The Council of Chief State Schools Officers—the folks who will have significant responsibility for implementing a new Elementary and Secondary Education Act—are weighing in on Sen. Tom Harkin’s bill, which will be considered on Wednesday by the Senate Health, Education, Labor, and Pensions Committee.

To refresh your memory, the bill by Harkin, D-Iowa, the committee’s chairman, would scrap No Child Left Behind’s signature yardstick, adequate yearly progress, or AYP. Instead, states would have to ensure that all students are making “continuous improvement” in student outcomes. States also would be required to identify the 5 percent of lowest-performing high schools, elementary schools, and middle schools. There would be more intensive interventions for those schools, as well as for so-called “dropout factories"—high schools with graduation rates below 60 percent.

In an Oct. 15 letter to Harkin and the committee’s top GOP member, Sen. Michael Enzi of Wyoming, the chiefs outlined three key concerns with the bill.

First, the chiefs oppose the single framework by which states would have to identify the bottom 5 percent. They want more leeway.

Second, the chiefs do not want to have to use federally determined school turnaround models, and instead want the power to come up with their own evidence-based models subject to peer review and department approval.

And, finally, the chiefs want more leeway in determining growth and how states meet performance levels.

Certainly, a lot of groups will be weighing in on this version of an NCLB rewrite, with civil rights groups already trashing the bill. The Chiefs for Change (a separate, smaller chiefs organization) has many of the same concerns as the CCSSO, but also feels the Harkin bill doesn’t go far enough on teacher evaluations. The unions are still mulling their response. Clearly, Harkin and the Senate will have a lot of interests to juggle.