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EPP Letter
New York City Council Class Size Reporting Bill Int. 619                                                                                    

October 25, 2005

Eva S. Moskowitz
Chair NYC Council Education Commitee
250 Broadway, Suite 1545
New York, NY 10007

Dear Education Committee Chair Moskowitz:

            As you know, the Educational Priorities Panel is a coalition of 25 organizations working together to drive more resources to the classroom level for the benefit of children and their learning.

            Well-designed research of class size reduction efforts in Tennessee (the STAR program) and Wisconsin (the Sage program) found that this strategy resulted in significant learning gains for children from kindergarten to third grade, especially for boys from low-income families in urban school districts.

            For this reason, EPP strongly supported the NYS Assembly’s LADDER program and President Clinton’s federal budget initiative when they were introduced in 1997 to provide funding to public school districts to reduce average class sizes in the early grades. The combined state and federal funding streams now provide over $160 million annually to public schools in New York City.

            EPP strongly advocates that some agreed-upon portion of the expected $5.6 billion in Campaign for Fiscal Equity remedy funds be dedicated to reducing average class sizes in New York City. Estimates of additional funding need to reduce class sizes have ranged from $97 million to over $1.5 billion dollars, depending on the span of grades where class sizes are to be reduced and the target number of students in each grade. Just as important, these estimates depend on data about current class sizes in New York City public school.

            EPP is profoundly shocked to learn that no reliable data exists on average class sizes in New York City:

• In direct conversation with NYS Department of Education (SED) staff responsible for collecting and analyzing class-size data for all school districts in the state, EPP staff was informed in 2004 that for the last several years SED has been discarding the BEDS (Basic Educational Data System) questionnaire answers on class sizes submitted by principals in New York City. The class size averages for New York City that have appeared in recent SED State of Learning reports to the NYS Legislature reflect SED statistical projections, not actual data. In the 2004 edition of State of Learning, it is noted that SED was unable to make projections about New York City class sizes during the 2002-03 school year. Since the U.S. Department of Education depends on state sources for data, New York City class sizes for 2002-03 are also excluded from national statistics.

• A NYS Comptroller’s audit of the state-funded class size reduction program found that, since the 2000-01 school year, close to 700 fewer early-grade classes were created every year than anticipated by the NYS Legislature. The New York City Department of Education (DOE) does not agree with this finding and also disagrees with the methodology used to arrive at this figure. But statements by NYC DOE officials about their agency’s compliance with this state-funded program tend to lack credibility due to the absence of reliable data on class sizes.

• Class Size Matters has informed EPP that class-size averages computed by the NYC Independent Budget Office, based on information provided to this agency by NYC DOE, included “virtual classrooms” of students who were scheduled to enroll but did not appear at a school or who had long stopped attending the school. These “virtual classrooms” have one to five students, thereby dramatically lowering reported class-size averages in some schools, grades and districts.

• On two occasions, in direct conversation with NYC Department of Education budget staff, EPP members were informed that allocations for teaching staff that are received by a school, based on student registers (either projected or actual), do not have to be used for classroom teachers, but are merely part of the formula for computing the total funds that are allocated to a school. While school “x” may use teacher staffing funds for classrooms, school “y” can use a portion of teacher staffing funds to support a school secretary or librarian position. Thus, an attempt to estimate the number of classes by analyzing funding that is budgeted for teachers does not result in a reliable indicator of class sizes or even student-to-teacher ratios.

            The absence of reliable data on class sizes in New York City has two serious and immediate implications: 1) It undermines the state’s $88 million class size program and 2) It calls into question all the estimates of the cost of reducing class sizes further when CFE remedy funding becomes available.

            Your sponsorship of In. No. 619, a local law to amend the New York City Charter to require the NYC Department of Education to report on the average class sizes in each school to the City Council seems to be a solution to the absence of reliable data. EPP was pleased to learn that the NYC DOE was supportive of this legislation, though we also understand that this reporting is not onerous since even more detailed data also has to be compiled for the New York State Department of Education.

            This legislation, however, needs to be strengthened so that the information collected and disseminated has validity and can be used as the basis for policy making:

1. For the most part, above the elementary grades, students are not in one class, but are instead in five to seven “subject” classes, such as math classes and English Language Arts classes. It makes little sense to compute a “class size” for these middle and high school grades that cannot be compared to class sizes in the rest of the state.
2. EPP was not informed of the reasons why SED discarded class size data from New York City, just that it was deemed unreliable. The NYC Council may also be the recipient of unreliable data. EPP can see no remedy to this problem beyond public reporting by principals at the school level as to student enrollment and average class sizes by grade in elementary schools and by subject classes in middle and high schools. This information should be made available to parents (through information sent home with students as well as posted on the internet) as well as to all school staff in the school, to CEC’s, and to organizations, such as Advocates for Children, that provide profiles of schools through the internet.
3. It would also be helpful to require public reporting by the principals about the school building’s capacity (using the two methods of computing a building’s capacity). When EPP did research for our 2002 report, Castles in the Sand, we found that Board of Education capacity numbers were sometimes wrong. Principals were not aware of these errors unless asked directly to confirm them. Requiring principals to provide current capacity information to parents and school staff and through the internet will result in a reduction of these errors.
4. The legislation needs to spell out the methodology used to compute average class sizes in the elementary grades and by subjects in the middle and high schools. EPP urges the Council staff to contact SED staff to learn their methodology so that the averages reported to the Council are similar to the ones reported statewide.
5. Similarly, class size averages can vary depending on the time of year that the data is collected. This is especially true at the high school level, when student registers can decrease in the spring semester. EPP recommends that class sizes should be reported as of the first Wednesday in October, which is the time frame used for BEDS reports.
6. Since NYS Department of Education BEDS reports are due by the third week in October EPP recommends that the NYC Department of Education be required to put the legislation into affect as soon as possible after this date. Next year, the reporting deadline should be the same for the BEDS data, the NYC Council, and for school and internet notices.
7. CTT classes, SETSS classes, other special education classes, classes for ELL students, and vocational classes need to be reported separately and should not be included in averages for class sizes in the elementary grades or subject classes at the middle and high school level.

            EPP wants to thank you for introducing this legislation and securing the support of your colleagues for this legislation. Since data gathering for SED on class sizes already takes place, but is flawed, we believe that In. No. 619 will help eliminate the errors in this data. It is critical that this legislation be amended so that the data gathering is not duplicative and so the information that results can be compared meaningfully to state level data.

                                                                                    Sincerely,

Marilyn Braveman                                                      Noreen Connell

Chairperson                                                                 Executive Director

Cc: Councilmembers, Leroy G. Comrie, Jr.,  Helen D. Foster,  Robert Jackson,  G. Oliver Koppell,  Andrew J. Lanza,  John C. Liu,  Domenic M. Recchia, Jr.,  Albert Vann,  David Yassky, Bill de Blasio. Maria Baez, Gale Brewer, Lewis A. Fidler, James F. Gennaro, Allan J. Gerson, Letitia James, Miguel Martinez, Michael C. Nelson, Annabel Palma, James Sanders Jr., Helen Sears, David I. Weprin, and City Council Speaker Gifford A. Miller and Public Advocate Betsy Gotbaum