Memorandum: Executive Order 1100 and Executive Order 1110

September 27, 2017

September 18, 2017
(revised 09-25-17)

To: Provost Yi Li
Adam Swensen, President CSUN Faculty Senate
Nate Thomas, California Faculty Association
CSUN Department of History

Memorandum: Executive Order 1100 and Executive Order 1110
This memorandum is written by CSUN’s Department of History in response to EO1100 and
EO1110 as they have been presented to faculty at CSUN. We join with the Departments of
Chicana and Chicano Studies, Africana Studies, Asian American Studies, Communications
Studies, Deaf Studies, English, Jewish Studies, Philosophy, Linguistics, Religious Studies, Queer
Studies, Social Work, and Sociology in demanding that EO1100’s mandate to eliminate Section
F: Comparative Cultural Studies be rejected. We further appeal for a reconsideration of EO1110
with full faculty consultation to effectively study the challenges faced by students needing
developmental course work and to offer well-considered and planned alternatives.

CSUN’s administration has asserted that Executive Order 1100 mandates the elimination of
CSUN’s Section F: Comparative Cultural Studies to ensure standardization across CSU campuses
and to facilitate “seamless transfer” of students within the CSU. At no point does EO1100
articulate the demand that Section F be eliminated. In fact, under Exceptions 2.2.5 the EO offers
a clear means of enabling CSUN to maintain Section F without moving or eliminating a single
class. Until the CSUN administration produces some documentation from the CO mandating the
elimination of Section F and declaring CSUN’s funding will be cut if Section F is not eliminated,
we must assume that the administration’s assertion is false. The rationale the CSUN
administration has offered for the said mandate of eliminating Section F: Comparative Cultural
Studies is of questionable validity. Finally, the form in which EO1100 has been introduced to
faculty and the university is a gross violation of faculty governance.

Does EO1100 Mandate the elimination of Section F?
EO1100 “incorporates changes recommended by faculty, students, administrators and the
Academic Senate CSU regarding how systemwide GE policy can better: (1) clarify requirements,
(2) ensure equitable opportunity for student success, and (3) streamline graduation requirements.
Additionally, the revised executive order includes a revised definition for
mathematics/quantitative reasoning (CSU GE Breadth Subarea B4), in response to
recommendations form a variety of sources [unnamed].

EO1100 establishes a maximum of 39 lower-division and 9 upper-division semester units (2.2.1
a, b, c); minimum GE grades (2.2.2 a,b); upper division requirements (2.2.3); and Residency
requirements. CSUN is in full compliance with all of these requirements.
EO1100 also includes a section titled Exceptions, which I quote in full:

2.2.5 Exceptions
Exceptions to eh foregoing requirements [listed in the preceding section 2.2.1 – 2.2.3 with which
CSUN is in compliance] may be authorized only under the following circumstances: In the case
of an individual student, the campus may grant a partial waiver of one or more of the
particular requirements of Title 5 of the California Code of Regulations, Section 40405.1 to
avoid demonstrable hardship. Each campus shall have clearly stated policy regarding such
waivers. [bold added]

1. In the case of high-unit major degree programs, the chancellor may grant
exceptions to one or more requirements for students completing the particular
program. Such exception must be approved at the campus level prior to initiating a
request to the Chancellor’s office. [bold added]
2. A student who has been admitted to a baccalaureate degree program is exempt from
additional GE requirements if:

1. . . . .
2. The student has completed equivalent academic preparation, as
determined by the appropriate campus authority.

3. Each campus is authorized to make reasonable adjustments in the number of units
assigned to any of the five required distribution Areas (A through E). The total
number of GE units required shall not be fewer or greater than 48 semester units . . .

It appears that CSUN confused the required distribution Areas (A through E) referred to in
Section 2.2.5 and 5.3.3 Lower Division Subject-Area (Partial) Certification as the only permitted
distribution areas and concluded that CSUN’s Section F: Comparative Cultural Studies, which
was developed by CSUN’s faculty, and especially its ethnic and gender and women’s studies
faculty, specifically to address the tremendous diversity of CSUN’s students had to be

If the Chancellor issued another EO that clearly articulated the demand that CSUN eliminate
Section F: Comparative Cultural Studies, which enrolled 9115 students in Fall 2016, close to
one-third of CSUN’s 30,281full-time undergraduate students, that document needs to be provided
to faculty and students at CSUN. Similarly if, as suggested, the Chancellor threatened to cut
CSUN’s funding if it failed to eliminate Section F: Comparative Cultural Studies, then the
document articulating that threat must be provided to faculty and students.

