## AISD Response (June 5, 2026) — Reply Draft

**What AISD said:**
- **Item #9b (within-district transfers):** Refused on FERPA grounds. Claims inter-campus transfer activity is not tracked in consolidated format, and producing it would require sharing student-identifiable information. Offers a time and cost estimate for programming and redactions if wanted. Asks me to confirm whether I want to proceed with the cost estimate or they will close the request.
- **Item #4c (statutory basis):** Claims already answered by the cost estimates provided for items #4a and #4b.
- Reiterated that I confirmed I do not wish to pay for cost estimates.

**Proposed reply (inline):**

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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

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**Open items:** #4c (statutory basis — unanswered), #9b (within-district transfers — refused on FERPA, but I dispute the FERPA basis)

**Preview of reply:** http://100.118.41.122:8080/api/pir/staging/AISD-R873/correspondence_reply.txt

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