Policy Implementation as an Instrument to Achieve Educational Equity in the Community College Context education policy analysis For Latinx, By Latinx: Race-Conscious Leadership in Policy Implementation

This article is part of the special issue, Policy Implementation as an Instrument to Achieve Educational Equity in the Community College Context, guest edited by Eric R. Felix, H. Kenny Nienhusser, Ángel Gonzalez, Luz Burgos-López. Abstract: Policy implementation research tends to document the failures of reform, describing the myriad ways implementers miss the mark in translating intent into impact; or in the words of Derrick Bell, policy scholars are left with examining the “unfilled hopes of racial reform” (2004, p. 185). In contrast, this article presents an intrinsic case study where campus leaders took a race-conscious approach to implementing a state-wide reform known as the Student Equity Policy. I constructed the Trenza Policy Implementation Framework to center the experience, knowledge, and assets of Latinx leaders in community college that oversee and implement policy reform. The framework highlights the raced-gendered perspectives of Latinx leaders in community college to understand their motivations to implement policy in race-conscious ways (Delgado Bernal, 2002). I conducted in-depth and sustained fieldwork to learn how implementers understood and responded to state-level reform in race-conscious ways and used the policy to target and address one of the most pressing issues in higher education, the inequitable rates of transfer for Latinx students. I share how the salience of racialized-gendered identity, cultural intuition, social context, and enacting agency allowed leaders to envision more race-conscious possibilities for policy reform and its implementation on campus. understanding how examines the experiences, and outcomes for students at community colleges, a and Her research explores anti-Black ideology in existing research pedagogy on the Latinx students and the role racial classifications in scholarship production and policy implantation within higher education. Her current research project uses critical analysis of the construction of Latinidad as a racial classification to examine the erasure of Blackness and the monolith representation of Latinidad.


Introduction
Latinx students are the largest ethnoracial 1 group in California's Community Colleges, with over one million of the 2.1 million students enrolled (California Community Colleges Chancellor's Office [CCCCO] Datamart, 2020). Despite this demographic reality, there are numerous barriers to Latinx student success, including attending underfunded institutions (Dowd & Shieh, 2013), being disproportionately placed in developmental courses (Acevedo-Gil & Solórzano, 2015), facing below average course and degree completion rates (Contreras & Contreras, 2015), experiencing inequitable rates of transfer (Crisp & Nuñez, 2014), and interacting with institutional policies, structures, and practices that may not be culturally-sustaining for these students (Maldonado, 2019). Carnevale and Strohl describe these conditions within community college as "separate and unequal," creating "racially-segregated pathways" that produce inequities in experiences and educational outcomes for Latinx students (2013, p. 8).
Once in community college, Latinx students are placed in developmental courses at a higher rate than their counterparts, which delays degree completion and transfer rates. Developmental education has been described as a cyclical trap that sorts and maintains Latinx students in remediation (Contreras & Contreras, 2015). Although Latinx students make up over 46% of all students in California's community colleges, they represent only 36% of students that successfully transfer to a four-year institution after six years (CCCCO, 2020). The Latinx transfer rate is eight percentage points below the state average (47%) and 25 percentage points below the highestperforming ethnoracial group's transfer rate (57%; CCCCO, 2020). Despite reporting higher than average baccalaureate aspirations (Jenkins & Fink, 2015), Latinx students' placement in developmental courses paired with low transfer rates creates stratification bookends limiting their educational attainment.
In recent years, California policymakers have passed several reforms to increase funding for community college (AB-1809(AB- , 2018, provide additional financial aid to students (AB-19, 2018), address developmental education issues (AB-705, 2017), and improve transfer pathways (SB-1440(SB- , 2010. Although well-intentioned, many of these reforms fail to achieve their lofty goals of improving outcomes for students upon implementation (Ching et al., 2018). Of particular interest for this article is the Student Equity Policy (SB-860, 2014) and its mandates requiring campuses to develop a student equity plan that a) documents the extent of inequity for specific student populations (e.g., racial/ethnic groups), b) establishes goals and metrics to address identified equity gaps, and c) allocates funds to create or scale-up initiatives to achieve equity goals (Student equity plans, §78220, 2014). Over the last six years, the Student Equity Policy has helped community colleges build the infrastructure to address disparities in student outcomes. As a state-wide reform, there is symbolic and material importance to a policy labeled "student equity" as well as the $785 million allocated since 2014 to explicitly target outcome disparities (CCCCO, 2020). Additionally, the explicit centering of equity (i.e., achieving parity in outcomes) and inclusion of ethnoracial categories as target groups (i.e., allowing for race-conscious interventions) makes it one of a few reforms in higher education that prompts institutional leaders to identify racial disparities and 1 I use the term "ethnoracial" to consider the complexity of Latinx students as an ethnic group with shared commonalities around identity, language, and culture as well as a minoritized group that is racialized in U.S. society and higher education. I use the broader term ethnoracial since state-level policies and data use race and ethnicity interchangeably, although many scholars have noted how this collapse of differing identity markers over simplifies and essentializes key socially-constructed markers and how researchers ultimately understand the experiences of Latinx students as it relates to race and racism (See Hordge-Freeman & Veras, 2020). propose new efforts to address racial inequity in community college. This policy, as written, has the potential to be leveraged as a tool to mitigate longstanding inequities facing minoritized students, especially Latinx.
In this article, I examined the way institutional leaders understand, interpret, and implement California's Study Equity Policy to address barriers facing Latinx students in community college. I focused on Huerta College 2 , an institution found to be implementing the policy in race-conscious ways (Felix, 2020). In part, the selection of Huerta College was an attempt to move "beyond misery research" (McLaughlin, 2006, p. 6), where researchers document the failures of policy implementation. Instead, Huerta was selected to explore how implementers used state-level reform to focus on one of the most pressing issues in higher education: the inequitable rates of transfer for Latinx students. To better understand race-conscious policy implementation in community college, I investigated the following questions: (1) In what ways do implementers' backgrounds, identities, and experiences influence how they understand, respond, and enact the student equity policy? (2) What factors enable implementers to develop a race-conscious student equity plan that mitigates racial disparities in higher education?
To answer these questions, I created a Trenza policy implementation framework that "braids" different theoretical elements (See Delgado-Bernal, 2002;González, 2001) to examine the role implementers play in enacting educational policy to ameliorate inequities. Guided by this theoretical approach, I employed an intrinsic case study to highlight the ways implementers perceive, respond, and use policy in race-conscious ways. In this way, I document and share insight into how campus leaders take a race-conscious implementation approach to explicitly address Latinx inequity in community college.

Seeing Policy as an Opportunity to Achieve Educational Equity
In recent years, equity-oriented reforms have been crafted, passed, and implemented with the hopes of addressing long-standing barriers in education and mitigating the inequities faced by low-income, first-generation, and racially minoritized students (Martinez-Aleman et al., 2015). State policymakers use these reforms in attempts to improve the quality of education for minoritized students and mitigate outcome disparities have increased (Felix & Trinidad, 2020;McNair et al., 2020;Sampson & Bertrand, 2020). Reforms seeking to change the conditions for historically marginalized students include: detracking (Oakes et al., 2005), desegregation (Bell, 2004;Gil et al., 2017;Mattheis, 2016) and finance reform (Allbright et al., 2019). In higher education, equityoriented reforms target: developmental education (Ngo & Melguizo, 2016), mitigating completion gaps (Mansfield & Thachik, 2016), and improved funding and accountability (Dowd et al., 2020;Kelchen & Stedark, 2016).
Policy implementation research in education tends to document the failures of reform, describing a myriad of ways individuals and institutions miss the mark in translating policy intent into impact. Recent scholars have sought to study and understand the conditions that allow for more robust, comprehensive, and successful implementation (Mavrogordato & White, 2019;Nienhusser, 2018). A focal effort in this research is documenting the ways that individual leaders get implementation "right." For example, Nienhusser (2018), Chase (2016), and Koyama (2015) explored how individual educators make sense of policy, respond to mandated changes, and use reform efforts to improve outcomes for students. In these works, individual implementers are identified as critical factors that influence how a policy unfolds and its eventual impact.
Of particular interest for this article then is exploring how policy researchers study the individual implementer's ability to influence the understanding, process, and outcome of educational reform. Within the context of higher education, implementers can include anyone who works at an individual institution that is involved with deciding how to fulfill policy mandates (Nienhusser, 2018). For example, the implementation of a state-wide free-tuition policy may include a Vice President of Fiscal Services, Dean of Financial Aid, or student aid specialist. In addition to these more visible roles, a workgroup is typically established to include other campus stakeholders (e.g., faculty members, counselors, outreach specialists) that can help decide how the policy can be used to better support the students they serve. Thus, everyday practitioners function (un)knowingly as policy implementers. The following section examines the role of implementers and factors shaping how they move policy forward to achieve its intent.

