MAP testing revolt: Superintendent announces task force; test boycotters threatened with suspension

January 23, 2013 at 2:58 pm | In West Seattle news, West Seattle schools | 38 Comments

In advance of a media briefing next hour about Seattle Public Schools‘ response to concerns about the testing known as MAP (Measures of Academic Progress), and a rally by MAP opponents after that, Superintendent José Banda has just announced a testing task force. Read on for his open letter (and, ADDED 4:30 PM, another administration letter saying test-boycotting teachers face suspension):

There has been much public debate about the Measures of Academic Progress (MAP) assessment in the last few weeks. Today I am announcing details of a Joint Task Force on Assessments and Measuring Progress. This task force will be a productive way for educators and our community to come together to discuss concerns and find solutions that best meet the needs of all our students.

I want to take a moment to emphasize the importance of data in our work as educators. Across Seattle Public Schools, we use multiple forms of data to help guide classroom instruction and measure progress. For many of our teachers and principals, the MAP assessment provides critical data to help screen the most vulnerable students for additional academic support and more personalized attention and to measure their growth and improvement over time.

At Seattle Public Schools, we must champion equity, access and opportunities for all students. I want to listen and better understand assessment concerns, and work with staff on a solution moving forward. But in the meantime, I am asking as your Superintendent that teachers follow our policies and procedures and administer this assessment for our students. This is especially important for our students who are the most at-risk academically. I am hopeful we will continue to work together in support of our students.

The new task force will have the opportunity to explore and review the strengths and limitations of the MAP assessment, and will consider potential alternatives to future district testing programs. The task force will be formed in partnership with the Seattle Education Association (SEA) and Principals Association of Seattle Schools (PASS), and will include teacher representatives and school leaders. The input of additional stakeholders, including families, students and community members, will also be solicited to provide multiple perspectives. The task force will be formed immediately and meet at least twice a month from February through May. Final recommendations should be provided to me in May.

I am hopeful the task force will develop strong recommendations for making future improvements to district assessment processes. I look forward to a productive conversation.

Thank you for the work you do every day on behalf of our students.

Sincerely,

José Banda
Superintendent
Seattle Public Schools

ADDED 4:30 PM: This afternoon’s media briefing also included a district administration letter, provided to principals, outlining among other things suspension penalties for teachers who don’t give the test:

I am writing today to help provide support and guidance around the recent issue of certain teachers refusing to administer the Measures of Academic Progress (MAP) assessment to our students.

We ask that each principal by the end of the school day provide a clear directive to all administrative and teaching staff that the MAP assessment must be administered to students of tested subjects on the timeline established by you, their building administrator. State law requires that teachers implement a course of study in accordance with District directives. Administering the MAP to students of tested subjects is a District directive.

If a teacher refuses to administer the MAP assessment after a clear direction by you, such conduct is considered insubordination. When a staff member engages in insubordination, such action will lead to appropriate disciplinary action as outlined in School Board Policy 5281 Staff Disciplinary Action and Discharge. Previously, the discipline imposed by the District when a teacher refused to administer a required assessment was a 10-day, unpaid suspension.

If you have staff who have either not administered the test on the date required by you or have given you clear notice that they do not intend to administer the test, you are required to give that staff person this communication, preferably in a letter or email that you send and hand to them:

Dear ________:

State law requires that teachers implement a course of study in accordance with District directives. As you are aware, the Measures of Academic Progress (MAP) is a District assessment that teachers are required to administer. You are receiving this communication because you are required to administer this assessment. Based on information that I possess, I believe you have either refused to or have declined to administer the MAP assessment.

For staff who disagree with MAP assessment, I acknowledge that you are certainly entitled to your opinion. Your disagreement with the appropriateness of the MAP assessment, however, does not excuse your obligation as a certificated employee to provide this assessment consistent with District directives.

Thus, I am specifically requiring that you administer the MAP assessment by the Feb. 22, 2013 deadline, notwithstanding your apparent disagreement with the District’s decision to require this assessment. Your refusal to administer the assessment consistent with District requirements and this directive will lead to discipline. Discipline that has been imposed for such insubordination in the past has included a 10-day, unpaid suspension. Please contact me immediately if you have concerns over getting this assessment done by Feb. 22, 2013.

