January 8, 2024
Dear Members of the Student Assignment Advisory Committee of 2023-2024,
As we come to the last few meetings of the Student Assignment Advisory Committee, we have suggestions for the recommendations that will come from the Systems Level discussion which could potentially provide more clarity and coordination around school openings and expansions. We would like to see these seriously considered by the full committee for inclusion in the recommendations.
Specifically, the advisory committee is tasked as noted in DC Law 20-61; D.C. Official Code § 38-221 with ensuring adequate capacity to guarantee the right to attend DCPS schools at each grade level, taking current and future population and enrollment trends into account.
Strengthening programming opportunities and safe spaces in all eight wards to the standard seen at DCPS schools in the northern and western neighborhoods will support stronger enrollment in the DCPS neighborhood schools. The investment has to come first. Citywide charter and DCPS schools were meant to enhance not weaken the DCPS schools of right. It is time to restore the balance and prioritize the DCPS neighborhood schools primarily in wards 5, 7 and 8.
Even if the excess capacity in the DCPS schools in the eastern neighborhoods were all utilized, it is still inadequate to meet population needs. The task is to fulfill the guarantee of the right to attend a DCPS neighborhood school for those living within its boundary. The right to a quality DCPS school with equitable levels of programming applies whether they currently attend or not.
The proliferation of charter schools in these areas–many in former DCPS school buildings–means ensuring adequate capacity in remaining DCPS schools of right will entail more intentional and comprehensive planning and the option of a path to conversion from charter to DCPS. The city government can, if it chooses to, fulfill the guarantee of the right to attend a high quality DCPS school close to home supplemented by a citywide lottery system and application schools.
The lack of adequate capacity to guarantee this right vs the chance to enter a lottery (in mainly, though not limited to, wards 5, 7 and 8) can be corrected by a binding requirement for planning among the 70 separate LEAs and 251 separate public schools across the District.
We need a binding requirement for planning because, currently, both DCPS and charters are able to expand and open new citywide schools without any concern of overlap or enrollment issues. This leads to a high number of unfilled seats in both sectors. This is costly and inefficient as well as ineffective at providing the education and support needed for all students.
In addition, while DCPS schools have the option of converting to a charter school, there is no process in place for DC charter schools to convert to a DCPS school. There have been two charter-to-DCPS conversions in recent years: Dorothy Height and Excel. These conversions were done through high-level agreements instead of through an established process.
It is imperative that school planning and charter conversion ensure adequate capacity for DCPS schools of right and are handled in a fiscally rational way. We suggest the following policy considerations:
There should be a requirement that an impact statement must be considered before the PCSB authorizes a new charter LEA, expands the enrollment (schedule i) of an existing LEA, locates a charter school, or relocates a charter school. That statement should include enrollment data as well as fiscal data. This statement should also be required of DCPS opening or expanding a citywide school.
Initial Draft of Possible Impact Statement required with School Expansion -
Any impact statement must include the following:
· Rationale for opening or expanding a public school. The DC PCSB currently includes this in the application. (see page 20).
● Whether there is enrollment capacity in a DCPS school to serve the student enrollments being proposed by the charter LEA in the location(s) being proposed.
● The location of the DCPS neighborhood school or schools likely to be affected by the charter LEA’s or DCPS proposed action with current data on their enrollment capacity, school demographics and community uses.
● A description of the DCPS program, buildings, and grounds of the schools likely to be impacted by the charter LEA proposed action.
● A profile of the students and neighborhoods likely to be impacted by the charter LEA or DCPS proposed action.
● Racial Equity Impact statement to be submitted and reviewed by the Chief Equity Officer
● A transportation analysis which identifies the likely amount of additional trips taken on various modes, the availability of transit, pedestrian, or bicycle options from the locations of likely students' homes, the environmental impact of additional car trips, and a Transportation Demand Management plan in coordination with DDOT which identifies methods of reducing traffic and pollution.
The impact statement should also delve into fiscal matters:
● The expected amount of the charter’s facilities allowance, DCPS expected capital needs.
● Any loss of real property tax revenue from private facilities or land converted to public education use, if part of the proposed expansion or opening.