The Role of the Individual Implementer in the Policy Process
Institutional leaders as implementers have been a focal point of policy researchers' attempts to understand the enactment of educational reform efforts (Hillman et al., 2015). Over time, the approach to studying actors on the ground-level of policy implementation has shifted (Coburn, 2016;Honig, 2006). Early work held certain assumptions of implementing actors and their fidelity to policy intent (Carley, 1980;Sabatier & Mazmanian, 1989). Scholars assumed implementers behaved rationally, held required information relevant to enactment, and aligned with the intent of a policy's goals (Lejano, 2006). Expanding the complexity of local-level policy actors, Weatherly and Lipsky (1977) described implementers as street-level bureaucrats who had the ability to dilute or reshape the intent of policy in the implementation phase. This nuance accounts for human agency, individual choice, and the ability of implementers to (re)shape policy in ways that benefitted their position, school, or overarching goals (May & Winter, 2007).
Scholars also study the ways that cognition and culture influenced what individuals did with policy opportunities (Coburn, 2001;Spillane & Callahan, 2000). Policy researchers explored cognitive aspects that shape policy understanding and implementation: meaning-making (Yanow, 2007), the influence of prior knowledge and experiences (Spillane et al., 2006), and how norms and beliefs shaped policy implementation (Coburn, 2001). From this approach, implementation success shifted to learn how "local implementers miss or misconstrue the intent of policy" and the type of change being sought by reform (Spillane & Callahan, 2000, p. 401).
More recently, policy researchers include the role of identity, power, and social context when studying the processes that shape policy implementation (Felix & Trinidad, 2020;Rodela & Rodriquez-Mojica, 2019). Scholars first ask, who these institutional actors are, what context they are embedded in, and how does identity and social position influence what power they have as implementers? This reveals the ways that social identities, like race and gender, can enable or hinder what an implementer can do with a policy. Similarly, more critical approaches examine the embeddedness of actors and how systems of power constrain or enable their ability to carry out implementation (Donaldson & Woulfin, 2018). Reviewing the literature, I highlight three elements to understand the complexity of individual implementer and the role they play in carrying out educational policy. First, the implementers' identities and background (Mavrogordato & White, 2019); second, their capacity and willingness to lead implementation (Nienhusser, 2014;Tummers et al., 2012); and third, their equity-minded competence to leverage policy for change (Chase, 2016;Dowd & Bensimon, 2015). These elements distinguish the ways implementers see, understand, and use policy through equity-minded and race-conscious ways.

Humanizing the Implementer: Their Social Identity, Prior Knowledge, and Experiences
This article highlights how social identities, experiences, and beliefs shape how implementers carry out educational reform at the local level. Policy research traditionally treats implementers as "stable actors" in the policy process (Coburn, 2016), devoid of social identities, campus status, personal beliefs, or professional motivations that enable or constrain their ability to lead change efforts. We have limited research that explores how race, gender, social status on campus, or personal educational experiences influence an implementer's ability to lead reform efforts. Recent scholars (Felix & Trinidad, 2020;Mavrogordato & White, 2019) exploring policy implementation as a lever for social justice advocate for understanding the differential experiences of implementers based on their social identities (Hankivsky & Cormier, 2011). For example, would the experiences of implementing policy changes in community college be the same for a Black, femme, pre-tenure faculty to that of a White, male, long-time faculty member?
Thus far, our research has failed to understand the complexity of social identity, notions of power and privilege on campus, and the potential ways that a Black femme implementer may face additional challenges to enact reform than a White faculty member who may be empowered to lead these same efforts (Collins, 2015;Liera, 2019;Patton & Bondi, 2015). Liera and Dowd remind us that Latinx and Black educators face "unsupportive social contexts" in higher education and that must be accounted for when exploring how local-level actors attempt to carry out intended policy reform (2019, p. 274). This call for "humanizing" policy implementers acknowledges the critical importance of social identity and the ways that being a racially minoritized leader creates additional obstacles as well as new opportunities to respond and carry out transformative equity-oriented change in higher education.

Capacity, Expertise, and Willingness to Implement Policy
A second area of research framing this work is the role of capacity, expertise, and motivation within the implementation process. When formulating policy at a state-or federal-level, little accounts for the time campus leaders have, their experiences with overseeing system-changing reforms, or their level of buy-in with the intended change (Malen et al., 2014). Mazmanian and Sabatier (1989) spoke of the need to examine a policy's ability to structure statutory (i.e., objectives, resource allocation) and non-statutory (i.e., social conditions, public support) elements. Specifically, they advocated for researchers to examine the "commitment and leadership skills of implementing officials" as these characteristics could shape implementation as much as the theory of action or fiscal incentives attached to a reform (1989, p. 22). Once the reform gets to the local-level, implementation is directly shaped by an individual's capacity to lead, familiarity with how change occurs, and motivation to achieve reform goals (Kezar, 2014).
When describing capacity, policy researchers include workload prioritization (Dowd & Bensimon, 2015), the time available for this responsibility (Malen et al.,204), and resources at their disposal (Chase, 2016). For example, when implementing reform, does an educator have the opportunity to shift existing responsibilities to focus on this new effort, or does the policy provide resources to form a small team on campus to carry the mandates forward? By examining capacity, policy researchers capture constraints that influence an individual's ability to comprehensively understand a policy's intent, the extent of change required on campus, and resources available to do the work required of the policy. Hillman et al. (2015) note that many policies fail to achieve their goals in higher education, once it "gets on the ground" as implementers "simply do not have the capacity to enact change" (p. 14). Kezar (2014) asks: how do we know that implementers are familiar with how change works or with effective organizational change strategies? When studying implementation and implementer's role we must account for (un)familiarity with leading change efforts and how this potential newness influences the end result of policy enactment. Similarly, Tummers and colleagues add that an implementer's willingness to oversee and lead the process is critical (2012). They find that an individual's willingness to lead an effort and complete the task of implementation is directly related to the attractiveness of the idea (i.e., desegregating schools), the personal and social (i.e., improving equitable schooling) meaningfulness of the policy, and the discretion perceived to lead efforts in their own style or preferred approach. This scholarship highlights how willingness informs an implementer's commitment to achieving policy goals, especially ones that carry more significant change. Examining how capacity, expertise, and willingness influences implementers' ability to carry out equity-minded reform provides nuance in policy research and helps to understand why well-intended reforms seeking equitable results may fall short of their intent.

Equity-Minded Competence
Many of today's policy reforms seek to address the shortcomings of previous efforts (i.e., unstructured transfer pathways to Associate Degrees for Transfer) or attempt to create more equitable environments and outcomes for students (i.e., Guided Pathways, Improved Funding Structures). In order to fulfill the complex mandates of these reforms, implementers need more than experience, capacity, and willingness to address longstanding barriers on campus that contribute to student inequity. Implementers need to build their equity-minded competence and awareness of social contextual factors not only to understand the root causes of policy problems, but also to compensate for policy design flaws and to respond to equity-oriented change. Bensimon (2007) developed principles of equity-mindedness to highlight the role institutions and practitioners (i.e., faculty, staff) play in implementing policies intended to improve educational outcomes for racially-minoritized students (Bensimon & Malcom, 2012). The characteristics of equity-mindedness include: (1) being race-conscious, as opposed to race-evasive; (2) being cognizant of structural and institutional racism as the root cause of inequities; (3) recognizing that to achieve equity it may be necessary to treat individuals unequally as opposed to treating everyone equally; and (4) being able to focus on institutional practices as the source of failure rather than student deficits (Bensimon & Malcom, 2012). Similarly, Baez (2000) asserts that critical agency, awareness of inequities, and resistance of hegemonic practices are necessary for higher education to challenge existing practices and structure institutions to better serve people of color. Recent work by Liera and Dowd (2019) found that faculty who possess higher levels of equity-minded competence are able to "identify their roles as change agents," expand their perspectives on the type of change required, and advance policy change toward improved racial equity (p. 481). Equity-minded competence serves as an important element to understand the disposition of individuals and their ability to take action within the implementation process. Thus, exploring how individuals embody equity-mindedness and apply it during implementation is a critical element to understand in this study.

Theoretical Framework
Seeking to better understand race-conscious implementation that highlights the critical role of individual leaders in the enactment process, I developed the Trenza Policy Implementation Framework. Dolores Delgado Bernal (2002) spoke of the need for a theoretical "trenza" in which researchers' "braid" distinct theoretical elements into a framework that can critically examine educational policy that seeks to ameliorate racial inequities (p. 116). Similarly, Young (1999) introduced the multifocal approach as a way of enhancing traditional educational policy studies by coupling rational and critical theories to create a more comprehensive portrait of the policy problem being studied. Broadening the range of theoretical elements allows me to study policy implementation with the strengths of traditional approaches as well as to employ more critical ones that highlight the ways policy impacts specific communities, such as Latinx students (Calderon et al., 2012). Drawing on these foundational works, the Trenza framework emphasizes ways individual leaders and their social identities shape how reform is understood and policy is leveraged to address inequities facing racially minoritized students.
Before describing the theoretical elements included in the framework and how they are operationalized, I reflect on my use of this theoretical approach. I want to be explicit that this framework is guided by the work of Chicanas, Latinas, and mujeres of color who once proposed these theories as means for survival in the academy, to represent themselves in spaces that rendered them, their identity, experiences, and research invisible. Influenced by their work, the Trenza framework provides a different approach to learning, understanding, and highlighting the role of individuals in the policy implementation process. This is especially important as the implementation leaders at Huerta College identified as Latinas themselves. Using the Trenza framework, my hope is to conduct policy research that centers people, their identities, and the uniqueness they bring to lead the implementation process in community college.

