests, curricular materials and instructional practice guides. A recent report that implementation of the national standards and tests will cost $16-plus billion (90% of which will come from states and localities) didn't sit well with them either.

In addition to the lagging time to grasp the real policy questions before them, the past three years have brought a sea-change in the political landscape. The 2010 elections changed the make-up of state legislatures dramatically, with a greater number of fiscal conservatives who look warily at unfunded federal mandates and overreach. With the new conditions, never approved by Congress, that Sec. Duncan is advancing, there is a growing realization among state legislators that the national standards are not truly voluntary. Even a stalwart supporter of a big USDOE like Mike Petrilli of the DC-based Fordham Institute recognizes that with the No Child Left Behind waivers Sec. Duncan:

seems compelled to attach mandates to his forthcoming NCLB waivers that will require adoption of the Common Core standards.

No, his team won’t mention the Common Core, but everybody knows that’s what he’s talking about when he calls for “college and career-ready standards.”

Fearful of stoking a backlash that will "lose many of the states that have already signed on," Petrilli in his blog is reduced to begging Sec. Duncan not to overreach:

Walk away from this one, Mr. Secretary. Please, those of us who support the Common Core are begging you.

That's a rather unbecoming act for a citizen in a free republic: We don't generally like begging our federal officials. That is in fact something state legislators abhor.

Unsurprisingly, there are state officials who are running for the exits. Hearings have been held in Indiana and South Carolina on bills that would prohibit implementation of the national standards and tests. More bills are working their way toward hearings in other states, as a number of state legislators and governors are showing the audacity to question whether national standards and assessments are actually a good idea.

In Indiana, notwithstanding former Bush budgetmaster and sitting Governor Mitch Daniels' support for Common Core, the legislature is insisting on a study of the cost of implementation:

Members of the Senate Committee on Education today unanimously approved a resolution authored by Sen. Scott Schneider (R-Indianapolis) urging a more in-depth study on Common Core State Standards and the impact on Indiana's nationally recognized education benchmarks.

In some states, both governors and legislators are asking questions--and even reaching a position of opposition. For example, in South Carolina, prior to an education subcommittee hearing on S.604, a bill that would prohibit the state from implementing the national standards and tests, Governor Nikki Haley took the bold step of calling for the state to pull out.

My testimony to the subcommittee drew on reports on the lack of quality, the cost and the illegality of the national standards and assessment project. But I also made one additional important argument, which is built off of the fact that South Carolina has been recognized as having the best U.S. History standards in the country. South Carolina and other states that choose to exit the national standards should not simply say no. They could draw from Texas’ efforts:

Consulting with top academicians in the U.S. and taking note of Singapore’s much-vaunted standards, Texas re-designed its state standards. Today, Texas not only has excellent English standards but also has among the best math standards in the country—far stronger than the Common Core.

South Carolina has rigorous US history standards and high-quality state standards. Saying “no” to Common Core is a matter of good judgment—but I would urge you additionally to use the opportunity of this debate to move forward with positive improvements to the Palmetto State’s standards and assessments.

States must aim higher than Common Core. Common Core aims at community college readiness, and that is not good enough for Massachusetts--and not going to make the U.S. internationally competitive.

As Catherine Gewertz of EdWeek noted, the bill "got voted down in a state Senate subcommittee, but was still going to move on to the full education committee."

But US Ed Secretary’s reaction to the South Carolina legislature’s and the governor’s actions was instructive. The day after the subcommittee vote, Sec. Duncan issued a formal statement on the happenings in South Carolina, which Gewertz described as "swipe" at the Palmetto State and "designed to dismantle support for the proposed legislation":

The idea that the Common Core standards are nationally-imposed is a conspiracy theory in search of a conspiracy. The Common Core academic standards were both developed and adopted by the states, and they have widespread bipartisan support.

Noting that states must stop “dummying down academic standards and lying about the performance of children and schools,” he accused the Palmetto State of “lower[ing] the bar for proficiency in English and mathematics faster than any state in the country from 2005 to 2009."

You could analyze the secretary's formal statement for style points, such as

  1. Why didn’t Sec. Duncan ask a surrogate to make such a statement rather than personally get involved? Previous secretaries would certainly not have been so heavy-handed.

  2. Who writes the secretary’s releases? “Dummying down”? They don’t teach that at Harvard, so I am going to guess it’s a Chicago-ism. And does the secretary hope to convince state legislators toward a course of action by berating them as if they were little children?

But there are two important, substantive conclusions to draw from the secretary’s broadside.