Sincerely,

__________________

Principal, School Name

We understand there are concerns around MAP assessments, and Superintendent Banda will soon announce details about a Joint Task Force on Assessments & Measuring Academic Progress. This task force, which will include principals, teachers and central office staff, will report recommendations to the Superintendent before the end of the school year. This is a productive way to work together on this issue. In the meantime, many of our principals and teachers find the MAP assessment to be very helpful. We want to be consistent across the district in administering this to all required students.

As a reminder, all MAP assessments should be administered by Feb. 22. If for logistical reasons your staff are unable to administer the MAP assessment by that deadline, an extension may be granted by your Executive Director.

If you have questions, please work with your Executive Directors of Schools. If you need additional support, please contact me at (206) 510-6697.

Sincerely,

Paul Apostle
Assistant Superintendent for Human Resources

38 Comments

  1. Ummmmm… I think the problem is that the MAP DOESN’T assess our students. So, any data from it is erroneously guiding classroom instruction and it does not measure progress.

    Comment by FWIW — 3:21 pm January 23, 2013 #

  2. Hmm, wonder which will cost more money: the testings or the task force?

    Of course, we all know the *real* cost: not enough time with the teachers teaching– instead, testing and preparing for the (lowest bidder?) tests.

    Let the teachers TEACH!

    Comment by happy — 3:44 pm January 23, 2013 #

  3. As a middle school student, i have to take this test three times of year. It’s always nerve wracking for me, because there is this social stigma behind it, if you are “smart” and you get a lower score than the last time, then you get teased. A lot of the time people just choose random questions and get high scores.

    Comment by SPS STudent — 4:38 pm January 23, 2013 #

  4. Wow! “Insubordination” is one of those administration bully words that doesn’t sit well with people who work extremely hard and should have the right to give their input!

    Comment by sanisloparent — 4:56 pm January 23, 2013 #

  5. I fully support the teachers on this. Down with MAP!

    Comment by kayo — 5:05 pm January 23, 2013 #

  6. I think the people that work extremely hard should have some input. However, the input they’re giving is that we should all just trust that they are all wonderful teachers. Our school systems are failing and whether that’s the fault of funding, the system, or the educators themselves we need to find the gaps and close them.

    The only way we can test whether the changes we are making, the monies we are spending are effective is to test.

    The tests should be reflective of the curriculum. They should reflect what the students should know. The teachers shouldn’t have to “teach to the test.” They should simply teach the curriculum well. Frankly, it is not at all indicative that they are.

    Comment by MyEye — 5:09 pm January 23, 2013 #

  7. I’ve heard of more than a few parents showing their support for the teachers by opting out their students from the MAP and asking that the reason why they are opting out be recorded. I have to say, if I had kids, I would do the same.

    Comment by Elizabeth — 5:12 pm January 23, 2013 #

  8. What happens to kids whose parents opt them out? Are they penalized for placement in advanced classes?

    Comment by Raincity — 5:52 pm January 23, 2013 #

  9. The test was designed to measure student progress – it was NOT designed to assess a teacher’s efficacy, yet the district insists on using it for this purpose (a national trend unfortunately designed to demoralize teachers and eradicate their unions). And it is hard on students, as one pointed out above, to continually take tests, rather then I dunno, spend time learning? Kids deserve more human time with a teacher, and less time in front of a computer. Glad they are standing up for what they believe in.

    Comment by bestbets — 6:08 pm January 23, 2013 #

  10. I am a local nationally board certified teacher and I support the bold action Garfield teachers are taking for their students. Teachers do not reject student testing- we do reject tests that are costly, misused and useless for instructional purposes. We do not reject comprehensive teacher evaluation- we do demand that data be used correctly to assess our craft. I am excited to see that the action of these courageous teachers has sparked a much-needed debate, now if we can turn the talk to focus on the real issues at hand- poverty, misuse of funds, unequal access, etc. we might get somewhere! Blaming the teachers is the easy way out and is counterproductive to the transformation our public schools need.

    Comment by Lindsey — 6:11 pm January 23, 2013 #

  11. Oops! 2 comments from me :) Didn’t intend to monopolize the conversation… tech glitch!

    Comment by Lindsey — 6:13 pm January 23, 2013 #

  12. I would think that its a clear sign to the district that the test needs to be reviewed. Next I would think that the task force would allow foe the complete suspension of the testing until it deemed the test was a positive or negative test. I also agree with the comments made by the student about what happens with results. And finally the HR assistant comes across as a bully himself.

