Achieving a state education finance program that is fair to students, taxpayers, teachers, and school districts is complicated by varying student needs and different property tax rates and school expenses among districts. Attempts at equitable allocation of state aid funds and other educational resources should be guided by the principles of treating everyone the same or treating individuals within groups with similar characteristics the same and providing equal opportunities to all. The equity of present programs should be assessed by measuring a district's size, per-pupil spending, tax rate, teacher salaries, relationship between wealth and spending, proportion of students with special needs, size of schools, and special problems. State assessment of revenue needs should then be adjusted for such district characteristics as wealth, tax rate, size, enrollment trends, price of education, teacher qualifications, concentration of educationally disadvantaged students, use of special programs, grade level of pupils, and possible federal grant support. (MJL)