  1. The secretary is, in essence, accusing South Carolina of cooking the books on student performance. As Jay Greene notes, that is factually inaccurate, and the secretary is either ignorant of state practice or his is shading the truth to suit his argument:

  2. South Carolina did significantly lower its performance standards between 2005 and 2009. But they did so because they had earlier raised those performance standards to well-above the national average. In the end, South Carolina had math and reading performance standards that were close to the national average and close to the NAEP standard for Basic.

  3. It’s unseemly for the secretary of education of the federal government to make a formal statement about a legislative proposal related to education standards in the state of South Carolina. That is especially true if Common Core is truly a state-led effort. More directly: if all this talk about state-led standards is true, why is the U.S. Secretary of Education flying off the handle when a single state expresses interest in pulling out? As CATO’s Neal McCluskey put it, "Apparently, if you try to undo something the feds want you to do, they’ll slap you around until you confess they’ve never threatened you."

The feds want Common Core really bad. This is mandatory volunteerism of the worst kind. It is a power play that is advancing a mediocre product, with high undisclosed and unfunded costs for states and localities, and it is illegal. Those are three really big strikes against it.

But worst of all, it treats states like children. However critical I can be of education leaders in our and other states, I cannot see a record of any accomplishment by the so-called adults in Washington that compares with the demonstrated gains in Massachusetts, Florida and many other states.

Crossposted at Pioneer's blog. Follow me on twitter at @jimstergios, or visit Pioneer's website.

Are School "Turnarounds" Just Spin?

Posted by Jim Stergios February 22, 2012 10:23 AM


The waiver from the federal No Child Left Behind Act will, as noted yesterday, have a number of effects, with three big ones being:

  • It moves the goalposts for accountability back years (at least 2017, more likely 2024) and weakens the accountability goal (from proficiency for all students to making progress on the achievement gap)
  • It gets rid of all of the law's school choice and parental options, which were to kick in after a number of years of continued school failure
  • It centralizes innovation and change strategies in Malden (the world HQ of the state department of education)

The first effect listed above is a simple punt on accountability. But the last two bullets mark a move away from empowering parents and reinvigoration of the state's education bureaucracy. It also lots of questions:

If parents are not empowered in the process, where will accountability come from? After all, if the state is the great innovator and also the keeper of accountability (the accountability office now directly reports to the education commissioner), why would the bureaucracy feel any pressure? They define the terms of the debate and the solutions.

There is also the question about whether central bureaucracies can ever really "innovate." Innovation comes from competition and new ideas that often take on conventional wisdom. Digital was unable to innovate from the inside and therefore it was replaced by other computer companies, etc. There is a lot written on the topic, and I guess the educrats are too busy to look at such research.

US Secretary Arne Duncan has ignored this as well, considering DC as the driver of innovation in the states, on standards, testing, instructional practice, curricula, and teacher evaluations. He has staked his claim to be an innovator on his work in Chicago, when he was Superintendent of Chicago Public Schools.

And for the most part, he and the state education bureaucracies who are working with him, have advanced the view that they can "turn around" schools and districts from central offices. I've noted the research on the absolute paucity of successful turnarounds before, but if thought it is worth sharing recent research that is focused on Duncan's own home town and its record with school turnarounds:

One day before Chicago School Board members vote on whether to “turn around” a record number of flagging schools, a new study emerged Tuesday that dumped on the results of the city’s major turnaround vendor.

About 33 neighborhood schools with at least 95 percent low-income students not only outscored equally poor schools cleared out of all staff and “turned around’’ by the Academy for Urban School Leadership, but even beat the city test score average, the study by Designs for Change indicated.

And the neighborhood schools did so without the average $7 million per school in funds and facility improvements over five years given the typical AUSL school — and with far less teacher turnover, the study said.

As the Chicago Sun-Times notes:

The analysis ranked 210 city neighborhood schools with at least 95 percent low-income students, based on the percent of students passing their 2011 state reading tests. It found that AUSL placed only three schools among the top 100 — Howe (53rd), Morton (84th) and Johnson (88th). AUSL’s lowest scorer was Bethune, at 199th. Two CPS-run turnaround schools — Langford and Fulton — came in 150 and 206th, respectively.

Often, the study found, neighborhood schools outperformed equally-poor AUSL turnaround schools located only a few miles away. For example, in the South Shore neighborhood, Powell came in No. 14, while AUSL’s Bradwell was No. 194.

Massachusetts will see in Lawrence Public Schools if somehow we will prove the exception and find a way to get the schools there on a strong path toward improvement. The state has taken over the schools in Lawrence and is crafting a central plan for lots of turnaround activity. Will it work? I really hope so, but given the data so far, and there's lots of it, the turnaround supporters frankly are just spewing a lot of spin.