    Comment by coffee — 6:21 pm January 23, 2013 #

  13. Maybe we should give the school district admins a MAP test of their own to see if they know how to manage money. Of course I guess it would be a waste of time as we already know that answer. Voting NO until the district learns to use their money wisely.

    Comment by Jack Loblaw — 6:22 pm January 23, 2013 #

  14. Or….is it possible that teachers will oppose ANY thing that evaluates their performance?

    The teachers union seems to oppose any attempt to improve the actual teaching ability.

    Almost everyone working today is subject to annual evaluations, but it seems that teachers somehow believe they are exempt.
    I am pretty sure that a lot of the posters here are teachers.
    What evaluation process do the teachers think is fair?

    Comment by orca — 7:00 pm January 23, 2013 #

  15. Orca- teachers are evaluated. Our supervisor comes in 2 to 3 times a year and takes notes on us for an hour or so as we teach. Analyzing and critiquing any of the 100 or so things we do in that hour. Does your boss evaluate you this way- does any profession evaluate people this way. Of course all of this is preceded by conference with our evaluator where we discuss in detail our lesson including; teaching points, ties to the standards, evaluation of students, modifications for struggling or advanced students and of course how it ties in to the current unit of study (in any one of 6 or more subjects elementary teachers teach). All of this is of course preceded by another conference with our evaluator regarding our goals for the year and how we will use data and state standards to meet these goals. So in answer to your question yes we are evaluated quite extensively and we get a little irritated when they want to use an arbitrary and inaccurate test as an additional part of that evaluation.

    Comment by Jaime Escalante — 7:36 pm January 23, 2013 #

  16. Not a teacher, not a parent, not a student – but a taxpayer- want the best for all of them for the sake of the society we all share. Forcing students to spend huge of amounts of their precious learning time being grilled by test after test after test, so that public funds can be sunk into scoring, analyzing, question writing, number crunching and high paid administrators who’ve never even seen a student just seems wrong. Needed for the SAT, needed for the occasion federal evaluation, but really? three times a year? There are soooo many other ways to evaluate teachers & students, fairly & constructively.

    Comment by when I was in school — 7:49 pm January 23, 2013 #

  17. I am not a teacher, but a parent of a 5th grader. This test is frustrating to students. The questions get progressively harder and then easier depending on how a child answers. But if the test is not asking questions related to what they are being taught – isn’t that a problem?
    My daughter has learned a great deal over the last three years and is doing great in school and did well on the MSP, but according to the MAP test each year she has lost ground. Why do we need both?

    This test is also used to place kids into more advanced classes in middle school – so you are telling my daughter that she will be placed in classes based on a test that does not cover what she’s learning? They loose their library, they spend extra time preparing and giving this test in addition to all the time spend on the MSP.

    This response from the school district is “comply or else”.

    Comment by Raincity — 7:50 pm January 23, 2013 #

  18. Orca-
    I’m a teacher & I’m on the fence about the issue of being evaluated by student performance. I think it’s incredibly important because we want effective teachers who guide students to success but this particular test is not based on the standards we are required to teach. Also, there are soooooo many factors that play into how a student performs on a test so it’s a matter if finding a ballance. It should not be the only tool to evaluate teachers (just my opinion).
    What time did the student go to bed the night before, did the student eat breakfast, did the student have an argument with someone at home or on the way to school before the test, does the student have test anxiety? I could go on for pages…

    I believe that the intention behind using tests to “grade” teachers comes from a good place (wanting our students to succeed) but it doesn’t make sense to use a test that is not based on the standards we are required to base our instruction on every day.

    Ponder this- You teach me how to use a regular, modern calculator. Then I get tested on my ability to use an abacus. I fail the test. You get fired because I scored low on the test that determined my ability to apply my knowledge. This is a ridiculous example and extreme but its what came to mind in the moment of trying to think of a scenario that was similar…

    Anyway, just my opinion.
    I teach special education & I love my job & all my beautiful students!!!

    Comment by ereljo — 7:57 pm January 23, 2013 #

  19. I agree with the district. If they want to use to assess student performance as well as the teachers is fine by me. Maybe this could lead to…..dare I say, merit-based pay for teachers.