The Trenza Framework: Braiding Theory to Make Sense of Policy Implementation
This framework draws on a rich history of policy theory-rational, interpretive, critical-to form a theoretical lens that allows me to examine the racialized, gendered, and institutional factors influencing policy implementation in community college. Coburn shares that "all theories of policy implementation have at their root assumptions about the nature of human action" (2016, p. 465), thus it is important to unearth hidden assumptions about implementation and the role of human actors. The Trenza framework makes an explicit connection between the researcher's approach to policy analysis, the theories utilized to understand implementation, and the methods used to account for individual actors' direct influence on how reforms unfold. Each approach shares a different account of what implementation is and the individual actor's "choice" and "influence" on how enactment occurs on campus (Coburn, 2016;Nienhusser, 2018). The Trenza framework can be visualized as a three-strand braid that weaves together distinct theoretical elements to take a critical and comprehensive account of the ways education policy is implemented in community college (See Figure 1).

Trenza Policy Implementation Framework
From the rational approach, I draw on theories that help examine the Student Equity Policy's design and mandates (Mazmanian & Sabatier, 1989), theory of action (Schneider & Ingram, 1993), instruments employed (McDonnell & Elmore, 1987) and the ways that implementers are able to interpret them. This strand highlights how the structure of reforms influences local implementation, asking: Are the mandates written in a clear and consistent language? Does the policy acknowledge the extent of behavioral change required? Does the policy include instruments to motivate implementers? This is especially helpful for understanding the hows and whys of implementation, and how certain factors with the design of the policy influence what individual implementers can do with it on campus.
Interpretive theoretical elements inform the second strand, include sensemaking (Nienhusser, 2018;Spillane et al. 2002), organizational culture (Chase, 2016), structure-agency (Coburn, 2016), and interpretive policy analysis (Yanow, 2007). Interpretive approaches argue for a cultural and cognitive understanding of implementation that explores actors' prior knowledge, norms and beliefs, and routines and practices. A sensemaking approach focuses on uncovering how individuals develop an understanding of equity -whether it aligns with the policy or foregrounds racial disparities. The framing of policy as a tool for equity and the implementers' understanding of it drives the entire implementation process. Yanow (2007) puts an explicit focus on understanding meaning-making; understanding the meaning of the policy text, the meaning-making of the social actors, as well as the researcher's own meaning-making process. The interpretive strand asks the researcher to understand: How does equity get conceptualized and understood by implementers? What is the role of sensemaking in responding to the mandates of the Student Equity Policy? How does the culture (i.e., shared beliefs, historical context) of a community college influence the ways individuals can implement the policy on campus? Interpretive theories help to illuminate how social context, institutional culture, and individual cognition shape the implementation of educational reform.
Critical theories inform the third strand and include Critical Policy Analysis (Young & Diem, 2017), Critical Race Theory (Delgado & Stefancic, 2017;Ladson-Billings & Tate, 1995), racedgendered epistemologies (Delgado Bernal, 2002), and equity-mindedness (Bensimon, 2007;Bensimon & Malcom, 2012). Critical Policy Analysis (CPA), as starting point, recognizes that policies are inherently biased, value-laden, and need to be interrogated. CPA foregrounds dimensions such as race and gender, and uses that lens to examine racism or sexism embedded in policy. Critical Race Theory (CRT) allows me to highlight the importance of social and historical context in policy analysis and center the ways race and racism shape how policies are crafted and implemented within education. Equity-mindedness spotlights how campus leaders use policy to advance equity in race-affirming and culturally relevant ways (Bensimon & Malcom, 2012;Dowd & Bensimon, 2015). Lastly, raced-gendered epistemologies center the unique role of individual implementers and ways they draw on their social identities, lived experience, social status, and cultural backgrounds to leading implementation. These theories help to uncover how and why implementers see policy in race-conscious ways and leverage reform as an opportunity for campus transformation rather than technical compliance.
My work builds on the tradition of scholars using policy research to illuminate issues of power, marginalization, gendered dynamics, and structural racism that influence what can be achieved with reform and how implementers are constrained or enabled to use policy to improve the conditions for historically marginalized groups. The Trenza framework centers the experience, knowledge, and assets of Latinx leaders in community college who oversee and implement policy reform. Inspired by Chicana/Latina scholars, I use the framework to highlight the raced-gendered perspectives of Latinx leaders in community college and to understand their motivations to implement policy in race-conscious ways (Delgado Bernal, 2002). By holding conversation between these theoretical approaches, I draw on the strengths of rational, interpretive, and critical theories to examine how individual implementers understand and use policy to address racial inequities on campus, specifically for Latinx students.

Research Design
Through an intrinsic case study (Stake, 2005), I highlight the complex interaction of people, policy, and place during the process of implementing educational reform in community college. An intrinsic design allows for an exploratory process to learn more about the case itself and the uniqueness of the implementers at Huerta College. I immersed myself at the site for over 18 months and collected multiple sources of data to generate a comprehensive perspective and deeper understanding of the implementation process (Merriam & Tisdell, 2016). This approach is especially resonant for educational policy research, as multiple actors, policy interpretations, and contextual differences across institutions often lead to varied implementation with differing outcomes (Nienhusser, 2018). The application of case study research also provided an opportunity to address the call by Koyama (2015) for policy scholars to use critical and qualitative approaches to contest the growing trend of "technical and rational educational policy… seen as efficient and practical" and move towards uncovering the complex social processes between policies, implementers, and perceived beneficiaries (p. 547). The research design is guided by the Trenza framework and the need to learn how practitioners used their "identities and histories" to "variably interpret, negotiate, and selectively appropriate policy" to address Latinx students in transfer, while other community colleges did not (2015, p. 549).

Site Context
Driving to Huerta is a lesson in understanding the campus context and highlights the richness of the predominantly Latinx area surrounding the institution. Exit the freeway: you are greeted by signs for the local Mercado Azteca; across the way is the Tortilleria Coyolxauhqui; you can smell the harina for blocks. Past these shops is a community center with an image of La Virgen de Guadalupe, a spiritual and cultural symbol for the heavily Mexican and Mexican-American area. Closer to the community college, you pass two elementary schools with Latinx surnames welcoming the students as they enter the gates. Outside one of these school buildings is a set of murals depicting the Chicanx history of the area and a tribute to Cesar Chavez, Dolores Huerta, and the United Farm Workers. Arriving on campus, you see a Latinx surname boldly displayed across one of the newest and tallest buildings, honoring a longtime college president. As you move through the space and see students, you can easily appreciate Huerta's status as a Hispanic-Serving Institution (HSI) with a Latinx enrollment over 70%. Although surrounded by all this cultura, the campus struggles to support Latinx students who seek to transfer to a four-year college. Huerta has been described as "intensely segregated" with "extremely low transfer rates" for Latinx students by UCLA's Civil Rights Project (2012). For years, Latinx students, its largest student group, have experienced the lowest rates of success in transfer and longest time-to-transfer rates on campus (CCCCO, 2019).
Huerta serves as an ideal site for an in-depth inquiry into policy implementation for multiple reasons. First, Huerta is a unique campus that has spent the last four years, 2015-2019, leveraging the Student Equity Policy to develop and implement various projects to make the campus a more equitable environment for Latinx students. A recent analysis conducted of 33 HSI community colleges in the state found limited implementation efforts to address transfer in general, or more specifically Latinx transfer equity (Felix, 2020). Huerta was distinctive among the colleges examined in that it developed its equity plan and allocated its funds to establish new Latinx-focused transfer efforts. Second, as one of the largest community colleges in the state, Huerta has been a top-five recipient in equity funds, receiving over ten million dollars between 2015 and 2019. Of the over $3 million it was awarded in 2015-2016, the campus designated over a third of those funds to explicitly improve transfer for Latinx students. Given the amount of equity funds and how they were allocated, it was important to explore how the new resources provided by the policy prompted campus leaders to create a more Latinx-conscious and transfer-focused student equity plan (Ching et al., 2018;Harris et al., 2017).
Lastly, Huerta has unique institutional characteristics that contribute to our understanding of policy implementation (See Table 1). At the time Huerta was identified, the campus enrolled over 50,000 3 students annually, of which 70% were Latinx students. With such a high concentration of Latinx students, the school easily surpasses the 25% enrollment threshold to be identified as a Hispanic-Serving Institution. Its HSI designation was not only reflected in the students it served, but also in the senior administration and individuals involved with the implementation of the SEP. The Campus President, the Vice Presidents for Academic Affairs and Student Services, and the majority of implementing actors involved in the effort were Latinx. Moreover, Huerta employed a higher rate of Latinx in administration, tenure-track faculty, and classified positions than its district or system (CCCCO, 2019). Given the growing Latinx demographics in the state and nation, Huerta provides a worthwhile site to explore and learn strategies employed to support one of the largest student populations in higher education. 3 Numbers and percentages reported in narrative and tables are rounded to try to protect institutional anonymity. 4 Completion in community college is referred to as the "SPAR Rate" which includes percentage of successful students to complete a degree, certificate, or transfer-related outcomes after six-years. 5 Based on US Census data pulled from the primary zip code of the institution.

