# PIR #AISD-R873 — Correspondence Reply Draft

## What AISD said

AISD responded to our May 22 portal message asking about #9(b) intra-district transfers and #4(c) statutory basis:

- **#9(b)** — Refused, citing FERPA. Claims producing aggregate transfer counts would require sharing "SIIs (student identifiable information)" which is FERPA-protected. Offers a time-and-cost estimate for programming and redactions.
- **#4(c)** — Claims the question is answered by the cost estimates already provided for #4(a) and #4(b).
- **Close request** — Asks us to confirm closure if we will not proceed with a cost estimate for #9(b).

## Proposed reply

The draft reply pushes back on both points:

1. **#9(b) FERPA argument** — Aggregate campus-to-campus transfer counts are not personally identifiable information. FERPA does not restrict summary data that cannot identify individual students. TEA publishes similar aggregate data via PEIMS. AISD can produce these counts without exposing student identities.

2. **#4(c) statutory basis** — A cost estimate for producing documents does not answer a question about statutory authority. The direct statutory citation is still owed.

3. **No closure** — Request remains open on these two items.

### Reply preview

http://100.118.41.122:8080/api/pir/staging/AISD-R873/correspondence_reply.txt

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