Dear AISD PIA Team:

I received your correspondence. I address the three points you raised.

#9b — FERPA argument. You state the District does not maintain between-campus transfer data in the format requested and that producing it would require sharing SIIs protected by FERPA. Aggregated enrollment counts at the campus level are not individually identifiable student information. TEA's PEIMS system publishes the same data type publicly every year. I am requesting counts, not names or IDs. FERPA does not authorize a governmental body to refuse records that are already maintained in an aggregated, non-identifiable form. I decline the cost estimate and expect the District to produce the available data without recharacterizing it as SSI-protected.

#4c — statutory basis. Your position that the cost estimates for #4a and #4b answer the statutory-basis question conflates two separate items. I asked for the legal authority under which the District relies to charge the rates and methods it priced in #4a and #4b. A cost estimate is not a statutory citation. I expect a direct answer to the question as asked.

Closure. You state the request will close if I do not accept the #9b cost estimate. Items under an active PIR cannot be unilaterally closed by the District. I am not waiving any items. The 10-business-day deadline under §552.2615(b) continues to run regardless of my position on cost estimates.

I expect responses on #9b and #4c consistent with the foregoing.

Kevin Hopper