Site Access, Building Rapport, and Researcher Positionality
It is important to note how I accessed Huerta College as well as the influence of my identity and positionality as a researcher in this study. I gained site access through a research partnership established in 2014 with USC's Center for Urban Education to support campus administrators with identifying and addressing Latinx transfer inequity. Through this project, I built rapport with administrators overseeing implementation and sought to document their efforts in using the Student Equity Policy to mitigate racial disparities, which resulted in this study. As Latinx scholar, my ethnic identity was an asset during fieldwork allowing me to easily interact with practitioners on campus and enter organizational spaces that gave me an on-the-ground understanding of policy implementation. As a critical policy researcher, my commitment was to examining the ways policy and its implementation benefit, harm, or render invisible racially minoritized students in community college. I firmly believe that policy provides legislative opportunities to transform campuses and how they serve students. As with all my scholarship, I was compelled to counter traditional notions of policy analysis (Anderson, 2012) and tell the story of Huerta College: the race-conscious approach taken by institutional leaders of color to respond and leverage policy to explicitly address persistent inequity facing Latinx students.

Data Collection
The data presented includes conversations with 11 implementation leaders and more than 20 observations of meetings related to enacting the student equity policy (see Table 2). Interviews were a key aspect of this study and represent the chief means through which I gathered participants' understanding, involvement, and experiences. In total, I conducted 18 semi-structured interviews (initial and follow-up) with various administrators, faculty, and staff who played a role in the development and implementation of Huerta's student equity plan. Specifically, I examined the role of the individual actors, their social identities, their capacity to carry out implementation, and their commitment to work towards the development of reform goals (Marsh et al., 2013;Nienhusser, 2014). The primary setting observed was within student equity committee meetings, the workgroup responsible for implementing the Student Equity Policy, creating their student equity plan, and coordinating activities described in them. In these collective spaces, individual actors worked together to fulfill policy mandates. Table 2 provides a summary of the participants that oversaw the implementation of the student equity at Huerta and some key characteristics (e.g., race, gender) relevant to this study.

Analytic Strategy
Data analysis began simultaneously with data collection, allowing me to conduct an iterative analysis of the data over time, and to identify emerging insights and themes, refine the collection process, and develop a more comprehensive understanding of the case (Patton, 2002). Once I completed my fieldwork, I proceeded to analyze in five phases, helping me to organize, interrogate, and present my data in ways that illuminated factors that shaped the implementation process at Huerta. In Phase 1, I wrote analytical reflections upon entering the field and commencing data collection. These reflective memos helped summarize and synthesize the various materials collected and produced (Emerson et al., 2011). Phase 2 focused on reviewing and sorting data upon completing fieldwork. I sorted my data into three buckets: interviews, observations, and documents, to see how each source of data contributed information pertinent to my research questions. Once I took stock of the materials collected and experimented with different analytic strategies, I used analytic questions (Neumann, 2006;Neumann & Pallas, 2015) to examine the full corpus of data during Phase 3. This analytic strategy can be described as taking a "small shovel, shaped (and iteratively reshaped)" to "scoop out" relevant data that helps the researcher answer their questions (Neumann & Pallas, 2015, p. 166). From the analytic questions process, I had 370 excerpts from 18 interviews and 20 observations that helped describe the role policy design, institutional context, and individual actors play in implementing the Student Equity Policy in community college.
In Phase 4, I theoretically coded (Merriam, 2011) the subset of data to help identify patterns and emergent categories (Neumann & Pallas, 2015). I utilized a two-stage approach whereby all 370 excerpts were reviewed and coded using the elements of my theoretical framework. This process was done using Microsoft Excel. In the final phase, I worked towards identifying patterns, descriptions, and events that highlighted how the SEP was implemented on campus (Charmaz, 2009). As a result of these analytic phases, four themes capture the experiences of Latinx leaders interpreting and implementing policy in race-conscious ways. These findings highlight how individual actors' social identity, experiences, and equity-minded competence prompted a raceconscious approach to policy implementation at Huerta College.

Race, Identity, and the Possibilities of Policy Reform
The first theme explores the importance of who the institutional leader is and how their individual characteristics shape the possibilities of what can be achieved during implementation. At Huerta, the responsibility to carry out the mandates of the planning policy were given to a longtime Dean of Institutional Research, but a few weeks into the process he suddenly resigned (See Figure 2). This vacancy led Emilia Leon, Dean of Student Services, to take over the process and bring a different approach to crafting Huerta's SEP. This shift in implementation leadership was pivotal as Emilia had a grander vision for equity planning, informed by her identity as a Chicana activist from the Huerta barrio, historical understanding of the reform's focus on improving outcomes for "ethnic minorities," and commitment to creating campus efforts for specific groups like Latinas and men of color.

Figure 2
Timeline of Huerta's Student Equity Plan Development

Identity as a Chicana Activist
Emilia Leon, a self-identified Chicana faculty member turned administrator, grew up in the Huerta barrio and strongly identified with the history of Chicanx activism, including the walkouts of 1968 6 and subsequent protests over unequal education. When we spoke of what drove her commitment to racial equity, she brought up her lifelong involvement in activism. At the age of eight, Emilia accompanied her older siblings to "La Raza Coalition" meetings, giving her a taste of student activism and community organizing. Emilia described her ties to the campus and the surrounding area, sharing, "I used to demonstrate here, I tell the story to my students about my issues coming from poverty, how it drives me, and how I always stay engaged with activism in the [Huerta] area." Emilia mentioned that throughout her educational and career trajectory, she has been called to work with and for her Latinx community. Her roots in the Huerta community and her activist mentality deeply informed her approach to leading the process on campus. She added, "I brought that same energy and commitment I had as a Latina faculty member to the implementation of the student equity and what we could achieve with it."

Understanding the History and Opportunity within Policy
Emilia did not anticipate overseeing the entire equity planning process when initially asked to help out, but she seized the opportunity when presented with it. Once named the planning leader, she examined policy documents from the 1990s to see what had been done in the past, what student groups had to be addressed in the plan, and what kind of efforts could be initiated on campus. The more she learned, the more she realized "student equity [was] a really valuable project," seeing it as "opening a box with opportunities to make a difference." She quickly recognized the potential, 6 Under a wave of student activism, these organized walk-outs demanded better teachers, improved resources, and equal education, in particular for Chicanos, Mexican-American, and students of Mexican descent. sharing that the policy allowed her campus and division to "improve the services offer[ed]" and "be more targeted with our efforts" to mitigate equity gaps. Emilia saw the policy as a way to address problems that couldn't be talked about openly at Huerta. For example, she shared how some oncampus saw developing culturally-relevant transfer programs as "running boutique programs" or providing additional resources to specific ethnic groups as practicing "reverse discrimination." She recognized that the policy mandated a systematic examination of educational outcomes by race and ethnicity and required that investments be made toward closing equity gaps. When asked about what she remembered when first reading the mandates and what she could do as the person overseeing it, she smiled and said: I just thought, I can't believe the state is funding this. Nobody wants to talk about equity. Nobody wants to talk about racial inequality and social injustice and how we can make changes. That's what I was excited about. I thought it was a good time to bring together people on campus that could unite and really try to push forward the agenda on equity.
Emilia Leon's long history of social activism and commitment to racial justice enabled her to see the policy as an opportunity to genuinely address issues of "racial inequality" and "social injustice" at Huerta. New to overseeing implementation, she brought a different imagination of what could be achieved with the reform and how it could benefit Huerta.