What is the rationale for Eliminating Section F: Comparative Cultural Studies?
In its letter of September 12, 2017 the Chicana and Chicano Studies Department of CSU
Northridge articulated clearly that EO1100 (interpreted as mandating the elimination of Section
F: Comparative Cultural Studies) does not make sense and, in fact, violates the spirit and the
requirements of the Student Success program introduced by the Chancellor in 2016-2017. CSUN
faculty have been advised that the change is necessary to facilitate transfer of students between
CSUs, yet Chicana and Chicano Studies notes that: “According to CSU Statistical reports,
‘Undergraduate Transfer headcount (2016-2017’, 1615 students transferred with in the CSUs out
of a total of 67,124 transfer students.” Those students who transfer from another CSU to CSUN
are covered by a waiver (as suggested in EO1100 Exceptions).
CSUNs administration has stated (though not documented) that students who transfer from
another CSU to CSUN often have to take from 3 to 6 additional units. No evidence has been
provided nor have these “excess units” been linked directly to Section F: Comparative Cultural
What is the cost of Eliminating Section F: Comparative Cultural Studies?
The Chicana and Chicano Studies Department’s letter also details the devastating impact that
elimination of Section F: Comparative Cultural Studies would have at CSUN. Their letter notes
that “67% of incoming freshman belong to historically underserved communities, most
prominently identified as Chicana/o and Latina/o, African American, and American Indian.”
They also observe that these are the very departments where the majority of faculty of color, who
may serve as mentors to underserved students, are housed in a university where faculty and
administrators remain disproportionately white and male.
What is the cost of the Proposed “Solution” to Eliminating Section F: Comparative Cultural

CSUN’s administration has proposed that the 137 classes in Section F: Comparative Cultural
Studies be moved to Section C: Arts and Humanities, which currently has 87 classes and/or to
Section D: Social Sciences, which currently has 80 classes. The requirement for Section C
would increase to 9 units and that for Section D would increase to 15 units. Students would be
required to take “Comparative Cross Cultural Overlay” classes of 3 units each in each of areas C
and D in order to “preserve” the classes that compose Section F.
1. An “overlay” does not denote the significance of Comparative Cultural Studies. This
area is crucial not only for the particular student population at CSUN, but for this
country. It should go without saying that in the context of Charlottesville, there is little
more important than introducing knowledge of Comparative Cultures. Doing so, is an
educational mandate.

2. As soon as the EO is implemented, two parallel GE frameworks will exist. A new
software tracking system will have to be developed IMMEDIATELY to provide advisors
with relevant information. This is expensive. It is unclear whether the expense incurred
justifies whatever “good” EO 1100 hopes to achieve. An immediate implementation of
the EO increases the chances the software needed to track students’ progress through the
new GE will be imperfect and, accordingly, students’ progress to graduation could be
impeded. Why the rush, particularly if it could result in disseminating bad information
that delays students’ graduation dates?

3. The immediate implementation of these EOs will put a significant strain on the advising
system. Advisors, even good ones, make errors. When advisors, with little advance
notice, confront a new GE system and must advise students who are subject to two
different systems -- some under the old, some under the new -- an increase in advising
errors is likely. Advising errors can (and do) contribute to delays in students’ graduation
dates. At a point when such delays run counter to our student success initiative, why
pursue a policy that will increase delays without producing some commensurate “good”
to offset this “bad”?

4. Given all the promises made in both EOs, implementing them immediately and
simultaneously sets us up for not being able to fulfill the promises and, in fact, makes it
likely that quality of education will suffer as we hastily try to achieve results that are not
achievable, let alone immediately achievable. “Innovative pedagogy,” (as called for in
EO1110) for example, is not developed in the snap of a finger. Likewise, faculty focused
on retooling courses to fit into new GE sections (as called for in EO1100) and scrambling
for enrollments (which will result given stiffer competition caused by having more
courses in each GE section) means faculty will be more focused on producing paperwork
and guarding “turf” and less focused on teaching (and developing “innovative pedagogy”
to serve students who are not adequately prepared to do college level work.)

5. Identifying “overlay” classes. Many of the classes in Section C and D can claim
legitimately that they include a “comparative cross cultural overlay.” In fact, many
departments offer classes in Sections, C, D, and F. Who will determine which classes
fulfill the overlay requirement? Departments that have classes in all three sections will,
in effect, be forced to compete with themselves. What will be the logic for making the
determination and who will be granted authority to make it?

6. Unintended Consequences: To address the potential “loss” of classes for key departments
it has been suggested that the Board of Trustees include CSUN’s GE Section F:
Comparative Cultural Studies in Title V. This change would entail a complete
reconsideration of a state mandated educational requirement, which technically may be
exclusive to General Education.

Executive Order 1110: Assessment of Academic Preparation and Placement in First-Year
General Education Written Communication and Mathematics/Quantitative Reasoning
Most disconcertingly, in August at virtually the same time that CSUN faculty were advised that
EO1100 mandated elimination of Section F: Comparative Cultural Studies, they were also
notified that EO1110 was to be implemented by Fall 2018.

