[Ed. Note: Yesterday, the DC Council issued a draft budget report from its education committee, along with draft changes to the budget support act, with both approved by the committee today and now awaiting approval of the entire council. In the latter, not only has an amendment to offer charter co-locations (with revenue to go to the host DCPS schools) been approved, but charters are being asked to follow the Open Meetings law, with a rather huge exception for discussions “related to the operation of a public charter school” (!), while the council is holding harmless funding for charter schools–essentially treating funding of charters as funding for DCPS, as a result of COVID (notwithstanding that charters lose students over the course of a year to DCPS). Budget mark-ups continue this week (see here for budget analyst Mary Levy’s excellent analysis of the proposed DCPS budget). In the middle of concerns over what all this means for our schools, and the safety of returning to school in the fall (see here for the Washington Teachers’ Union report (bottom line: it’s not safe) and see here for EmpowerEd’s petition to ensure better social distancing through outdoor learning), the letter below, sent to DC council members yesterday from DCPS parent Danica Petroshius, is a must-read. The only question now is: will our elected leaders listen?]
By Danica Petroshius
I write in strong opposition to the Mayor’s co-location proposal in this year’s Budget Support Act. Now is not the time to formalize and codify a policy that requires a new governance structure throughout our system and will further stretch limited resources when we need to double down on helping students, particularly those who have been disengaged or fallen further behind. We must do more, not less, to help students succeed in what will be a challenging year of learning ahead followed by many years of recovery for the students most negatively impacted by learning and other critical supports disrupted by COVID-19. And we should be boosting support for our public schools East of the River, not further undermining them.
We understand that the Mayor proposes that DCPS schools that are part of a co-location may receive additional funds, as routed through DCPS rather than DGS as the law currently stands. We also understand that the DME [deputy mayor for education] argues that co-location itself is already allowable and has occurred in at least one location. The reality is that a one-off example is very different from a budget-related policy designed for more widespread use that will have direct negative impacts on specific schools, especially schools East of the River. The co-location budget proposal creates significant challenges that require changing our governance structure to ensure the health, safety and quality of learning for all of our students. The potential limited funding boost for the “host” school (if it truly even arrives in the host school’s budget in a timely way) comes with no guarantee that the host school and its students will actually benefit and is an inefficient use of limited funds that should be directed at our most at-risk and vulnerable students.
Co-location is not a convenience or a funding boost prize and it is not a substitute for adequate funding for schools facing major needs. It is a major governance and funding decision that parents and community members must be assured has all of the safety, health, transparency, accountability and equity policies addressed before it can move forward systemwide with public funding.
Funding and Equity Issues
The Council rightly rejected the Mayor’s proposal for a Master Facilities Plan (MFP) because it was not a plan. A plan would allow for accurate projecting for enrollment, budget and other issues to set the course for building use and efficient use of limited resources. Co-location makes no sense without a robust master facilities plan that substantively plans for underutilized buildings, over-enrolled buildings and enrollment growth. At minimum, Council should request a redraft of the MFP supplement which specifically requires language covering over- and under-enrollment, that includes the logic model of co-locations in this facilities plan. How will co-locations interact with over-enrollment? Under-utilization? Enrollment growth? The MFP is exactly where this work belongs, for Council approval and public discussion. Therefore, while the Council rejected the Master Facilities proposal from the Mayor with great foresight, it would be short-sighted of the Council to adopt the Mayor’s co-location budget proposal. Budget, enrollment, and facilities planning go hand in hand. Stretching limited resources without a facilities plan is an inefficient and ineffective use of scarce resources. Finally, ad-hoc co-location implementation will have clear impacts on specific schools East of the River listed in the final paragraph of this section. Council must know the names and faces of these schools it is legislating for in this proposal–do not look away.
Transfer of Funds: As you know, there are regular problems ensuring that DCPS properly and accurately funds schools. There are three current examples illustrating this lack of accurate funding using designated fundings: 1) at-risk dollars, 2) the enrollment reserve fund, and 3) field usage fees. These three special funds that do not make their way to real schools in an accurate, timely, or supplemental manner should give Council great pause in assuming that for some reason these co-location funds would be allocated any differently. Further, DCPS does not provide sufficient transparent and logical data that allows Council or families to understand where these special, additional funds go and there is no part of this proposed amendment that addresses additional transparency or oversight. We must not assume transferring funds works–we must look carefully and follow the current funding before we embark on new transfers of funding.