● Projected administrative and operations costs as a percentage of total per pupil expenditures. (see adequacy study)
Finally, any application along with the impact statement for expanding, opening, locating, or relocating a charter school must be submitted to the DC Council, the DC register and Chancellor of DCPS at the same time it is provided to the PCSB and a formal response submitted to the application by DCPS. There should then be a public input period and ANC input based on the impact statement. For the expansion of DCPS citywide schools, the submission should also be made to the PCSB.
2. Strengthen programming opportunities and safe spaces in all eight wards to the standard seen at DCPS schools in the northern and western neighborhoods. This will support stronger enrollment in the DCPS neighborhood schools. The investment has to come first. Citywide charter and DCPS schools were meant to enhance not weaken the DCPS schools of right. Prioritize the DCPS neighborhood schools primarily in wards 5, 7 and 8.
3. Charter LEAs can initiate a conversion to become a DCPS school through an application to DCPS, which would include any or all of the following processes:
● A petition with signatures of 65% of the full-time charter school-based staff and 65% of the parents or guardians from the students’ households is provided to the charter LEA, PCSB and Chancellor of DCPS.
● The charter LEA board of directors votes at an open public meeting of staff and families to seek a conversion to become a DCPS neighborhood school, with a 2/3rd board vote in favor of seeking a conversion.
● Following the closing of a charter LEA, the LEA or PCSB requests that DCPS incorporate the charter school into DCPS. If the charter school is in a former DCPS building and owned or leased by the charter LEA, the building will revert back to a DCPS building.
DCPS would then have a series of options upon receiving the application for conversion:
1. Deny the application based on clear factors - enrollment, building condition etc
2. Accept the application, which would
a. Convert the charter to a DCPS citywide school OR
b. Convert the charter to a DCPS neighborhood school of right OR
c. Grant the charter a measure of autonomy within DCPS.
The decision by DCPS will be made using data around current enrollment trends and the capital budget. As a DCPS school, a charter would be covered by union contracts and the DCPS capital budget.
4. A pause in opening or expanding citywide schools until a binding requirement is in place. This agreement shall include as noted above, the transparency and public input with third party Impact statements as outlined, investments in program in DCPS under enrolled neighborhood schools primarily in wards 5, 7 and 8 and the policy for a path for charter schools to transition to DCPS schools.
Sincerely,
Members of the C4DC Coalition
September 22, 2023
Dear Members of the 2023 Student Assignment Advisory Committee and Technical Team,
As we head into the fall meetings, the advisory committee is tasked with creating recommendations around our most basic and important job: boundaries that will clarify for families the schools students have a right to attend. That means the committee has a chance to make recommendations that take advantage of our resources, of where neighborhood diversity exists, and of our beautifully modernized DCPS facilities across the city, putting into place a DCPS city system that is stable, strong and equitable for all. The recommendations should reflect a 10 year vision that is future oriented, not reactive.
The recommendations must look at placement priorities while identifying the resources needed to ensure that families across the city are entitled to programming close to home that is rich academically, serves children with special needs excellently, and provides for quality out of school time care and activities as well as safety.
The law specifies that the public know the effect of any redistricting or student assignment changes on adequate capacity and on equitable access. Utilization and quality are not static or fixed. They respond to policy, planning and changes outside the realm of education like affordable housing and health.
In order to evaluate any proposals for change, the Committee and the public at a minimum need:
A clear method of assessing "adequate capacity" – The committee will have access to revised program capacities through the work of the consultants. The committee will then need to assess adequacy from that data as well as other inputs.
A clear definition and metrics for "equitable access' ' – The committee has identified this challenge in terms of short term and a 10 year plan. Currently “at-risk” applicants are underrepresented in the lottery as noted here. Granting preference to at risk students in the lottery has been the primary method of granting equitable access; it will be re-considered in this process. Equitable access can also be defined as resources and quality in by-right DCPS schools. There is a question here as to whether “equitable access” means “a higher likelihood of access for certain students with specific identified needs,” or something closer to “entitlement of access for all students to have their specific individual needs met.” In addition, there is the question of convenience / proximity – is it sufficient “access' ' if a student has a right to attend a high-quality school, but has to travel across the city in order to do so?
A clear definition and metrics for "high-quality DCPS schools.” – Currently, the DME’s team is using the OSSE accountability score, family demand (as shown by lottery waitlists, even limited to top 3), and programming, to evaluate school quality when proposals are weighed and considered. We do not yet have the metric for measuring programming.