    Comment by Mike — 8:08 pm January 23, 2013 #

  20. ereljo- As a fellow teacher, I think you are right on. The issue gets even harder to discern at the high school level. If we are only evaluated on student performance who would ever volunteer to teach remedial or credit retrieval type classes? Everyone would clamor for the ‘honors’ students who would be above standard no matter who their teacher was. Finally, as a teacher of a currently non-assessed subject I see it as unfair to my colleagues that teach English and Math.

    Comment by Teacher — 8:34 pm January 23, 2013 #

  21. I do not think there are any teachers that would object to a FAIR testing process or assessment of their students, by say looking at a portfolio of actual work being created by their students. The MAP testing is completely bogus. I am a parent of 2 children in the SPS. My son was given the wrong grade level testing of the MAP because he was actually in 6th grade, but was learning 7 grade math at the time. He got a satisfactory score, but with a quick refresher could have done much better. He was actually being taught 7th grade math at the time but had to test on the 6th grade material because he was in 6th grade. Who would be willing to hold his math teacher accountable for my son’s score? It wasn’t an accurate score based on his actual knowledge and had nothing to do with the curriculum he was being taught at the time. Kindergarteners are also tested even though they can barely read! It’s simply not fair to hold the teachers accountable with such an inaccurate test.

    Comment by Schmoopie — 8:50 pm January 23, 2013 #

  22. Raincity poignantly gets straight to the point. As parents, when we see our children frustrated with excessive, duplicated testing sessions, are we not to have a voice? And, the ‘comply or else’ district response is stinging. So collaborative, well, err, eh… Not. Should not the students insights, as well as the parents observations of the incessant testing politics be valued? In it for the students or the test, dog gone it. Sometimes I wonder. Missing library time for a test. Well? Go figure. They paved paradise, and put up a parking lot. Instead of books, it’s computers bubbling over with multiple choice dribble and testing deadlines. As a parent, it’s disagreeable, in my view.

    Comment by Greenpeace — 8:51 pm January 23, 2013 #

  23. I am a teacher. I do want to be evaluated so that I can get even better at the job I love to do. However, the MAP is a bad test. As teachers, we’re not supposed to know what is on this test…so that we don’t “teach to it”. But, when a kid says, “Hey what should I do about this question that doesn’t have any answers?” You pretty much have to look at what they see on their computer screen. Here’s the question a student encountered several years ago. “What type of triangle is this?” Then there was a picture of a triangle. This was followed by a), b), c), & d) multiple choice answers –only problem was, there were NO WORDS/ANSWERS after a, b, c, & d! WHAT?

    As a teacher, do I really have to be evaluated by a test containing questions that students can’t possibly get correct? That just doesn’t seem fair, does it? Best part of the encounter with this question was that the VERY SAME QUESTION came up the following year, even after we had reported it to the company that makes MAP. (For as much as this test costs, that’s pretty unacceptable; who’s “accountable” for that?) After two years of this, I now tell my students to raise their hand if they run across a question that just doesn’t seem right. Every testing session we get one, and the test proctor ends up terminating the student’s test.

    I’m glad to hear that parents are supporting us by opting their kids out. I too am a parent of a kid in the SSD. FYI I’m not letting him take the test either. Yes, it probably will affect his acceptance into Spectrum, or an AP program, but that’s what “teacher appeals” are for –you know, the folks who spend all day with out kids, and know better than any test how capable they are.

    Comment by Just want to teach... — 9:01 pm January 23, 2013 #

  24. Hmm, I’m disappointed in Banda.

    Comment by Evergreen — 9:54 pm January 23, 2013 #

  25. A thoughtful look at why teachers refuse to administer the MAP test- worth a read: http://seattletimes.com/html/opinion/2020158085_jessehagopianopedxml.html

    Comment by Lindsey — 9:55 pm January 23, 2013 #

  26. MAP is far from perfect, but having it as one more point of reference so that we can evaluate if our students are actually making yearly progress seems very appropriate to me. Teachers do need to be held accountable and we (as taxpayers and parents) need to know that our students are learning. I don’t agree with using MAP scores for weeding out students from Advance Placement opportunities, nor do I believe teacher evaluations should ride upon the results of MAP alone, just as I don’t agree with using MSP or HSPE scores as standalone benchmarks in determining successful teaching. I do think however, that until we can find another standard source for evaluating academic growth, that we need to stick with what we have. I’m glad for the discussion, but I think that teachers and others who are concerned should put their energy into proposing sound alternatives, rather than to simply complaining. Suggest some alternatives that allow us to track success, recognize what’s not working, and fix it so that students get what they deserve. The failing marks of our schools is not only about student’s personal situation, it’s also very much about not adequately addressing the needs of students with best teaching practices, and sound curriculum. Please, if you’re going to complain, offer a solution that makes sense. (BTW, it is NOT sound teaching practice to threaten students with their scores, nor is it ok to post scores so that students feel ridiculed. That’s a teacher problem that needs to be addressed).

