This is the first in a series of reports based on a multi-year research project on the Tennessee Achievement School District (ASD). The purpose of these reports is to present independent analyses based on evidence, as well as the experience and judgment of the research team. The current discussion examines the ASD's theory of action, and considers how its system of accountability and guidance could influence the nature of students' educational experiences. Particular attention is given to the diversity of approaches among the organizations operating schools in the ASD, and the extent to which this could lead to meaningful comparisons, discussion, and ultimately organizational learning. Our focus on organizational learning is motivated by the belief that the capacity of ASD providers to learn and improve is critical to the success of the overall enterprise.