Envisioning the Racial Possibilities of Policy Reform
For her, the SEP was a "new opportunity to transform the campus" and live up to its commitment to Latinx students who entered Huerta with transfer aspirations. Emilia viewed the policy as a form of empowerment to accomplish an agenda that was important to her and other Latinx campus stakeholders. Not only did she have a race-conscious vision for the planning process, but she also had a steadfast commitment and willingness to move implementation forward. Participants described Emilia as a "champion" for equity, someone who "marathoned" the implementation process and was able to "push through" the proposed ideas with faculty, academic senate, and board of trustees. Participants acknowledged that her passion was not just about student success for all, but also focused on those student groups that needed additional support to achieve their educational goals. One practitioner involved with the planning process shared, "She's an amazing champion for so many different efforts. She's very committed to improving student outcomes, specifically for people of color and women." Her status as a campus leader, willingness to coordinate the planning effort, and historical understanding of student equity's priority to address ethnic and racial inequity enabled her to focus the plan on the barriers that Latinx students face on campus. As implementation leader, Emilia's next step was to recruit a workgroup and fulfill the policy mandate of identifying gaps in educational outcomes as well as posing potential strategies to address and mitigate those equity gaps.

Assembling the Student Equity Implementation Team
The second theme highlights sensemaking, shared motivation, and having a critical mass of Latinx leaders committed to addressing student inequity. Huerta, like other campuses in the state, had the discretion to determine what "broad campus and community participation" meant in developing an implementation workgroup (Student equity plans, §78220, 2014). Vague language and the newness of the planning process, enabled Emilia to recruitment individuals who shared a commitment to social justice and equity and aligned with her vision to use the policy as a means to address racial disparities in transfer and completion for Latinx students.

A Shift from Constituency to Competency
Aiding this recruitment process was the informal nature of the student equity workgroup. As an ad-hoc committee focused on the implementation of a single policy, the student equity workgroup operated outside the typical structure established by shared governance rules. 7 For example, a long-standing requirement of the union contract was that committee appointments had to be filled by representative stakeholder groups such as employee-type (i.e., classified staff), specific academic units (i.e., social science, liberal arts), and functional areas (i.e., student services, workforce development). According to two planners, these rules of representative membership in formal committees were described as the "Noah's Ark" approach, where the priority was to have two people from different sectors of the campus serving on decision-making bodies. At Huerta, this usually resulted in committees being filled randomly with two faculty union representatives, two counselors, two classified staff, and so on. In Emilia's experience, "implementation becomes difficult" because people involved are "representing just their area" rather than "what's best for the campus or students" and ultimately, she felt that "very little change occurred." Instead, she intentionally recruited people based on their competence around equity, selecting vocal leaders from across the campus that were like-minded and also concerned with improving how the campus supported students.

Seeking Like-Minded, Student-Centered, and Equity-Driven Practitioners
The implementation workgroup consisted of people who were aware of issues of equity and racial disparities and had expertise in program development, as well as individuals that possessed social status at Huerta College that could help push the plan forward. Emilia shared some specific characteristics of the planning workgroup: [Members] had a strong work ethic. They were ready for a challenge and were very fluid in terms of working with something new. And the biggest thing was how they viewed students. Students are an asset on campus, they [didn't] talk about what students can't do. We had a collective vision that we're here to help students find their self-agency, and could use the [plan] to be much more organized and efficient to help them be successful.
Lola Velazquez, a Chicana who attended and transferred from Huerta, elaborated on the ways that the people included in the planning process made sure that the ideas, programs, and resources were centered on students and their goals of transferring from Huerta. Lola described that "in this kind of group," it was important that the members be "student-focused and have a commitment to ensure that resources be provided to Hispanic students." She added, "The reason we were selected, it was not random, we were all selected because we had the actual expertise and an actual interest in students' success." Stacy Ramirez, a Chicana from the area and Dean at Huerta's regional campus, echoed that sentiment, sharing that the practitioners involved in this workgroup "were more concerned with students' learning and success." Dr. Nancy Ortiz, Latina and Vice President of Workforce, shared, "We're dedicated to our students. We know that every student has a story, every student needs to get through, and there's a reason why we're at [Huerta]." She 7 An implementation progress report by the Legislative Analyst Office in 2016 showed that community colleges had an array of configurations to develop an equity plan from advisory groups, informal working groups, ad-hoc subcommittee, or folded into existing planning-related committees in the shared governance structure.
continued, "We were most passionate about historically marginalized groups," specifically "Latino, low-income, and immigrant students."

A Tie to Community, A Commitment to Change
It was clear that the members of the planning workgroup had strong ties to the campus and the surrounding community. Lola added, "We hire people who want to serve our community and [who] come from it, and know the struggles and aspirations our students have." Lola continued to describe the intentional practice of hiring from the area: "Our former president, he did his best to hire people who had a vested interest in the community and might've been [Huerta] alums." Lola reflected on this strategic hiring practice, "that local identity has helped to form who we have here. To have people who have a social justice background. And a large percentage of our campus, our faculty, administrators, and staff are Latino and first-generation college students." Rey affirmed this sentiment: "Here, we hire our own," because people from Huerta have a "higher commitment to student success." Stacy Ramirez, who began as a librarian in the 1990s, encapsulated the idea of hiring educators from the community: I love working at [Huerta]. I love the students. I love the community. This community college is a symbol of opportunity, a symbol of potential and possibility for… cultural, academic, and generational success. My in-laws live down the street. They brought their children, my husband, to [Huerta] when they were kids for summer programs. This is one of the stepping stones for a lot of families in the neighborhood to be successful. And it's predominantly a Latino working-class community that I feel very connected to.
Implementers like Stacy Ramirez and Rey Valenzuela shared how they grew up nearby and were inspired by the rich history of activism. Stacy reflected, "Growing up here, a lot was going on with the Chicano Movement," and it shaped her desire "to go to college, get educated, and give back to the community." Although she went to the Midwest for college to study library science, she added, "I had this drive and desire, I wanted to get back to the community and I needed to be here in [Huerta]." She concluded, "I was not raised with books in the home. Becoming a librarian was kind of like a contradiction because I was never in a library, you know, but I wanted to change that experience for kids in the [Huerta area]." Rey also shared that he was always drawn to working at Huerta; he commented, "When I got the faculty job, I knew I was home. It was strange, but that's what was calling me to come back." Within the implementation workgroup, six members emerged as more transfer-focused practitioners who wanted to use the policy and planning process to improve transfer services. This transfer-focused sub-group included individuals with three types of experiences: they had successfully transferred from Huerta themselves (Rey, Lola), had worked in programs to improve transfer (Stacy, Nancy, Emilia), or had conducted research on the transfer process (Nancy, Marissa). For example, Nancy Ortiz was one of the leading voices in the planning workgroup advocating for transfer. She grew up in the neighboring area of Huerta and had been on campus for over 15 years as a faculty member and administrator. Nancy was known for successfully acquiring a Title V grant to improve transfer for Latinx students and applying her doctoral research to develop programmatic efforts that supported Latinas' transfer aspirations. Similarly, these transfer-focused practitioners shared that they had long been advocates for improving the conditions and experiences of transfer on campus. Lola shared that "there was a commitment to transfer before" but "there wasn't much coordination…or institutional efforts being offered." She lamented, "It was unfortunate, but that was the reality." Implementing the SEP gave these transfer advocates the opportunity to propose race-specific, culturally-relevant transfer efforts to combat the low rates of transfer success on campus. This carefully curated workgroup significantly impacted the implementation process and how the policy was used to explicitly target the transfer barriers facing Latinx students at Huerta.

Advocating for Latinx-Students in Equity Planning
The third theme showcases implementer's collective advocacy and how they were able to leverage policy mandates to create new initiatives that explicitly addressed transfer barriers facing Latinx students. With the workgroup assembled, Huerta began to develop their SEP and prepare for multiple phases of review and approval. Over a three-month period, the workgroup focused on a) examining campus data and identifying equity gaps, b) deciding which student groups to prioritize, c) developing goals and activities to mitigate identified equity gaps, and d) providing a budget and evaluation strategy to implement the plan. This section highlights the workgroup's collective advocacy and how they were able to leverage the policy mandates to create new initiatives that explicitly addressed inequities facing Latinx students.