    Comment by parent — 10:21 pm January 23, 2013 #

  27. I’m with the teachers.

    Comment by Mike — 11:04 pm January 23, 2013 #

  28. I bet Many of us in the private sector would love to refuse an uncomfortable, disagreeable work assignment. We are paid to do a job, and we do it, or someone else will.

    Comment by Chris — 4:55 am January 24, 2013 #

  29. Chris,

    Would you refuse a work assignment that might cause another person harm? If you were a nurse, and a doctor ordered you to give medication to which a patient was allergic (let’s assume the doctor wasn’t paying attention to allergies at the time), would you just give the patient the medication? I sure hope not.
    It’s not a question of a disagreeable assignment – it’s an assignment that causes more harm than good.
    I’m a parent, not a teacher, but I’m constantly surprised at how little understanding there is of what teachers try to do with my kids every day.

    Comment by WSparent — 8:22 am January 24, 2013 #

  30. I support our teachers and think that if they see a problem with the system and the evaluation of our students abilities, they should question it. I want my child to learn how to stand up for themselves and question things that do not seem right or fair and applaud the teachers for doing just that. And yet again, parents have been put in a reactive position rather than a proactive position when dealing with the SPS regarding big decisions that directly effect their children’s education. Perhaps the SPS would like to get a sense of what the parents think about MAP, based on their experiences with it. I don’t think it will benefit anyone for our teachers to get the message, “Just do it or get suspended/fired.” I am a parent at Sanislo and see the teachers work hard every day to teach and inspire my children. I can’t imagine how yanking them out of the classroom for standing up for what they believe will benefit anyone.

    Comment by juju — 9:08 am January 24, 2013 #

  31. @orca:

    http://www.trelease-on-reading.com/no-dentist.html

    Comment by fulana — 9:59 am January 24, 2013 #

  32. “However, the input they’re giving is that we should all just trust that they are all wonderful teachers. Our school systems are failing and whether that’s the fault of funding, the system, or the educators themselves we need to find the gaps and close them.”

    NO, teachers aren’t saying “trust me, don’t assess my work.” They are saying MAP is a flawed assessment that doesn’t help students nor adequately assess students.

    And our school systems are NOT failing; where is your proof of that?

    Orca, the teachers AGREED to two assessments of their work in their contract. They would not have done that if they didn’t agree it was necessary.

    In answer to the question about advanced class, yes, MAP is a gatekeeper for Advanced Learning programs but not to AP classes.

    Comment by Melissa Westbrook — 11:37 am January 24, 2013 #

  33. Justified or not, these actions by teachers only contribute to the perception of Seattle Schools as a less than desirable school distract. All districts have standardized tests, but only Seattle chooses to “fight the good fight” and make a public spectacle of themselves.

    Comment by DW — 12:52 pm January 24, 2013 #

  34. I feel that it is important to include support for having some outcomes based data to use as part of the teacher evaluation process. It doesn’t have to be the MAP, perhaps a test the kids already have to take such as HSPE or end of course exams. Teacher quality is an important issue that should not be overlooked during this important debate. Teacher tenure has been a detriment to my sons’ experiences at Garfield. Young, talented teachers were riffed due to seniority, and it takes up to 25% of an administrator’s time with our current system to terminate an ineffective teacher. It is only common sense that there are underperforming professionals in all sectors, teaching is not exempt from this factor. The ones who stand to lose are our students when we have a few chronically ineffective teachers.
    My hope is that the taskforce comes up with a good alternative to high school MAP testing as a component of teacher evaluation, but holds firm on including some component of teacher evaluation that is not subjective, and helps identify the ineffective teachers we all know who are being protected by outdated union rules.

