Dear Ms. Bacom:

Thank you for your correspondence dated June 5, 2026, responding to my May 22 follow-up on R000873-030926. I write on two items.

Regarding item #9b (within-district campus-to-campus transfers): the aggregated transfer counts you describe by originating campus, receiving campus, and school year are not student-identifiable information. TEA publishes inter-district transfer data publicly at the campus level through its PEIMS reporting. The District can produce the same aggregate counts without disclosing any individually identifiable student data. A FERPA invocation is not a valid basis to refuse records that are inherently non-identifiable. Please produce the aggregated transfer counts, or provide a specific statutory citation for why this data is exempt.

Regarding item #4c: a cost estimate for items #4a and #4b does not answer the statutory-basis question I asked. Item #4c asks for the specific legal authority under which the District claims no campus-level per-pupil expenditure records exist. I have not received that answer. Please provide a direct response to item #4c.

I do not wish to proceed with a cost estimate for item #9b at this time. However, the District may not unilaterally close this item. Under Tex. Gov. Code §552.2615, a cost estimate does not obligate the requestor to pay. The District's obligation to produce public information remains independent of the requestor's willingness to pay. If the District refuses to produce #9b on FERPA grounds, it must state that refusal clearly with a statutory basis, and I will evaluate my options accordingly.

Kevin Hopper
kevin.hopper1@gmail.com
