## AISD Response to Narrowing Letter — Draft Reply

AISD replied to my May 22 narrowing letter. They are doubling down on three positions:

### Summary of AISD's Position

1. **Item #9(b)** — They reiterate that they do not maintain between-campus transfer records in the requested format. They claim producing the data would require sharing SSI (FERPA protected) and offered a cost estimate for programming and redactions. I already declined the cost estimate.

2. **Item #4(c)** — They claim the time and cost estimates for items #4(a) and #4(b) "answered your question" about whether the District maintains campus-level expenditure detail in its financial system. This is a complete dodge — no actual confirmation or denial was given.

3. **Closure threat** — They stated they will close the request if I do not proceed with a cost estimate for #9(b).

### Proposed Reply (draft_reply)

The draft reply pushes back on all three points:

- **FERPA claim**: Aggregated transfer counts by campus/year are not SSI. FERPA protects individually identifiable records, not enrollment totals. The PEIMS data itself is already public.
- **#4c dodge**: The cost estimates are not an answer to a yes/no confirmation question. Demanding the actual answer.
- **Closure threat**: The District cannot unilaterally close a pending PIR. If they want to deny #9(b), they must issue a formal written determination with legal basis.

### Open Items

| Item | Status |
|------|--------|
| #9(b) | Open — AISD denies maintaining data in requested format, cites FERPA |
| #4(c) | Open — AISD dodged; no confirmation or denial provided |

### Draft Reply Preview

View the reply here:
http://100.118.41.122:8080/api/pir/staging/AISD-R873/correspondence_reply.txt

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