    Comment by Molly Calkins Seaverns — 8:04 pm January 24, 2013 #

  35. Juju – are you thinking SPS admin – bureaucracy cares what you think as a parent or taxpayer? Can you please name me one successful community outreach communication strategy in the last 10 years fr SPS Admin? (Individual schools and PTSAs not withstanding and usually in spite of SPS Admin).

    DW can you please name me another school district locally in this area or indeed, the entire state that uses MAP in this way (to assess teachers competence and admission to advanced placement when the vendor itself specifically stated those were NOT acceptable or psychometric ally/valid uses, the teachers or parents were not trained how to USE or ANALYZE the data generated, and was purchased under a glaring conlict of interest (former Supt Maria Goodloe Johnson on the board of the vendor, NOT disclosed to the SPS Board or Taxpayers/Parents and the “sweetheart contract NOT put to bid in violation of SPS policies and state law?

    Can you name ANY other district that ties up its staff, limited computers, libraries like this for weeks 2 – 3 xs a year – when the test is NOT in synch w/ the learning objectives, and the error of margin is greater than the expected rate of growth?

    See the so- called back pedaling from the NWEA (NW Educ. Assessment Assn. ) in the Times Op-Ed (sic) piece today published….. Hogwash – millions in direct purchase price and lost time in teaching and tying up of resources.

    Would I have staged the protest this way? No. If I were union leadership or a teacher would I have been bullied into MAP inlusion as part of evaluation? Heck No. If I were an SPS Boardmember , would I have caved to the “powers that be ” pro forma renewal of this specious contract – double heck no.

    But the devil is in the details and history – and very very few opportunities to learn about the details and weigh in and the arrogance of those “that know better” rule the day.

    I truly hope that Supt Banda makes good on his promise to listen to those outside the insular SPS admin and takes a mtg -not some weighted hand-picked task force and LISTENS to those willing to risk the penalties of civil disobedience, before imposing draconian “insubordination” penalties.

    We’ve waited for years for a community outreach plan – this might be a good time to implement it.

    Lots of nice Nat’l publicity, the usual Sea Times push-back, but change is a bear.

    Comment by Leslie — 9:08 pm January 24, 2013 #

  36. Sorry, before I’m flamed – not a teacher, but know tons of them – both pro and con MAP, followed the initial contract for MAP and its renewal, SPS board mtgs, retreats, budgets, etc. my kid tests well ( but so what doesn’t make this train wreck any less palatable). I am a taxpayer/ parent who strongly believes in public education and that we can do a lot better for our kids, our future and our money spent.

    Comment by Leslie — 9:17 pm January 24, 2013 #

  37. In regards to those commenting that there needs to be testing to gauge teacher performance, the MAP can not be exclusively used as a fire/discipline situation for a certified instructor. It can only be used as an influencer when there are other performance issues.

    Should an instructor teach the test? Absolutely not. Should the MAP or replacement be used as a gauge at the start of the school year to see where a student is, sure. At the end of the year to see what the student has learned, sure.

    The problem is that middle test is simply a waste of money and precious resources. What do you do with the students that are expected to research and write reports when they don’t have a computer at home and the computer at school is off limits due to the MAP testing?

    Also understand that the MAP may test on items not covered in class. Imagine being tested on the Quadratic Equation in February when you’re not schedule to learn it until May? Is that fair to the student or the instructor?

    The other thing that is very unfair that goes beyond the MAP is holding an instructor accountable for all their students for the objectives that the students should have reached, when some students have moved out of the area and some have moved into the area that are not at the level they should be. Add English Language Learner students to the mix coming in as well. Until the district can come up with a fair system to handicap the evaluations, factoring student movement and factoring the skills of the students coming into the class and afterwards, instructors that are good instructors face a tough future.

    Comment by Lance — 10:11 pm January 24, 2013 #

  38. Testing equals big profits for testing companies. Glaring conflict of interest pointed out above by Leslie, who mentioned Goodloe on board of both school system and testing company. Clear conflict of interest which should be addressed by SPS. I did not know this. There are clear policies in place for public entities/districts which are designed to negate such conflicts–ie, if an employee works w in a district, they can’t peddle their wares, or a conflict of interest occurs. WSB, however, would ensure I am correctly stating this, however, as I am not an attorney, simply a citizen stating policy as I understand it. If correct, though, well, eek. Glaring conflict of interest, if so.

    Comment by Greenpeace — 2:43 am January 25, 2013 #

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