It would be far smarter for the state to give parents more charter options, create an additional vocational-technical schools that operates autonomous of the district structure, and interdistrict choice options.

Funny how empowering parents has, unlike turnaround strategies, a very good empirical record.

Crossposted at Pioneer's blog. Follow me on twitter at @jimstergios, or visit Pioneer's website.

Moving the goalposts on NCLB

Posted by Jim Stergios February 20, 2012 05:14 PM


Massachusetts and nine other states made news last week by seeking and receiving waivers from major provisions of the federal No Child Left Behind Act (NCLB). The law was never a favorite of mine but I think the way it was upended and why says a lot about the centralizing worldview of federal and state policymakers.

First thing is to separate process and substance. The process on the waivers is wrongheaded—and likely illegal. Stay tuned for more on that. On the substance, US Department of Ed Secretary Arne Duncan outlined the key requirements he wanted Massachusetts to fulfill, on standards (what Sec. Duncan calls college- and career-readiness standards), instruction and leadership, and accountability.

On standards, Massachusetts met the feds’ requirement by adopting new national standards and national assessments in July 2010. No news there, and not good news given the mediocrity of the Common Core national standards (if you’re interested in a good pro and con conversation on Common Core, read this.) Massachusetts met the feds’ requirement on teacher evaluations by adopting statewide regulations on evaluations in June 2011.

The real story on the waivers is about accountability and the education establishment’s antipathy to school choice in any form. NCLB touched on a number of aspects of school life including school safety, communication with parent and teacher qualifications, but at its core was accountability. It never changed state standards, nor did it focus on input requirements (how much to spend, how specifically to teach, etc.). Instead, it relied on accountability to drive its ambitious goal that ALL children would be proficient in reading and math by 2014. It required testing students in reading and math in grades 3-8 and one high school grade.

Here’s a short list of why the waivers are not a great step forward for schoolkids and parents when it comes to education and accountability:

Will the new accountability system work? We have no idea.
With the waiver in hand, Massachusetts will now unify state and federal requirements regarding school and district accountability and assistance through a new five-tier system. The state’s education department will from summer 2012 classify schools and districts

in one of five accountability and assistance levels. Schools meeting their proficiency gap closing goals will be placed in Level 1, schools not meeting their gap closing goals will be placed in Level 2, schools with the largest proficiency gaps for student subgroups and for all students will be placed in Level 3. The state’s lowest performing schools will be placed in Level 4 or 5. Districts will be placed in a level based on the performance of their lowest performing schools.

Will it work? The new Massachusetts accountability system is at best a work in progress. The Bay State used to have a tough state accountability office for schools, but that was shuttered for all intents and purposes in 2008. There’s not been a full-blown district accountability report (covering teacher evaluation, curriculum development, professional development, building upkeep and maintenance, use of data to inform decision-making, student performance by subgroup, etc.) since 2009.

Proficiency for all students is not the same as making progress in closing the proficiency gap.
AYP was a problematic construct but its goal was clear and its provisions were clear. AYP required that ALL (100%) schoolkids be “proficient” (by state definition) by 2014. Each year until 2014, district and charter public schools had to make improvement toward that goal. AYP looked at overall school outcomes, but it also forced districts to break out performance and meet AYP targets for subgroups: Asian & Pacific Islander, Black, Hispanic, American Indian, White, Free/Reduced Lunch, Special education, and Limited English proficiency. (The subgroups had to have 30 or more students to be included.)

The Massachusetts waiver sets a different bar – and it is lower. In its application, Massachusetts promises that it will give districts 6 years to cut the number of students not at grade level in half. Not only does that move the goalposts back time-wise but the state’s press announcement states:

Targets will be differentiated for each school, district, and subgroup based on its starting point in 2010-11.
In lay terms, that means that some districts get treated differently from others.

AYP was a tool that sought to change how schools did business, but schools don’t want to change how they do business.
Schools not meeting NCLB’s AYP goals for

  • two consecutive years were to give students an opportunity to transfer to a higher-performing district school

  • three years were to offer students tutoring and other supplemental services, as well as school choice options

  • five years had to take tougher steps like replacing school personnel or extending the school year

And since the start of NCLB, districts and schools have been very reticent (and in most cases hostile) toward any of these actions. Most of the outside sought by districts has been focused on central office-driven solutions.

Moving away from clear consequences for schools has put the state education department in the driver’s seat, but do they have any destination in mind?
Massachusetts DESE insists that the change will allow it to focus its “most dramatic interventions where they are most needed.” I’m not sure the department is any good at this. In fact, as noted in this blog before, few interventions across the country have actually made a longterm difference. We are about to find out very fast, with the state’s takeover of the Lawrence Public Schools, whether something has magically changed.

