I would like to update my earlier submission on the proposed regulations to include the following points, after having read the draft regulations and RIS [ which were not available at the time of my earlier submission ]

I oppose the proposed regulation changes, for the following reasons :

- The extra constraints on homeschooling subvert the rights already given by the Act, and as such I believe they are illegal

- Insufficient consultation was undertaken. For example the VRQA did not email the proposed draft to registered home schoolers, even though they have their email addresses on file. The consultation with HEN was not substantive, and it was done in bad faith in my opinion. Thirdly the draft was released just before Christmas in the hope it would receive little scrutiny.

- The measures will be costly, and the RIS underestimates the costs substantially - firstly, 1.5 hrs for a parent to prepare a learning plan is an uninformed estimate, secondly there is no estimate of the high cost of dealing with home ed parents who oppose the regulations in protest, including legal costs for the government to defend its position, thirdly the actual costs of maintaining a new bureau within VRQA are likely to be higher than an estimate based on perfect allocation of fractional FTEs.

- The measures will be ineffective - a learning plan does not guarantee learning, and there will be cases where pressured parents provide a rushed/incomplete plan, or a form-plan obtained by googling / copying that exists merely to satisfy the new requirement of a plan. The whole system of review is a new bureaucracy which will have no effect on student learning outcomes nor student safety.

- The additional constraint that parents may not remove their child from school for at least 28 days is largely punitive and unreasonable. In many cases there is a legitimate need to remove the child at the time when the decision to homeschool is made - in cases such as bullying or other abuse, or where a parent has already gone to extreme lengths to negotiate a learning solution with the school to no effect. Here we have a case where regulation is taking away a legal and moral right of the parent and child to a safe environment in which that child can learn.

- The whole approach of the regulations is officious and uninformed, and goes counter to the rights and provisions guaranteed by the education Act itself - the act recognizes the need for Home schooling, it guarantees that right. No matter how good our schools are [ and they are not good now ] there will always be some students who do not fit the mainstream approach. Home education is needed to provide the flexibility for accelerated and slower learners that even the best schools cannot be expected to accommodate. It was with this understanding that the provisions of the act were given, under lengthy consultation and public review. If the government wants to change this, they should change the Act itself, via the parliamentary process, not subvert the Act via regulations which overstep their powers.

- The government has not yet stated clearly what it hopes to achieve by these regulations - there are real problems to solve in education in Australia, but Home Education must surely come way down the list when compared to failing academic performance in STEM, teachers who are overburdened with paperwork, creating enough roll places and math teachers for the demand, addressing bullying in the classroom, curriculum updates and so on. The government has not made its case for any change in Home school regulations - where is the evidence for there being a problem with either academic achievement or child safety ?

For these reasons, I believe the regulations in regard to Home schooling should be left as is, and the proposed draft regulations discarded. The money saved can certainly be put to better use, such as hiring new Math teachers to help improve the international comparative STEM results,

regards,

gordonanderson

Our Experience

Mysonis12yo,ishigh-achievingacademicallyandhashadamixtureofHomeschooland Public schoolexperience.

HeattendedpublicschoolatPrimarylevel-PrepandYear6lastyear,theotheryearsof primary were homeschooled. In 2016 he was accepted into a SEAL program in inner Melbourneandattendedfor4monthsbeforewemadethedecisiontoHomeschoolhim again.

Our reasons were mainly due to him being advanced in areas such as Mathematics - he is working on year 10 curricula currently. Despite much discussion around the issue the school found this hard to accommodate adequately, in our opinion.

Observations

The Victorian regulations are reasonable and should be preserved as is

A significant sector of families choose to Homeschool in order to provide a better academic education

ThereisagrowingsocialnetworkforHomeschoolerstomeetandswapexperience,whichis veryvaluable.

SchoolsininnerMelbourneareunderextremepressuretogrowtofillthedemandfor schoolplaces.Ifeelthistakesbandwidthawayfromimprovingthebasicsofacademic achievement.

Schoolteachersandmanagementmaywishtoaccommodatedifferentiatedlearning,butin practice there will always be ends of the spectrum that are difficult to address in an economicalandsystematicwaythroughpublicschool

CurriculumdeliveryinpublicschoolstendstobeweakintheareasofMathandScience. There are ways to mitigate this without yet another curriculum overhaul, by replicating thingswhichhaveworkedinothercountriessuchasweeklyMathCircles/problemsolving clubs/programmingclubs/sciencetalks.

Inparticular,TheAustralianMathematicsCompetitionisaveryfineprogramwhichiswell respectedoverseas,butseverelyunder-utilisedinAustralia-everystudentshouldtrytheir handatthis,notjustthe'elites'.IncontrasttheNAPLANregimetakesalotoftimeand achievesverylittle,inmyopinion.

The 'lite touch' approach towards Homeschooling in Victoria should be preserved, and I hope to see other states adopt this.

Thedepartmentofeducation,throughpublicschools,shouldmakeanefforttoengagewith Homeschoolers in a more inclusive way [ partial 'community' access to venues/facilities, events, curriculum working groups, social events, co-participation in education research studiesetc].

PartialfundingforHomeschoolresourcesupportshouldbediscussedinfuture,asthisisa growingdemographicandgainingmorewidespreadsocialacceptance,andisalsoaviable alternativewhereschoolscannotgrowfastenoughtofillthedemandforplaces.

Support organisations such as HEN, gifted children association and the several facebook groupshavebeenofgreatpracticalvalue-perhapsorganisationssuchastheseshouldhave somefinancialgrantsupport,giventheimportantroletheyplay.

Anapproachof'workingtogether'withHomeschoolfamilies,ratherthananapproachof 'enforcement',ismuchmorelikelytoresultinthebestoutcomeforchildrenandfamilies.