The U.S. Department of Education received nearly 500 comments on its draft proposal for the new Race to the Top competition for school districts announced last month. If you recall, the competition (we’ll use RTT-D as shorthand) will award $400 million to school districts, consortia, and education agencies that meet ED’s criteria for improving teaching, learning, and academic performance. (You can read the executive summary below.)

The comment period ended on Friday, at which point my colleague Alyson Klein, at the Politics K-12 blog, rounded up the most notable comments from groups representing state education officials and urban schools officials, and from think tanks. Commenters questioned whether charter schools, low-income districts, and larger school districts are properly represented and whether it’s proper for school boards and state officials to review district applications.

But there were also several comments from the private sector and technology community regarding the competition’s focus on “personalized learning,” the nebulous term used for teaching to each student’s individual needs. It is often associated with technology—adaptive learning software, virtual schools, the flipped classroom—but also associated with competency-based credits and response-to-intervention approaches.

ED has its own, more tangible definition of what districts are expected to provide in the way of personalized learning:

A formal document, available in digital and other formats both in and out of school to students, parents, and teachers, that, at a minimum: establishes student learning goals based on academic and career objectives and personal interests; sequences content and skill development to achieve those learning goals and ensure that a student can graduate on-time college- and career-ready; and is updated based on information about student performance on a variety of activities and assessments that indicate progress towards goals.

My colleague Ian Quillen and I rounded up some notable comments and critiques of the plan from foundations, professional associations, and investors. And while ED’s public comment period is over, EdWeek’s never is. Let us know what you think of the competition in the comments section.

• The NewSchools Venture Fund, a venture philanthropy fund in San Francisco, is concerned that the kind of personalized learning plans in districts’ applications could be difficult to actually implement. In a letter signed by 15 other groups, including start-up companies, think tanks, and education associations, NewSchools laid out its own prescription for the competition.Instead of a mandated personalized learning plan, districts should be encouraged to develop “digital toolboxes” that give teachers the option to use a set of tools in the classroom, the letter says. Those tools would be determined by working and negotiating with vendors who would be paid based on usage and performance metrics, the letter says. The letter suggests the competition encourage winners of the grant to work with nonprofit organizations, which would be eligible for RTT-D subgrants, on professional development and technology strategy. Worth noting: former NewSchools chief operating officer Joanne Weiss is Secretary of Education Arne Duncan’s chief of staff.
• In a letter submitted by Michael B. Horn, the executive director of education for the Innosight Institute, a think thank that advocates for personalized learning, Horn takes issue with student attendance as a success measure for applications. He suggests the competition should promote districts looking to raise competency in subjects—whether class is held in a school building or online— not simply attendance.

“It is clear that time spent sitting in a seat does not mean time spent truly learning,” Horn writes. “The metrics should reflect that although attendance may be correlated with achievement in traditional schooling models, it is not causal.”

• Somewhat surprisingly, Creative Commons, a nonprofit organization that provides and manages free copyright licenses for digital content, including open educational resources (OER), decided to weigh in on the competition. OER are free, digital educational materials, that have been praised by ED as affordable alternatives to more costly content options. The RTT-D competition mentions school districts making its data more open to parents and students. But Creative Commons asks the department to go further and require any educational content created through the grant competition to be made available under a Creative Commons Attributable License that would allow it to be used by anyone for free. There is a similar provision in the Department of Labor’s grant program for community college and career training, the comment notes (it’s toward the bottom of this page). From what I saw, no publishers offer comments on the competition but I’m guessing if any such provision is considered they would weigh in.
• The International Society for Technology in Education in its comments lauds the priority given to personalized learning environments, but raises concerns that the program’s definition is too narrow (as Alyson points out, the American Association of School Administrators thought the same thing). The comments go on to suggest edits to RTT-D criteria that would broaden that definition.
• Like ISTE, the Consortium for School Networking, or CoSN, praises the draft application documents’ focus on personalized learning. But CoSN raises the concern that the link between technology and personalized learning is not clearly explained. It also stresses that “technology can and must undergird much” of the kinds of proposals hoped for in the RTT-D competition. (Full comments are about halfway down this page.)
• The International Association for K-12 Online Learning, or iNACOL, calls the guidelines a positive step, but expresses worry that they are too broad, and could eventually result in applications making promises which are, after approval, blocked “by policies and legislation beyond their control.” (Full comments about one-third down this page.)

ED will now consider the comments as it develops final guidelines.