Conducting Data Inquiry into Student Inequity
Among the first steps in the planning process was conducting a campus-based inquiry into five academic indicators 8 for specific student groups (i.e., students of color, women, foster-youth, veterans) outlined in the policy. The workgroup received a set of "data packs" for each indicator area from their institutional research office. The five "Equity Plan Data packs," as they were known, contained student profiles, data tables, and charts to visualize the disparities on campus. These data reports served as confirmation for some practitioners with long-held beliefs that Huerta was not serving Latinx students effectively. For others, it was more of a discovery, unveiling previously unknown inequities on campus. One participant shared, "For me, the data were eye-opening, because I was new [to Huerta]. It was an eye-opening experience to see the numbers." For others, like Lola, one of the transfer-focused members of the workgroup, the data confirmed her prior beliefs: "I always knew that's who needed the most help. We are a Hispanic-Serving Institution, the majority of our students are Latino and are the ones struggling the most. I mean it is ridiculous to not acknowledge those facts." The data packs were a springboard for additional inquiry. Nancy commented, "We had so many questions after the first meeting" and "we asked for more data." Nancy continued, "We further dissected the data and we looked at momentum points and the time it took to transfer." She continued, "there were lots of variables acting as barriers for Latino students, math that was tripping the progress because they're repeating and getting stuck there." The workgroup continuously asked for additional data to help them identify which students were facing the largest equity gaps on campus. Santiago, an institutional researcher, recollected: I worked with all the indicator areas, but I spent more time working with the transfer group. We looked at the standard data reports, but we also went beyond, we did follow-up research where we actually found out that there were a large group of students who graduated after the first 10 years. I don't know about the percentage, but let's say 20%, of the students in those cohorts, were graduating 10 or 15 years later and what we found out was that the majority of those students were Latinas.
As the workgroup pored over data charts, tables, and reports, they recognized that the evidence pointed towards the need to support Latinx students, especially in transfer. 8 Access, basic skills progression, course completion, degree completion, and transfer

Leveraging Data Inquiry to Advocate for Latinx-Specific Programs
Implementers spoke of the importance of having state-manded efforts to disaggregate data based on race and ethnicity. "Having race-based data," according to Nancy, made these transfer inequities "so evident" and much more "glaring," as if they were "screaming at you" to address them. Rey shared that one of the most "critical things [they] learned was the time it took to transfer for Hispanic students." Nancy provided the data points referenced by Rey in a chart titled "[Huerta]'s Time of Completion for Transfer," showing the time to transfer by gender and ethnicity within a 12-year period ( Table 3). The average time to complete transfer for all students on campus was nearly five and a half years, but Latinx students took the longest of all ethnoracial groups, nearly seven years to transfer. When the chart data was disaggregated by gender, Latinas had the longest completion time, over eight and a half years. Additionally, Nancy had circled the section of the chart displaying that of the 584 Latinas in the cohort of 1392 analyzed, 42% (248) of Latinas took more than 10 years to successfully transfer. During one of our conversations, Nancy went to her filing cabinet and pulled out her files from the 2014 planning process. Reflecting on her handwritten notes and circles around the number of students that did not transfer out of Huerta, she remarked, "We looked at the transfer number, disaggregated that by race, gender, time to completion, and who's going to the UCs, it was just dismal." She then shared, "The data just screamed at you. It really gave us an opportunity to run with the numbers and say this is a priority because it was really glaring that Latino students weren't working their way through [Huerta]."

Developing Latinx-focused Transfer Programs
Once data inquiry was complete, there was less guidance as to how to develop interventions targeting identified equity gaps or to distribute newly allocated resources to support implementation of these planned equity efforts. The policy guidelines were also silent on how to evaluate impact. Accordingly, the workgroup had the discretion to determine how to invest the equity funds. Nancy, Lola, and Rey were more involved in meetings, requesting nuanced transfer-level data and with ideas ready for improving equity issues in the area of transfer. Lola described how they took advantage that other people in the group were slower to come up with ideas while they had plenty of ideas to share. Nancy shared that the meetings were a place where "we could be creative about what could work" for the "students identified as facing gaps" and "talk about what really could address these disparities in outcomes." Based on the state formula for the distribution of student equity funding, Huerta's share was $3 million dollars and they allocated more than one-third, $1,350,000, to support transfer. The substantial investment in transfer, in addition to the Latinx focus, made Huerta's plan an outlier within the district. Table 4 lists the five activities focused on improving the experiences and outcomes of Latinx students in transfer. Note. Funds rounded in an attempt to provide anonymity* Nancy and Lola pitched Viva La Mujer, "a program just for Latinas," grounded in the data they looked at "identifying Latinas were finishing in ten years or stopping out." Lola reflected, "We thought, what can we propose to keep them from stopping out?" She continued, "Once we proposed the idea, that really got the ball rolling, people in the room were all for it, they became part of the movement" to address the barriers facing Latinas in transfer. Nancy added, "The program was focused on improving transfer rates for Latinas and providing wrap-around services that scaffold" as well as "getting them through developmental courses that were holding them back." She recollected, "With everyone on board, our juices were going, trying to do more specific things for Latinas like offering daycare services." Nancy continued: "We explored lots of ways to better support Latinas that needed additional help to transfer out. Glad this one was included." Nancy mentioned that there was minimal push back in the planning meeting since "it was one of the outcomes of the whole equity plan effort." Another proposed program was The Men of Color transfer program, which developed leadership development and mentoring strategies to support and assist Black and Latinx men in their goals of degree completion and transfer from Huerta. Stacy Ramirez reflected, "I was open to what was proposed, we supported the [Men of Color] transfer program." Stacy added, "I felt great about the idea, I have felt for a long time that we're not addressing students who are falling through the cracks with transfer." The University Transfer Partnership was the third project proposed, and created a Latinx-focused summer transfer immersion program with a neighboring four-year institution. This effort would build on an existing partnership, but the focus was to target the "disproportionate results in transfer for Hispanic/Latino students" by creating a "transfer pathway program with a local university" where "Hispanic/Latino students" spent the summer taking Chicano Studies courses, living in the residence halls, and attending workshops that "promoted the importance and value of transfer" to students.
The remaining two proposed activities were the Faculty Advocate Program and Latinx Transfer Equity Project. The faculty program provided campus practitioners with training to better support Latinx students explicitly, and students of color broadly, by bringing in speakers on topics such as racial equity, supporting men of color, validating Latinx students, and using contemplative pedagogies. The Latinx Transfer Equity Project was a contract with the University of Southern California's Center for Urban Education to examine institutional transfer practices through the lens of racial equity in general and Latinx inequity more specifically. This two-year effort, in which I served as a researcher member, was a participatory action research project focused on examining structural, relational, cultural barriers to transfer equity.
The implementing workgroup recognized that the planning process and the need to disaggregate data based on race aligned with and offered cover for more race-conscious approaches to addressing student equity. These transfer-focused practitioners within the group used the available data, their expertise, and their personal advocacy as an opportunity to shape Huerta's student equity plan to address Latinx transfer equity. Nancy was matter-of-fact when reflecting on the planning process: "Well, they put us in a room, with that data, and that amount of money, what did you expect us to do?" The final step was to share out the equity plan and get it reviewed and approved by various internal and external campus constituents.

Navigating Campus Dynamics during the Implementation Process
The last theme discusses how implementers used the policy language, their own educational experience, and social status to navigate Huerta's approval process and mitigate resistance to a Latinx-focused student equity plan. Helping implementers push their race-conscious approach was a) using the SEP as a shield against those reluctant to discuss racial inequities, b) aligning with the campus president's prioritization of transfer, and c) describing the unique funding source for these equity efforts.

Policy as a Shield for Race-Conscious Implementation
By late August 2014, the workgroup began to share the equity plan and its proposed racebased activities. Alejandra Gutierrez recalled going to an academic senate (AS) meeting to share the first full version of the plan and getting pushback from campus stakeholders hesitant about the Latinx-specific activities included. Emilia remembers these comments as well, adding that there were three types of objections: 1) programs were too race-specific, 2) created additional "boutique programs," and 3) were not the best use of equity funds. For instance, when a senator asked at the October 2014 AS meeting if creating a Latinx-specific program could be seen as "reverse-racism," Emilia was able to rely on the policy, the compelling data accumulated, and the guiding documents from the Chancellor's Office to underscore that the plan's focus was based on objective evidence. Alejandra shared, "This is where leadership was so important, having [Emilia] willing to step out and say, yes, we are going to use this language and it's okay because we are being asked to look at inequities for specific students." Nancy remembered being straight forward during these plan review meetings, arguing that these programs were addressing inequity and there was a need to "talk about racism and institutionalized racism" and "recognize that inequities on campus are a race issue." The student equity policy and planning process offered opportunities to talk, somewhat openly, about racial equity gaps and why these disparities occurred on campus. As Lola shared, "The equity policy [was] saying you must serve these groups. So, I can come out and say this program is for these groups; this is what the state is telling me, this is what the data says. So, let's target them." The mandates included in the policy created a window for race-conscious plan development, and when questioned about their approach, these campus leaders were able to leverage the legislative language to get their plan and proposed ideas passed and approved. The requirement to identify equity gaps legitimized and empowered the workgroup to advance a race-specific agenda. Lola continued: "We always had a hunch that we needed more supports for these special populations, which is the majority of our students if you look at our profile," but before "you had to be very respectful and careful and make sure that things were fair, but for the first time, we had the opportunity and the freedom to show the data publicly and address them."