Increased Inefficiency and Added Expense: In a time of revenue loss citywide, it is irresponsible to further codify in the Budget Support Act an amendment that could actually lead to additional monetary inefficiencies. The Council Budget Office must study this amendment, and a fiscal impact statement be added or at least understood before Council can responsibly vote on it. We understand that the [education] Committee accepts that there is no budgetary impact of this policy. How is that true from common sense? There will need to be staffing, facility, health, safety, building structure and transportation changes, at a minimum, to accommodate two schools in one building. There is, in fact, massive potential for increased costs. How can anyone think there is no budgetary impact?
As the amendment is currently written, charter LEAs and the DCPS school would collaboratively decide on a fee that the charter LEA would provide to DCPS at the district level (yet we have no guarantee the school will see that money in the end). Not only will all of these fees vary on a per pupil basis, but to further codify this circular and convoluted transfer of public dollars is unacceptable. The amendment proposes that the District continue to pay charter LEAs a facility fee; co-located LEAs would then transfer back to DCPS part of these fees, and DCPS would then transfer these fees to impacted schools. Further, charter LEAs are allowed to use remaining facilities funds on capital expenditures (although a quick look through budgets shows wide use beyond capital), which will now be occurring in District-owned property. So, that LEA can make changes to the building itself, which the District pays for, but may have to change again later if the District ever intends to use the building as one school again. If Council is substantively interested in pursuing co-location, after addressing governance issues, they should consider asking charter LEAs to forego the facility fee to co-locate rent-free in District-owned property, rather than create opaque, circular, and inefficient uses of taxpayer dollars.
Inequitable buildings: Our buildings are not magically designed for one school and/or two schools. Significant facilities changes will have to be made to accommodate two schools in any one building. There are countless media stories (see below) from other jurisdictions experiencing co-location that describe the stark realities of students going to school in buildings that are differently equipped and modernized. From unequal paint to computer labs to water fountains, these co-locations have caused stress and harm to students attending them. Council should fully expect to hear all of these stories and more during future hearings if they proceed with this amendment. Assuming that the case of Bancroft Elementary is a good representation of co-location issues is naive. This was a case of two different school levels (elementary and adult) and differing school demographics that led to a very different balance of power and facility use conflicts than the type of co-locations likely to be pursued in the future. Without clear changes in governance to manage accountability, equity and transparency, this policy sets a course to widen inequities.
Inequitable Co-location Outcomes: Council needs to very clearly know which buildings the District believes to be underutilized right now. These are predominantly DCPS schools East of the River, in particular, DCPS middle schools East of the River. If the District moves forward with co-location they are specifically and explicitly deciding the fate of EoTR middle schools. The following schools will be irreparably harmed, know this now, before moving forward: Sousa, Hart, Kramer. Instead, as a city we should invest in the success of these neighborhood middle schools, stop mistreating them, and provide the resources they need.
Running a school building daily is a complicated, multi-faceted effort that requires clear protocols and standards that are adhered to building-wide; dozens of nuanced decisions daily to keep learning, health and safety on track; and emergency preparedness and decision trees to activate in an emergency. In fact, some of these decisions are made at the building level and some at the LEA level. Every single decision requires a “final say” authority that must stand for the entire building. To consider a co-location proposal, necessarily managed by two different LEAs (DCPS plus a charter LEA) that have different standards, protocols, rules and final-say authorities, we MUST first consider new governance structures to protect and serve all of our students well.
Clearly, the governance issues that must be attached to a systemwide co-location policy are numerous. Here are just some that require public input and discussion, significant policy development and important governance reform:
Final Say Overall: Final say is required to ensure the health and safety of all students and adults in the building and that learning and extracurriculars can happen seamlessly. While adults can work together on solutions, there needs to be a clear line of authority and liability that rests with one person and one LEA. Under co-location, it must not be unclear where final authority lies, and it must be transparent and clear to parents that there is a strong system and backstop supporting their students.
Deciding Who, When and Why to Co-Locate: The decision to co-locate must have a process, standards and protocols that must include significant community, staff and parent input and majority support in both schools as measured by clear, transparent data. Currently, the District has no clear, common, and transparent method for defining building capacity and utilization. We allow each LEA to decide their own building capacity however they deem appropriate, and it is therefore not accurate to compare capacity rates across LEAs. However, for DCPS, those schools are not involved in setting their own capacity; this is done by DGS.
