CSM comments on A-190, proposed regs on school closings & co-locations 10/4/10

Full comments posted here. Summary below.

COMMENTS BY CLASS SIZE MATTERS ON A-190
PROPOSED REGULATIONS IN REGARDS SIGNIFICANT CHANGES IN SCHOOL
UTILIZATION AND PROCEDURES FOR THE MANAGEMENT OF SCHOOL
BUILDINGS HOUSING MORE THAN ONE SCHOOL
October 4, 2010

SUMMARY:

Unfortunately, the proposed Educational Impact Statements, building plan template and
Instructional footprint are inadequate to meet the needs of students for a sound basic education,
as defined by research, experience, and the state’s highest court.

 The EIS should include an analysis that projects the impact of the proposal on class
size, and no co-locations or changes in utilization should be proposed that would prevent
schools from reaching their class size goals in their Contract for Excellence plan.

 The EIS should include an analysis to determine if the proposed class sizes violate the
building code, especially as the minimum size of rooms in the proposed instructional
footprint has shrunk by as much as 50%.

 The EIS should provide enrollment projections for at least the next five years; including
students disaggregated by grade, program, and student status (English language
learners, Gifted and Talented, students with disabilities etc.)

 These projections should specify what data sources they are based upon, and should
include (but not be limited to) current enrollment trends, building starts, census data,
birth rate data geocoded by residence, and surveys of neighborhood day care centers
and preKindergartens.

 The EIS should include an analysis to determine if the proposed change in utilization
would affect the ability of students to be provided with sufficient dedicated space for art,
music, science, remediation and special education services, as well as shared spaces.

 Instead of the minimal standards provided, the EIS and the utilization proposal should
ensure that there is adequate space for SETTS, resource rooms for remediation, and
special services, based upon the actual number of students who require such services at
each school.

 The footprint is especially inadequate for high schools; and appears to call for only two
specialty classrooms, no matter how large the school, and only one science lab, even for
high schools of 4,000 students (a reduction from two in 2009).

 As for shared spaces, the EIS should describe during which period and times of day the
cafeteria will be utilized for lunch each day, and how many periods a week the students
in each school with have access to the gym for physical education;

 The EIS, as well as instructions on how to provide public comment and when and where
hearings will take place, when it is issued, should be made available to all parents in the
affected schools in a document that is sent home through backpack mail.

 The DOE should publish at least 24 hours in advance of the PEP meeting on its website
an assessment and summary of all public comments concerning the proposal.

 For school closings: A summary of the significant steps taken by DOE to improve school
performance before decision to seek phase-out was reached should be required, not
optional as currently proposed, as a required part of the EIS.

 Enrollment options must be made available to all current students enrolled in the school,
so that they are provided with an opportunity to graduate from high school by
accumulating course credits in the usual way, that is by attending regular classes,
without engaging in substandard “credit recovery” . (Right now the only opportunity
afforded students who are behind in credits at closing schools is either to be discharged
to GED programs or receive their diploma through sub-standard and rushed credit
recovery programs.)

 For each school in the building, the allocation of instructional space should include a
listing of all rooms that will change in terms of school ownership or boundaries, their
size, and current use.

 The analysis of the impact on the community should include how many students
currently attend overutilized schools in the community; and how the school closing may
affect these figures; as projected five years into the future, by grade and program.