The state’s menu of interventions (expanded learning time, fixing long-broken professional development, and wrap-around social services) is not very promising in terms of empirical record. And its process-heavy description of why it needed a waiver does not bode well either.

At one time NCLB provided useful feedback on district and school performance


Under NCLB's original goal – 100 percent proficiency for all students by 2014 – rising federal targets resulted in far too many schools and districts being identified as in need of improvement to enable the state to effectively identify those in greatest need of assistance or intervention.

You could read that last sentence as stating for the umpteenth time that NCLB was okay until it started to bite. But it also underscores that the state believes that its own technical interventions are what will fix our schools. That is a very different mindset from what I consider a strength of NCLB. Rather than thinking that bureaucrats (the state department of ed) will reform bureaucratic systems (our districts), NCLB gave safety valve choices to parents who were in districts that were failing to meet the law’s goals. The idea behind that was to ensure that we adults don’t simply push back the goal posts whenever big goals promised at big press conferences get pushed back.

It is no surprise that the department’s press release clearly states that “Massachusetts will no longer mandate NCLB school choice and supplemental educational services.” I get that NCLB was not working, but I also get that this waiver is not a step forward.

It’s the usual goal-post shifting we have come to expect in education.

Crossposted at Pioneer's blog. Follow me on twitter at @jimstergios, or visit Pioneer's website.

Racking up Talking Points

Posted by Jim Stergios February 18, 2012 05:08 PM

At 6'5", U.S. Secretary of Education Arne Duncan is known for being up to a foot taller than most policymakers and bureaucrats. I am sure you've all read of his close friendship and basketball sessions with the president.

Jon Stewart on tiptoes is 5'7" (have it from a reputable site!). But in Duncan's Thursday night appearance on the Daily Show, Stewart was like junior sumo sized wrestler Mainoumi running rings around Kotonishiki. Stewart clings to lots of old nostrums, but he was by turns more practical, grounded and uplifting in his conversation with Arne Duncan about education policy, No Child Left Behind, Race to the Top, and the nationalization of decision-making in education.


Stewart clearly hears a lot from his mom. She's a teacher and her much doted upon son delivers his jabs at Duncan with the cunning of Macaulay Culkin protecting hearth and home from (dumb) interlopers in Home Alone. She doesn't like NCLB, RttT and standardized testing, and the conversation deliciously exposes just how wooden and worn the former Australia league pro's talking points are.

The Washington Post's Valerie Straus noted how disjointed and stiff Duncan was in responding to Stewart:

Jon Stewart tried to engage Education Secretary Arne Duncan on “The Daily Show” Thursday night, but the effort was an exercise in the futility of conversing with someone who won’t deviate from his talking points.

Calling him programmed is kind. Look - I am a supporter of high quality academic standards and testing, but they are accountability tools that were meant to leave teachers broad range in how they got the results. Secretary Duncan is trying to pull all power to the center, not just on accountability but also in evaluations and teaching practice. If you think I am kidding consider the instructional practice guides and curricular materials being developed by the two national consortia in charge of creating national tests.

Duncan suggests that his one-size-fits-all-states strategy will foster creativity and innovation. He claims he wants to stop teaching to the test. Hmmm.

File under dorky, disconnected, and in need of a teleprompter. I don't know how Duncan did in Australia, but right now the only points he's scoring are talking points. He seems to have no idea what impact his policies are having and will have well into the future.

The Daily Show With Jon StewartMon - Thurs 11p / 10c
Arne Duncan
Daily Show Full EpisodesPolitical Humor & Satire BlogThe Daily Show on Facebook

Crossposted at Pioneer's blog. Follow me on twitter at @jimstergios, or visit Pioneer's website.

A halfhearted school budget

Posted by Jim Stergios February 4, 2012 11:05 AM


You know you’re in for trouble when a school district with major graduation and dropout rates problems announces a new budget and leads with the hiring of five new nurses. That is not the definition of urgency.

The big new Boston budget of $856 million came with big headlines about more nurses and an overhaul of Roxbury’s Madison Park Vocational Technical High School. $856 million for about 54,000 students. That breaks down to almost $16,000. Of course it does not include additional funding sources and is not the complete picture. Last year’s NCES estimates pegged Boston as the most expensive urban school district in the country, clocking in at around $21,000 per student.