In addition, it is extremely difficult for supposedly underutilized DCPS buildings to increase their capacity due to structural obstacles in how our common lottery process works. As documented in the Auditor’s enrollment projections audit, DCPS typically only puts seats in the lottery that align to current school budgets, not “extra” seats that align to underutilized building capacity. DCPS would need to have an intentional school growth plan and place all of those extra seats in the lottery in order for them to be filled.
This is not what happens. These schools are facing a structural battle to fill so-called “empty seats.” As the [council] Chairman knows, after reviewing the MFP and not approving it, it contains no plan for dealing with either underutilized buildings or over-enrolled buildings. There is no substantive plan to grow these schools. If forced to co-locate it will further the “death spiral” in enrollment outlined in the DC Auditor’s second report on enrollment projections. Instead, Council should continue to work with the DME to produce an MFP that actually meets legislative requirements, or hire a firm that can produce the needed work.
Building Operating Hours, Holidays and Shared Spaces: Currently, DC’s 63 LEAs run on different calendars and hours and use shared spaces in many different ways. Co-location requires significant contract and liability agreements that align calendars and hours to ensure the safety and health of students, adequate security, and time for schools to do necessary repair and cleaning of schools when no students are in the buildings. And there must be a final say leader who determines how shared spaces are used, protected and kept up.
Liabilities and Systems for Outside Vendors and Partners: Both schools must operate under one system for vendors and partners and must ensure that only the highest standards for student safety are met. Currently LEAs operate under different agreements and different standards.
Building Repair and Standards/Protocols: Currently DCPS and other LEAs operate under different standards for management and upkeep of their buildings. Presumably, under co-location, DCPS would manage the buildings and their standards should be kept. This calls into question who would receive and manage the current charter facility allotment and who manages the enrollment counts to dictate those allotments.
Health and Safety Standards: We know that in a school building there are many adults and children that come through the doors every day–regardless of which school, event, class, or meeting they are attending. Children are not isolated to one grade or one room–they move throughout buildings, share common spaces. The entire building community (parents, staff, community, partners) shares spaces and resources. Currently, LEAs operate under different standards for health, safety and security. Final say would have to be set for the highest standards to allow for building-wide safety measures to be activated in time. For example, if an adult in one school within a building sexually assaults a child, we know that that adult has had access to every child in the building. Governance protocols must ensure that every family in the building is communicated to, that proper procedures are followed, and that there is one leader and LEA responsible and liable. If schools will close due to a crisis in weather or other, one LEA decision must trump the other.
Transparency Standards: Communities in buildings are porous and human. Adults and children will share spaces, community and resources. When a parent or child experiences a problem in the building, there must be one protocol for transparency requirements. Currently LEAs operate under varying levels of transparency.
Discipline Standards and Protocols: Children interact throughout buildings. Bullying, drugs, violence, or any other misconduct must have a building-wide policy and enforcement. Currently policies vary amongst LEAs.
Enrollment Management: Enrollment management is a major part of every school’s work. Different LEAs have different student information systems managing this day to day enrollment work. In addition, throughout the year, enrollments change in any given school for a variety of reasons–which affects how the entire building operates. The very buildings the District may consider underutilized in the fall are likely to be less so in the spring, as reported in OSSE’s report card data and the Auditor’s recent enrollment report. Co-location requires a multitude of decisions around enrollment that have significant consequences for funding for the building and schools, but also for the health, safety and management of the building.
All of these issues are significant governance issues that affect all schools that consider co-location. We cannot dismiss these issues as school-by-school logistics to work out. There are deeply rooted policies, laws and practices that must be agreed to as a system–and currently they are not the same in word or practice for all LEAs. Before we consider co-location, there must be system-wide policies and changes to governance to accommodate any system-wide policy to allow co-location. Such system wide policy and governance change requires significant research, public input and policymaking to ensure that parents are certain that any option for co-location will have the highest standards for learning, health and safety for all students.
Examples that Council should expect to see in DC with the passing of this amendment:
Please reject the Mayor’s budget proposal for co-location now and give it the full time, attention and public debate that it deserves.