Aligning with the President's Priorities
President Manuel Lopez's focus on improving transfer rates and making the Huerta a topranked transfer-sending institution aligned with the working group's approach and made it easier for them to push their agenda forward. The president's vision for transfer, according to Lola, brought about a new mindset where "everybody on campus [was] looked at as a transfer student." This was illustrated at an all-day staff professional development, where the President highlighted Huerta's recent transfer success mentioning that "more students have transferred out through our strategic efforts." As he spoke, a presentation slide showcased the significant increase in associate degrees for transfer and he reported that Huerta jumped into the top 15 of community colleges that transfer students to both the CSU and UC systems. He concluded by saying, "There's no reason we can't be number one; if we come together to share ideas and tackle barriers, each of you can have an impact on improving transfer." More than articulating a vision, Lola described how President Lopez also committed resources and encouraged others to also focus on improving transfer: [In 2013], as our new president, he dedicated a million dollars to create a first-year completion program, to serve 500 students with the intent to create transfer-ready students. This new transfer program helped with the getting through math and English courses, provided a career guidance counselor assistant, and additional support for when life happens. We model it after our Latino culture, so family members were included in the program and added personal development/student success courses. That [was] one huge effort of getting our students through the transfer pathway.
According to Rey, the SEP aligned perfectly with the president's vision for transfer. He recalled, "Some of the transfer initiatives we developed coincided with the push for transfer as a big initiative by the president. I think the plan's efforts dovetailed nicely with the push from the college president to increase transfer." Stacy added how they merged priorities: "We had this opportunity, we need to do better at transfer, the president had this as a priority as well, and we felt empowered to push transfer in the [workgroup] meetings." She added, "So when we did our plan, I don't think people had an issue with being transfer heavy, it wasn't a problem." The convergence between the President and the workgroup's priorities helped get approval from campus leadership and continue through the shared governance process.

The Policy's Student Equity Funds
As implementation occurred, the state, community college system, and Huerta benefited from the economic growth post-2008 recession. Increased funding lessened the competition for resources, and it was easier to gain support for equity efforts that may have been rejected in times of scarcity. Emilia realized, "We had money to make a change, to change the campus. Having our own money was important because it helped fuel those new ideas without taking from [General Funds]." From Emilia's perspective, it was clear that she and the workgroup had ownership over the equity funds and discretion to allocate it according to their priorities.
For the wider campus, student equity funds were seen as supplementary dollars because they were new categorical 9 resources that did not take away from state-appropriated general funds allocated to the campus. This view of equity funds as "new," "add-on," and "soft" money made it less contentious for implementers to use student equity resources to address Latinx transfer inequity. Alejandra Gutierrez reflected on the review and approval of Huerta's Latinx equity projects through the policy's new funds: We are a Hispanic-serving institution; the majority of our students are Latino. Latinos are the ones that are struggling the most. I mean ridiculous, that's where our attention and money need to go. Luckily, we [had] good people that their minds and hearts [were] in the right place. They realized that even though this money could be used to change all kinds of things, we were going to focus on Latinos and the challenges faced in transfer.
Huerta's president had a similar view that equity dollars could be used to address Latinx students and described them as "flexible" resources: Student equity funding is so flexible. We were driven by the identified gaps. For example, to close the gap of Latino students transferring from this campus, it's going to take a while, it's not going to happen in a year or two. It might take five years. So that's the advantage of having student equity funds. You get a chance to delve into these issues that you know are going to take long-term solutions, not just a quick fix.
During October and November 2014, Emilia and Santiago, with the support of the Huerta President, presented the equity plan to the Strategic Planning Committee, then the full shared governance committee. Emilia noted that the review process with shared governance "was pretty easy," adding that "during [the] presentation with the faculty there wasn't questions about who our programs targeted [i.e., Latinx students], they only cared about how we were going to fund and measure the impact." Any concerns over funding were quickly addressed since the policy included a specific equity allocation for each campus annually. After these successful steps, the workgroup prepared for the district review, the last step before submission to the state. At this district meeting, an updated equity plan and one-page executive summary with five supplementary tables on "disproportionate impacts and plans for improvement" for each academic indicator were presented. Santiago recalled, "I don't remember it as a difficult vetting process," adding, "Our presentation to the board of trustees was only like three slides, four slides, and so we probably had about five minutes to present, right. So, that was it." Huerta's student equity plan was approved by all internal and external stakeholders and submitted to the state on December 10 th . The workgroup's race-conscious approach was reviewed by the Chancellor's Office and approved. In retrospect, Nancy shared how they were able to pass their plan: It was kind of a perfect storm. The equity policy was created. You had Emilia in place. You had a new president. You had a shift in academic senate leadership. The president said, 'Let's improve Latino transfers.' We are all hoping for the same thing.
Nancy description of "a perfect storm" alludes to critical aspects highlighted in these findings and how Emilia's accession to lead the implementation effort, the intentional composition and characteristics of the workgroup, leveraging of policy's mandates to be Latinx-specific, and receptive organizational conditions all created a window for Huerta to move forward.

Discussion
Education policies seeking to ameliorate racial disparities in community colleges need not only strong mandates, but also race-conscious and equity-minded implementers (Sampson & Bertrand, 2020). Implementers that see opportunities for transformation within policy and imagine ways reforms can address long-standing barriers to student success (Felix & Trinidad, 2020). This article explored how leaders within one community college took advantage of a state policy to explicitly address Latinx transfer disparities. Findings from this study highlight the importance of the identity of the practitioners-as-implementers overseeing reform at the local level, the intentional composition of workgroups carrying out the enactment process, and the larger campus dynamics that shape the legibility of a race-conscious approach.
As mentioned earlier, the selection of Huerta College was an attempt to move "beyond misery research" (McLaughlin, 2006), to no longer report failures of policy implementation, but instead report potential successes. Seeking to provide a more critical approach to implementation research that draws attention to understanding how local actors and campus conditions influence what is achieved from policy reform, I created the Trenza policy implementation framework. Using a Trenza approach allowed me to better understand the implementation process as a series of acts that are carried out by humans who are distinctly shaped by their identities. As Coburn (2016) writes, policy researchers must contend with the ways that "institutionalized roles and positions in social networks-enable and constrain the roles one can play in the implementation process" (p. 470). By exploring who implementers are, we can understand how well-intentioned equity-oriented policy can be implemented in ways that "sometimes reinforce existing structures of inequality, rather than interrupt them" (p. 471). This study's theoretical approach thus centers implementers' role, positionality, and social identity to understand how leaders interpret, understand, and act on policy in critical ways that disrupt longstanding educational inequity.
The results highlighted the ways Latinx leaders, especially Latinas like Emilia Leon, established a vision that the Student Equity Policy would try to tackle racial inequality on campus. As scholars note, personal beliefs and professional values influence how implementers respond and carry out complex reform in community college (Chase, 2016;Nienhusser, 2018) Those involved with implementation drew on their affinity for the local community, commitment to racial equality, and own experiences as transfer students to see and use policy as an opportunity to address the persistent inequities faced by Latinx students. From one participant's point of view, implementing the student equity policy unfolded during a "perfect storm," a convergence of political, organizational, and individual factors, that made it possible for Huerta to develop an equity plan focused on improving Latinx transfer equity The first finding emphasized individual implementers and how their background, experiences, and competencies influence policy enactment. The possibilities of what could be achieved with the Student Equity Policy were significantly altered when implementation leadership was transferred to Emilia Leon. Driven by her experiences as a Latina faculty and administrator that grew up in the community, she saw the policy as an opportunity for campus transformation, one that benefited communities of color. Bertrand and Rodela (2018) share that educational leaders with a sense of "transformative agency" are able to envision broader aims for social justice, involve campus stakeholders, and work to close equity inequities for marginalized groups. The second finding pointed to the need for intentionality when identifying and selecting campus participants to support implementation. The implementation workgroup was dominated by Latinx faculty and staff with a personal commitment to improving Latinx transfer. Like Emilia, the workgroup saw the policy, its mandates, and intended purpose as an opportunity to address longstanding transfer inequities. As Mavrogordato & White (2019) note, implementers who take the time to develop a deep rather than perfunctory understanding of policy are more like to leverage reform as a tool for educational equity.
The third finding explored the ways that implementers at Huerta were able to interpret the mandates of the policy as an opportunity to tackle racial inequity. The extant literature documents the importance of structuring policy in ways that allow for ground-level actors to interpret, carry out, and achieve the intended goals of reform (Coburn, 2016;Marsh, 2012). One implementer mentioned how they perceived that "the state finally gave them the license to be Latino-centric" because the reform was about serving students that were facing large gaps and use equity resources specifically for these identified groups. Similarly, having implementers examine their own campus data by race and ethnicity served as a catalyst to mobilize and address disparities in Latinx transfer. The last finding described the organizational conditions that enabled race-conscious implementation where institutional leaders faced minimal pushback to emphasizing Latinx transfer issues. Malen et al. (2014) remind us that when there is alignment between institutional priorities and the availability of resources, implementers are more successful in carrying out complex reform with fidelity. From these findings, I share four implications that prompt policymakers and practitioners to consider how policy implementation can take a more race-conscious approach to achieve the equity in higher education.

