The Data Quality Campaign (DQC) submits these comments in response to the US Department of Education's (ED) draft requirements, priorities, selection criteria, and definitions for the Race to the Top District (RTT-D) competition. DQC applauds ED for including the following components of the proposal: (1) Data is acknowledged throughout the proposal as a critical tool for students, parents, and educators to use to inform student-centric teaching and learning; (2) Data is a means to an end, and too often federal policies ignore the data implications or demands of specific strategies. The proposed criteria appear to acknowledge the data implications of its requirements by requiring districts to put in place certain data systems capacities; (3) Data cannot be leveraged to inform decisionmaking if stakeholders lack access to timely, actionable information and the training to use it effectively. The proposed language calls for providing leadership teams, educator teams, parents, and students with data, acknowledging that all of these stakeholders need training and support to ensure they have the data literacy skills to understand and use available tools and resources; (4) Local education agencies (LEAs) and schools need support implementing best practices to comply with federal and state privacy and security policies and protect student information. The RTT-D language acknowledges that critical need by requiring applicants to work with ED to put in place deliberate implementation plans that address those issues; and (5) Culture change is the most difficult part of any continuous improvement process. The RTT-D language acknowledges that putting in place tools is not the same thing as creating a culture that embraces the effective and appropriate use of data to inform decisionmaking. As such, it asks applicants to indicate how the implementation plan will translate into meaningful reform and support districtwide change. It will be difficult for grantees to demonstrate and the federal government to monitor these kinds of outcomes. (Contains 1 footnote.)