According to E.O.1048 Mandatory Early Start Plan for CSU Northridge (Draft Plan—For
discussion Purposes only) (rev. Monday 4 Oct. 2010), in Fall 2009 75 percent of CSUN’s
incoming freshman needed developmental coursework. This need is demonstrably higher for
students from underserved, frequently economically disadvantaged, communities. According to
the CSU EO1110 FAQ of August 3, 2017 “59 percent of African American Students and 47
percent of Latino students are informed that they are not prepared for college coursework after
being admitted.” Indeed, according to CSUN Institutional Research’s Report “What is the
Opportunity Gap,” retention rates for these students are among the lowest at CSUN: 35% of
African American students and 23% of Latina/o students leave after their first year, while only
14% of white students and 15% of Asian American students leave.

EO1110 proposes to address the challenges faced by these students. To do so, it has eliminated
the English Placement Test (EPT) and the Entry-Level Mathematics Test (ELM) and disbanded
the committees that oversee them. It demands that placement of students in classes appropriate to
their skill levels shall “be based on multiple measures of academic proficiency. Such measures
may include high school English and mathematics/quantitative reasoning course grades, high
school grade point averages, grades in collegiate courses, ACT scores, SAT scores, Advanced
Placement Scores, International Baccalaureate scores, SAT subject tests or Smarter Balanced
Assessment/Early Assessment Program Scores.” (EO1110, IV. Skills Assessment and Course
Placement Recommendations)

EO1110 does not provide for evaluating differences in class content and skills learned in private
vs. public schools or schools in wealthy vs. poor districts. Nor does it create or propose the
creation of a committee that will evaluate the “multiple measures” or identify how these measures
should translate into placement. It does not weigh the distinct measures nor does it offer
prescriptive grades or scores. It could be argued that this is the purview of faculty.

Yet, EO1110 does mandate the elimination of established developmental coursework classes. It
requires that “CSU faculty provide academic support by making curricular modifications to
existing courses, by developing new courses, or by introducing innovative instructional
approaches that achieve appropriately rigorous student-learning outcomes.” The “appropriate
rigor” is to ensure that the developmental classes will grant students college credit.
Most significantly, these modifications, new courses, and innovative instructional approaches,
along with the means to measure and place students in appropriate classes are all to be done and
in place for freshman starting in Fall 2018. Faculty in the affected departments, who teach a ten
month schedule and do not officially start until August 23rd, were notified of the change in August
2017. Chairs in the College of Social and Behavioral Sciences were not notified of the change
until September 7, 2017. It’s not clear if other faculty, advisors, or students know anything about
the changes, which are to be implemented by Fall 2018.

In the August 3 FAQ on EO1110 in response to the commonly asked question how will faculty be
supported, the Chancellor’s response was that “Approximately $10 million has already been
provided to campuses for new course development and course redesign, to support advising and
to more effectively use campus data to support student success.” In other words, no additional
financial support will be provided to faculty who, with no consultation, are being asked to teach
their existing courses, while at the same time designing an entirely new system of education to
assist our most vulnerable students. In addition to being a violation of faculty governance, the
increased work that faculty will need to do to address the changes appears as a potential violation
of our union contract with the CSU.

Significantly, as with the elimination of Section F: Comparative Cultural Studies Ethnic Studies,
Departments that offer much of the developmental coursework will be disproportionately
affected. Underrepresented students, identified as at the highest risk of failing, will be treated like
guinea pigs as faculty scramble to evaluate their skills, place them in appropriate classes, and
create those classes, while teaching their current classes with students who need remediation in
core skills to succeed in college.

These policies make no sense. When the inevitable unintended consequences begin to mount, it
is hard to see how those responsible for precipitating this needless disruption will be able to
defend their actions. Virtually every department and every student, but especially
underrepresented students and faculty, will be affected by these what can only be described
generously as ill-considered changes. Those among CSUN’s administration and faculty who
assert that these Executive Orders are “mandates” and therefore must be blindly accepted –
particularly when those who have issued the mandates have not consulted with those most
directly affected and most knowledgeable of what the likely ill effects of implementing said
mandates will be; or, from all indications, have not even looked at the numbers to see if the
mandated policy will produce a quantifiable “good” to justify all the “bad” sure to accompany it –
show a staggering lack of imagination and capacity for critical thinking. Following blindly also
abdicates our responsibility as faculty to participate in the governance of the University and the
CSU system. And, in this case, accepting said “mandates” flies in the face of logic itself. Why, as
faculty, would we simply knuckle under to something that, fundamentally, makes no sense AND
undermines so many other priorities and initiatives that we all agree are more deserving of our