Designing Policies with Possibilities for Racial Equity
The results from this study show the importance of designing a policy with non-neutral language (Oakes et al., 2005), including mandates that can empower practitioners to be raceconscious (Dowd & Bensimon, 2015), and allowing for flexibility at the local-level (Hill, 2001). The equity-oriented language in the policy cued implementers at Huerta that this reform was about supporting students who faced the largest barriers in student success. Many of the implementers noted how the policy gave them the "green light" or "license" to be "Latino-centric," especially when the data showed such glaring inequities. Critical to the race-conscious implementation at Huerta was the requirement that data be disaggregated by race, language that prompted addressing specific student inequities, and the inclusion of new fiscal resources to implement their vision. Policymakers must craft policies that acknowledge structural racism and other barriers that hinder student success and include design elements that enable implementers to use the reform in ways that can truly attain the intent of equity-oriented policies.

A Supportive Organizational Environment to Address Racial Inequity
My research suggests that a supportive organizational environment is necessary to carry out race-conscious policy implementation. I shared how Huerta's history, senior leadership, and shifting campus culture allowed practitioners to develop an equity plan that addressed Latinx transfer barriers. Mattheis (2016) shares how state leaders and the policies they create fail to recognize the importance of campus dynamics and providing guidelines to help implementers carry out equityoriented reform goals. Not all campuses finding themselves with the infrastructure or individual leaders to tackle racial inequality. Moving forward, state-level policymakers and system-level leaders must consider the level and depth of change required to implement Student Equity Policy, particularly helping faculty and staff understand ambiguous concepts such as "equity" and "racial disparities." Aligned with Patton, Harper, and Harris (2015), I suggest adopting capacity-building tools that focus on the realities of race, systemic causes of inequities, and ways well-intended policies can be detrimental to students of color in higher education. As the authors note, regardless of student equity efforts, if oppressive structures are not acknowledged, racial equity will not be achieved. With an investment in capacity-building, institutions and practitioners can have a deeper awareness of issues of equity and race and use policy efforts to support the success of raciallyminoritized students.

Intentional Recruitment and Selection of Implementation Leaders
Implementing complex reforms within institutions of higher education requires practitioners who have a certain set of skills, competencies, and experiences. At Huerta, the transition from James Denton to Emilia Leon put in place a leader with a race-conscious vision for equity planning who was known as a champion for student success. Although serendipitously placed in this role, Emilia leveraged her experience as a faculty member and administrator to maneuver the planning process. Nienhusser (2018) describes how institutional implementers respond to policy objectives in varied ways; at times compliant, other times unpredictable, and many times resistant. Research on implementing equity reform (Bensimon & Malcom, 2012;Lewis & Diamond, 2015) shows that ideal implementers are friendly to a culture of inquiry, can have conversations about race and racial disparities, and have power, influence, and institutional know-how to create change from the ground up. My findings call for institutions to be more intentional in the selection of implementers. Institutions should actively identify reform leaders that can interpret and implement policy in ways that benefit racially minoritized students facing equity gaps, such as Latinx students in transfer. Key to the success at Huerta was having leaders who were equity-oriented, comfortable discussing race and racial disparities, and able to develop race-specific strategies and advocate for these efforts when resistance emerged.

Latina Implementers: Courage, Commitment, and Campus Transformation
The Trenza approach focused less on the design of policy or its impact, but on the process in which reforms unfolds on campus. This analytic frame played close attention to the people overseeing implementation and the ways their identity, experience, and motivations shape the use of policy to address racial inequity. Drawing attention to people, the findings highlighted how Latina leaders had a significant influence over how the student equity policy was understood and the ways Huerta used the mandates within the reform to tackle persistent inequities facing Latinx students. Latina leaders, when given the opportunity to lead, did so in a community-centered, equity-oriented, and transformation-driven way. The implementing leaders profiled in this study demonstrated coalition building, political savviness, and a steadfast commitment to the community and students that make-up the Huerta Barrio (Bordas, 2013). Emilia was unapologetic about her approach to leading the implementation process that drew on her connection to the Huerta community, activist mentality, and deep commitment to addressing "racial inequality and social injustice." As Rodela and Rodriguez-Mojica (2019), found Latinx administrators that draw from their "childhoods, educational histories, and Community Cultural Wealth" display an equity-driven leadership style that seeks to address educational inequities they similarly faced (p. 289). Being of and from the local area and experience the barriers to transfer themselves, these Latina leaders saw the opportunity embedded in the student equity policy and leveraged it to disrupt longstanding educational inequities, especially for Latinx students in transfer and completion (Parker & Villalpando, 2007). These results speak to the ability and possibility of Latina implementers, and other minoritized implementers, to not only carry out compliance aspects of policy implementation but generate and achieve a more transformative vision for reform given the experiences, skills, and competencies possessed. Carey et al. (2019) note that despite the fifty years of studying implementation, research has primarily focused on "highly rationalist thinking that sees the policy process in a larger linear fashion" (p. 144). Many within the field of policy implementation have called for new and different approaches to understand the most complex aspect of the policy process (Hill & Hupe, 2009;Koyama, 2015). As a critical researcher, I designed the Trenza policy implementation framework as a response to this call and need to weave distinct theoretical elements that help capture the complexity of implementation and the ways policy design, campus conditions, and implementing actors translate reform into practice. Findings from Huerta illustrate how Latinx administrators used their identity, educational histories, culture, and commitment to community as assets to robustly lead an implementation process that explicitly targeted and addressed longstanding inequities facing Latinx students on their campus.

Conclusion
This article adds to recent scholarship examining the role of leaders of color in implementing higher education policy (Cuellar & Gándara, 2020;Gaxiola Serrano, 2018;Nienhusser, 2018). Huerta provides a race-conscious example of the ways community colleges can use policy reform as a portal for achieving racial equity. To do so, implementers should be encouraged to create new structures, programs, and practices that center the experiences of specific student groups. When policies encourage race-evasiveness in implementation, practitioners tend to create generalized solutions for specialized problems, failing to address the racial disparities on campus. The eradication of educational inequity can only be addressed when racial inequality is acknowledged and addressed by practitioners through explicit and targeted policies, practices, and programs that are race-conscious as demonstrated at Huerta College.

About the Author Eric R. Felix
San Diego State University efelix@sdsu.edu https://orcid.org/0000-0002-6116-0214 Eric R. Felix is the proud son of Mexican and Guatemalan immigrants. Born and raised in Anaheim, I'm the product and beneficiary of public education from kindergarten to graduate school. I'm the first in my family to attend and graduate college. Now I get to be a faculty member at San Diego State University and do my best to fulfill our state's promise of providing affordable, quality, and transformative education. I hold three principles dear to me -Partner, Parent, Professor-and do my best to be present and passionate for each. My work at the intersection of implementation and institutional changes seeks to highlight the possibilities of policy reform to improve racial equity in higher education.

About the Editors Eric R. Felix
San Diego State University efelix@sdsu.edu https://orcid.org/0000-0002-6116-0214 Eric R. Felix is a critical policy scholar examining the ways policymakers craft higher education reform and how institutional leaders implement them. His research focuses on understanding how policy implementation may benefit, harm, or render invisible Latinx students and other minoritized groups in the community college context.

H. Kenny Nienhusser
University of Connecticut kenny.nienhusser@uconn.edu https://orcid.org/0000-0001-9013-0682 H. Kenny Nienhusser is an Assistant Professor in the Higher Education & Student Affairs Program in the Neag School of Education and Faculty Director of La Comunidad Intelectual at the University of Connecticut. His research examines the origins of public policies and their implementation environments that affect the postsecondary education access of minoritized youth in the United States.

Ángel de Jesus Gonzalez
San Diego State University agonzalez2426@sdsu.edu https://orcid.org/0000-0001-6361-7399 Ángel de Jesus Gonzalez is a third-year doctoral candidate in the Community College Leadership Ed.D. program at San Diego State University. Their research examines the conditions, experiences, and outcomes for LGBTQ+ students at community colleges, with a focus on Queer Latinx students and professionals.

Luz Burgos-López
University of Connecticut-Storrs luz.burgos_lopez@uconn.edu https://orcid.org/0000-0002-2394-4456 Luz Burgos-López is a second year doctoral student in the Learning, Leadership, and Educational Policy Ph.D program at the Neag School of Education, University of Connecticut. Her research explores anti-Black ideology in existing research pedagogy on the Latinx students and the role racial classifications in scholarship production and policy implantation within higher education. Her current research project uses critical analysis of the construction of Latinidad as a racial classification to examine the erasure of Blackness and the monolith representation of Latinidad. Readers are free to copy, display, distribute, and adapt this article, as long as the work is attributed to the author(s) and Education Policy Analysis Archives, the changes are identified, and the same license applies to the derivative work. More details of this Creative Commons license are available at https://creativecommons. Please send errata notes to Audrey Amrein-Beardsley at audrey.beardsley@asu.edu Join EPAA's Facebook community at https://www.facebook.com/EPAAAAPE and Twitter feed @epaa_aape.