Commissioner of Education who is the head of the State Education Department (SED) (NY Const. art. XI, § 2; Educ. Law § 202; Educ. Law § 101). The SED carries out the policies enacted by the Regents, and is responsible for the general management and supervision of all of the public schools in the State (Education Law § 101 (/nyctap-cgi/ez-nylaw?EDN+101)). Pursuant to their delegated authority, the Regents establish the requirements students must satisfy in order to obtain a high school diploma. In the past, students could obtain a local high school diploma by passing the Regents Competency Tests (RCTs). Plaintiffs offered unchallenged testimony that the RCTs measured eighth grade reading skills and sixth grade math skills. Students who wished to obtain a Regents diploma were required to pass more rigorous tests. That system is being phased out, and a new system is being phased in. Under the new system, students are required to pass five state-administered Regents Examinations in four subject areas (English, mathematics, social studies and science) that are aligned with new Learning Standards. Students can obtain a Regents diploma evincing higher levels of achievement in mathematics, science, and foreign language by successfully completing eight Regents examinations. The State argues that the Learning Standards are aspirational and “world-class.” That the minimum requirements in order to obtain a high school diploma are aspirational, which connotes striving for something that is not necessarily achievable, may actually come as a surprise to high school students who must satisfy them. If these tests are aspirational, then the tests for an advanced high school diploma must be ultra aspirational. While some witnesses described the Learning Standards as “high” and “rigorous,” all the witnesses testified that they represent the minimum students need in order to be productive citizens.[22] In his memorandum to the Regents explaining the Learning Standards and urging the Regents to adopt them, Commissioner Mills stated: “All children need strong skills and knowledge to grow into competent, caring, productive adults and citizens in a free society. To give any student an undemanding or watereddown education is not a kindness; it's wrong.” Commissioner Mills testified that “at-risk” students can satisfy the Learning Standards, but that they require additional resources in order to do so. The Chancellor of the Regents, Carl T. Hayden testified that the Learning Standards sought to reverse the education system's “inexorable slide into mediocrity,” and that too many children were graduating but could not “demonstrate the rudiments of reading, writing and computation.” He testified that the ultimate