These currently selected indicators of school quality are problematic for several reasons:
OSSE and the State Board of Education are finalizing their recommendations for a revised school report card now, in an attempt to repair the inequities and misrepresentations of the STAR system. The SBOE has identified systemic bias, a narrow view of quality and limited support here. OSSE requested a one year amendment to identify the required lowest performing schools given the challenges of COVID – this is not an appropriate metric for use in a 10 year plan.
Demand is not a direct reflection of quality.
While demand can indirectly suggest a family’s needs and values – including convenience / proximity to home or public transit, demographics (applicants are not in a small racial ethnic minority), accountability ratings, access to before and after school care, and availability of specific programs. See here. – these are highly variable, impossible to parse out, and they do not necessarily equate with quality.
Many schools formerly on closing lists for low quality or low enrollment are now in high demand, as are schools once perceived as not desirable. This shows that school quality, and its relationship to demand, is neither simple to define, nor static.
There are also a number of reasons that waitlists and other lottery data fail to fairly represent demand, even if that demand did accurately reflect quality. For example,
It is challenging to parse the difference between slots offered and accepted in terms of a universal demand metric (i.e., is a school with 200 slots in the lottery and no waitlist less in demand than a school with 20 slots in the lottery and a waitlist of 100, etc.).
Students attending their in-boundary neighborhood school do not have to enter the lottery, so their demand for those schools is not captured in the waitlist data.
In DC families with higher income and often white, participate in the lottery to a greater extent skewing the data. See here. Because we are bound by law to determine boundaries for schools students are entitled to, and equity requires that this entitlement serves all students across the city in an equitable manner, using lottery demand as a metric for our work on equity does not pass the test of being fair or representative of quality or program access.
These concerns are particularly worrying due to the context in which this process of defining “high-quality schools” is happening – as part of a Boundary and Student Assignment study. This definition could be used to set policies which divert students away from their neighborhood schools and communities, withdrawing resources from by-right schools in a short-sighted approach that will create or perpetuate self-fulfilling prophecies for particular school communities.
We have the chance now with this boundary process to ensure there is a path to equitable entitlement to a high-quality education in DC’s schools--not just a chance/choice for some for a (seemingly) better option in the present or near future. We should not be simply seeking pathways to provide more, or certain, students with the opportunity to attend a limited number of existing high-quality schools. Rather, we should be pursuing a reality in which more schools currently determined to be “low-quality” can be improved so that all students, and particularly those with the greatest needs, are able to have convenient, guaranteed access to a high-quality education.
For all these reasons, we believe the advisory committee needs to ensure the following in any recommendations going forward:
That they push for a definition of "equitable access" that goes beyond “a higher likelihood of access for certain students with specific identified needs,” and instead insists upon “entitlement of access for all students to have their specific individual needs met at a DCPS school that is located in convenient proximity to their home.” We insist upon a definition of "high-quality" that normalizes a view that students do not have to travel to have “quality.”
That they focus on programming, Special Education resources and other inputs* in any definition of quality, as it is clear that such factors more directly reflect a robust education than do measures of academic outputs. This can also filter out tendencies for economic or racial segregation.
That they provide recommendations that identify and outline the resources and policies needed to ensure that all DCPS public schools offer a high-quality education, close to home that is rich, strong and responsive academically, serves children with special needs excellently, and provides for out of school time care and safety.
The Advisory Committee and then the DME’s team will have to bring specific boundary scenarios to the public and then to the Mayor. To consider quality in formulating recommendations before then, they must consider the first directive of the work, to ensure equity across the city in securing education entitlement.
Sincerely,
Ward 2 Education Council
Ward 3 Education Network
Ward 4 Education Alliance
Ward 5 Education Equity Committee
Ward 6 Public School Parents Organization
Ward 7 Education Council
Ward 8 Education Council
21CSF
DC Fiscal Policy Institute
Decoding Dyslexia
EmpowerEd
S.H.A.P.P.E.
Teaching for Change
Education Town Hall
Educationdc
These might include: Access to advanced classes; Access to curriculum electives; Access to stable special education services; Small class sizes; Before and After-school for early childhood ages; After-school opportunities for students, co-curriculars, athletics, social clubs, Building modernization and school yard improvements; Stable school administrative leadership and connections to community; Pedagogical differentiation – Montessori, STEAM, dual-language; Partnerships with external groups, e.g. NAF, Communities in Schools, with UDC or other DC based College