May 19, 2021

Re: Docket ID ED-2021-OESE-0033, Proposed Priorities—American History and Civics Education, 86 Fed. Reg. 20348

Secretary U.S. Department of Education 400 Maryland Avenue SW Washington, DC 20202

Dear Secretary Cardona:

The U.S. Department of Education’s (“Department”) Office of Elementary and Secondary Education (OESE) recently released a proposal establishing priorities for grants in “American History and Civics Education” programs. Proposed Priorities—American History and Civics Education, 86 Fed. Reg. 20348 (Apr. 19, 2021) (“Proposal”). The Proposal would offer priority to grant projects that “incorporate racially, ethnically, culturally, and linguistically diverse perspectives.” Id. at 20349. The Montana Office of Public Instruction (OPI) has serious concerns about the effect of this Proposal on the education of students in Montana. We strongly advise you to withdraw the Proposal and reconsider these priorities.

Today’s students are tomorrow’s citizens. We need all students to understand and appreciate the future of our state and nation. We need them to study our founding documents, and understand what makes the so exceptional. And we need them to comprehend when and where our country has fallen short of its lofty ideals, and how ordinary citizens and leaders alike have come together to enact change to guarantee we learn from our history and that the same mistakes are not repeated. But this Proposal falls far short of that goal.

As the elected State Superintendent of Public Instruction in Montana, and on behalf of students and parents across Montana, I am pleased to submit the following Comments on the Proposal to the Department and expect that you will take them under advisement.

Proposed Priority 1—Projects That Incorporate Racially, Ethnically, Culturally, and Linguistically Diverse Perspectives into Teaching and Learning

I. Proposed Priority 1 Replaces History with Propaganda

Proposed Priority 1 alarmingly attempts to replace neutrality in teaching with propaganda. Debunked theories that twist and distort our history have no place in our schools.

As an example of the type of education it seeks to promote, the Department highlights ’ “1619 Project.” See id. This is deeply troubling from an educational perspective. The project’s thesis infamously claimed that the arrival of slaves in America in 1619 was the beginning of racial oppression in the United States and that every ideal about American freedom and equality was thus “false from the beginning.” Five of the world’s leading scholars of the early-American period have pointed out the 1619 Project’s deep historical carelessness, inaccuracies, and oversights:

[W]e are dismayed at some of the factual errors in the project and the closed process behind it. These errors, which concern major events, cannot be described as interpretation or “framing.” They are matters of verifiable fact, which are the foundation of both honest scholarship and honest journalism. They suggest a displacement of historical understanding by ideology.

Letter to the Editor: We Respond to the Historians Who Critiqued The 1619 Project N.Y. TIMES (Dec. 29, 2019).1

One Princeton historian accused the 1619 Project of making arguments “built on partial truths and misstatements of the facts.” Sean Wilentz, A Matter of Facts (Jan. 22, 2020).2 Even a historian who supported the project has admitted that its central contention was demonstrably false. See Leslie M. Harris, I Helped Fact-Check the 1619 Project, The Times Ignored Me, (Mar. 6, 2020) (“On August 19 of last year I listened in stunned silence as Nikole Hannah-Jones, a reporter for the New York Times, repeated an idea that I had vigorously argued against with her fact-checker: that the patriots fought the in large part to preserve slavery in North America.”). The 1619 Project’s errors were so grievous that the National Association of Scholars has called for the Pulitzer Prize Board to revoke its award given to the project’s founder, Nikole Hannah-Jones. See Peter Wood, Pulitzer Board Must Revoke Nikole Hannah-Jones' Prize, National Association of Scholars (Oct. 6, 2020).3 The Times itself finally had to issue a correction. See Jake Silverstein, An Update to the 1619 Project, N.Y. TIMES (Mar. 11, 2020).4 The 1619 Project is riddled with errors and is unworthy of journalism, much less historical scholarship.

To be very clear, schools should not avoid uncomfortable parts of our history. We must ensure, rather, that our civics education and social studies standards are honest, candid, and most importantly, accurate. Our children must know their history, understand their government, and use original, primary source documents to achieve that knowledge. Montanans celebrate our diverse heritage, and proudly embrace our state’s unique Constitution, which commits to the continued education and preservation of Indigenous culture. In fact, here in Montana, we have recently updated our social studies standards for the first time in 20 years to better reflect our opportunity to teach students the full perspective of the history of our first Montanans and provide Indian Education for All in our classrooms. But history based upon half truths and poor scholarship, like some of the materials specifically cited in the Proposal, is not education, it’s indoctrination.

1https://www.nytimes.com/2019/12/20/magazine/we-respond-to-the-historians-who-critiqued-the-1619-project.html. 2 https://www.theatlantic.com/ideas/archive/2020/01/1619-project-new-york-times-wilentz/605152/ 3 https://www.nas.org/blogs/article/pulitzer-board-must-revoke-nikole-hannah-jones-prize#_ftn3 4 https://www.nytimes.com/2020/03/11/magazine/an-update-to-the-1619-project.html.

II. Proposed Priority 1 Encourages Discrimination

The most troubling aspect of the proposal is the incorporation of so-called “antiracist” teachings and “” (CRT) into classrooms. I have heard from countless Montana families statewide in recent weeks specifically about what fringe ideologies such as CRT or “antiracism” education would mean for Montana, and what it would mean for their children. They are rightfully concerned about this thinking being introduced into their schools’ classrooms.