There is an obvious problem with the results we are getting. You don’t have to believe that “everyone has to be a college graduate” to see that a system that gets less than a third of its students to be truly college ready and that graduates 64 percent of its freshman class is in trouble. A study in 2008 showed that among 50 urban districts Boston was well behind many of its peers. San Jose and Nashville had graduation rates of 77 percent, Virginia Beach and even Sacramento outpaced Boston. We were clumped together with districts like Fort Worth and Houston (two districts whose numbers reflected the admittance of New Orleans transplants after Katrina.

Since 2008, when our graduation rate stood at 57 percent, we have seen steady but very slow progress. 2011 data shows that

Of the students who entered high school in the 2006/2007 school year, 63.2% graduated within four years. This 2010 data is an increase of 1.8 percentage points from 2009 and more than 5 percentage points since 2007. BPS calculates the dropout rate fell from 6.4% in 2009 to 5.7% in 2010.

That’s good news but hardly anything to crow about. It means Boston, Massachusetts’ district schools rank right up there with Memphis district schools on graduation and that we’ve gone from a 26 percent dropout rate to a 23 percent dropout rate.

So here are my takeaways on the new budget:

  1. It still does not reflect a change in the school selection zones and therefore expends far too much money on transportation rather than actually educating kids.

  2. More nurses can be helpful but their presence has little impact on improving students’ academic outcomes. And the simple fact is that when your budget announcement underscores the hiring of five nurses as a major victory, the real story is a lack of vision and leadership.

  3. The overhaul of Madison Park Vocational Technical High School strikes me as falling in the “as yet undefined” category. On the face of it, it is tepid. A strong proposal would have allowed Madison Park to function as an autonomous school, much like the regional vocational technical schools that have performed tremendously since the early 2000s (and have incredibly low dropout rates). But superintendents are by definition incapable of giving up control of portions of their fiefdom.

  4. The emphasis on turning around underperforming schools will allow a few gems to shine, like Up Academy, which really seems to have turned the school in a new direction. But the ability to replicate that level of focus is extremely limited. The charter model, which does not require the same level of involvement from all the institutional players and, you know, is by now proven on a consistent basis, is a far better way to go. I am not mentioning here the less interesting turnaround efforts—which do not bring the level of talent seen at Up Academy.

  5. The superintendent’s plan includes extended day at two middle schools, funded by foundations and driven by Chris Gabrieli’s work at Mass 2020. In writing about this, the Globe’s Jamie Vaznis notes that “The schools hope to replicate the success of the Edwards Middle School in Charlestown, where an extended day has helped boost test scores and has offered students more enrichment opportunities.” That is devoutly to be wished for. What Vaznis and others often don’t mention because Chris Gabrieli is a terrific person and of really good will is that the data on Extended Learning Time is that the record of success is not that great. (A recent Abt Associates three-year review of ELT noted "no statistically significant effects of ELT after one, two, or three years of implementation on MCAS student achievement test outcomes for 3rd, 4th, or 7th grade ELA; 4th, 6th, or 8th grade math; or 5th or 8th grade science.")

The pace of improvement is faster in many other cities, including Washington DC and New Orleans. You can note that they started out below Boston, but Boston, Massachusetts has to aim higher. There are three big things that we could do to amp up our progress:

  1. Go back and expand charter schools from 18 percent to 25 percent of the student body. This is good for the kids in the charters and also good for the larger system. We are now in the five millionth month of teacher contract negotiations. The fact is that once charters wrest a 25 percent market share of the total public schools from the district schools, the teacher contract negotiations will change drastically. Look at the change in other cities when that happened.
  2. Expand METCO on the basis of socio-economic status, from the 3,000 Boston kids in it to even 5,000 kids. While certain Boston suburban districts have experienced significant student growth in the past few years, others can accommodate METCO students—as long as the state fully funds the program.
  3. Set Madison Park Vocational Technical free from the superintendent’s control. Carol Johnson and Mayor Menino have to know that the regional VTEs have demonstrated striking success on student achievement, graduation and dropout rates. They have long waiting lists now, and it is because they have the flexibility that comes with control at the school level. The Superintendent and Mayor could assemble a crack team of advisors from the heads of the state’s regional VTEs to create a plan that is practical and effective.

There is data to back up each of these recommendations. And embracing them would demonstrate the kind of urgency we need for kids in public schools today. Not some ephemeral tomorrow that we've been hearing about for decades.

The exciting thing is that these are reforms that are within reach. The frustrating thing is that theses are reforms that are within reach.

Crossposted at Pioneer's blog. Follow me on twitter at @jimstergios, or visit Pioneer's website.

About the author

Jim Stergios is executive director of the Pioneer Institute. Before joining Pioneer, he was Chief of Staff and Undersecretary for Policy in the Commonwealth's Executive Office of Environmental Affairs, where More »

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