The Proposal notes that “schools across the country are working to incorporate antiracist practices into teaching and learning.” 86 Fed. Reg. 20349. The Department then explains:

As the scholar Ibram X. Kendi has expressed, ‘‘[a]n antiracist idea is any idea that suggests the racial groups are equals in all their apparent differences—that there is nothing right or wrong with any racial group. Antiracist ideas argue that racist policies are the cause of racial inequities.’’ It is critical that the teaching of American history and civics creates learning experiences that validate and reflect the diversity, identities, histories, contributions, and experiences of all students.

Id. (citing Ibram X. Kendi, HOW TO BE AN ANTIRACIST (2019)). Accordingly, “[u]nder this priority, the applicants propose projects that incorporate teaching and learning practices that reflect the diversity, identities, histories, contributions, and experiences of all students create inclusive, supportive, and identity-safe learning environments.” 86 Fed. Reg. 20349. This includes requiring applicants to “incorporate[] teaching and learning practices that … [t]ake into account systemic marginalization, biases, inequities, and discriminatory policy and practice in American history.” Id.

How to Be an Antiracist is radical and discriminatory. It contends that “the most threatening racist movement is ... the regular American’s drive for a ‘race-neutral’ [state].” Ibram X. Kendi defines what it means to be an antiracist, Penguin Press, June 19, 2020 (excerpt from HOW TO BE AN ANTIRACIST).5 Incorporating the ideas of “institutional racism,” “structural racism,” and “systemic racism,” it argues that:

A racist policy is any measure that produces or sustains racial inequity between racial groups. An antiracist policy is any measure that produces or sustains racial equity between racial groups. By policy, I mean written and unwritten laws, rules, procedures, processes, regulations, and guidelines that govern people. There is no such thing as a nonracist or race-neutral policy. Every policy in every institution in every community in every nation is producing or sustaining either racial inequity or equity between racial groups.

Id. The most shocking aspect of this philosophy is the pronouncement that “[t]he only remedy to past discrimination is present discrimination. The only remedy to present discrimination is future discrimination.” Id.

5 https://www.penguin.co.uk/articles/2020/june/ibram-x-kendi-definition-of-antiracist.html

CRT, likewise, rejects race-neutral public policy and the legal liberalism of our Constitution. See generally CRITICAL RACE THEORY: THE KEY WRITINGS THAT INFLUENCED THE MOVEMENT (K. Crenshaw et al., eds.) (1996). The National Association of Scholars (NAS) characterizes CRT as:

more a pedagogical weapon than a theory. Its purpose is to demoralize and demean white students by telling them that not only their views but also their very lives are illegitimate;….[it] is a way of playing with the minds of vulnerable children who are in no position to assert their own critical independence.

Position Paper, Keeping the Republic, NATIONAL ASSOCIATION OF SCHOLARS (May 17, 2021).6

NAS’s observation is not merely theoretical. It has been borne out in classrooms across the country. In the spring of 2019, for example, the Evanston/Skokie School District in Illinois began developing the “Black Lives Matter at School” curriculum, which “unapologetically aims to create a new generation of allied activists.” Conor Friedersdorf, What Happens When a Slogan Becomes the Curriculum THE ATLANTIC (Mar. 14, 2021).7 The District then went on to:

• Separate administrators in a professional development training program into two groups based on race—white and non-white. • Offer various “racially exclusive affinity groups” that separated students, parents and community members by race. • Implement a disciplinary policy that included “explicit direction” to staffers to consider a student’s race when meting out discipline. • Carry out a “Colorism Privilege Walk” that separated seventh and eight grade students into different groups based on race.

Carl Campanile, US Dept. of Education curbs decision on race-based ‘affinity groups’, N.Y. POST (Mar. 7, 2021). In November 2020, the U.S. Department’s Office for Civil Rights opened an investigation of a complaint against the District for possible violation of Title VI. Id. As another example, the New York Department of Education’s Early Childhood Division also sponsored an “anti-racist Community Meeting” where teachers were segregated into discussion groups based on skin color, race and ethnicity. Kathianne Boniello and Susan Edelman, NYC teachers segregated by race for ‘affinity groups’ amid protests, N.Y. POST (June 20, 2020). These types of actions are inconsistent with our values as Americans and have no place in our schools. Perhaps no one has summed up what CRT really entails better than South Carolina Senator Tim Scott in his response to President Biden’s recent address to Congress. “A hundred years ago,” Scott said, “kids in classrooms were taught the color of their skin was their most important characteristic —and if they looked a certain way, they were inferior. Today, kids again are being taught that the color of their skin defines them—and if they look a certain way, they’re an oppressor…. It’s backwards to fight discrimination with different discrimination.”

I, therefore, join Senator Steve Daines from Montana and 38 of his U.S. Senate colleagues in calling on the Department to withdraw this misguided Proposal. In their letter, the Senators write, “our nation’s youth do not need activist indoctrination that fixates solely on past flaws and

6 https://www.nas.org/blogs/article/keeping-the-republic. 7 https://www.theatlantic.com/ideas/archive/2021/03/should-black-lives-matter-agenda-be-taught-school/618277/

splits our nation into divided camps. Taxpayer-supported programs should emphasize the shared civic virtues that bring us together, not push radical agendas that tear us apart.” I concur in their assessment, and add my voice to the many who respectfully request that you not proceed with this Proposal.

Sincerely,

Elsie Arntzen State Superintendent Montana Office of Public Instruction