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Letters 02-03
EPP January 2003 Letter to Mayor Bloomberg & Chancellor Klein

January 21, 2003

Hon. Michael R. Bloomberg
Mayor of the City of New York
City Hall
New York, NY 10007

Dear Mayor Bloomberg and Chancellor Klein:

The Educational Priorities Panel is a coalition of 27 civic, parent, and religious organizations that work together to improve the quality of public education for New York City’s children in order to close the performance gap between city schools and those in the rest of the state.

Bold plan As a coalition, we have been strong supporters of school-site decision making. Children First is a bold plan to make this concept a reality in New York City. In the fall of 2000, EPP members went to England and Scotland to visit schools in high-poverty areas in order to evaluate the strengths and weaknesses of school-site decision making after more than a decade of its implementation in the UK. On the negative side, we found a continual churning of top-down initiatives, some of which were implemented by poorly trained consultants. On the positive side, we saw a strong centralized system of education that was balanced by a strong management team at each school. Even in schools we visited that had an enrollment of only 200 students, the head teacher had the support of two assistant head teachers and a bursar who dealt with administrative tasks so that the other administrators could focus on instruction. Another advantage of the school management team was that it enlarged the pool of well-prepared candidates for the position of head teacher.

Provide support for principals Based on these observations, EPP urges you to provide building-level administrative support to principals in order to ensure the long-range success of Children First. Even before the era of community control, the New York City school system had a powerful mid-level bureaucracy. Your dramatic restructuring of this system requires building up the capacity of school-site administrators to assume new tasks previously performed by districts. No amount of training for new principals will prepare them to turn around schools if schools remain chronically understaffed. In fact, two highly capable principals of charter schools returned their schools to the system they had left because they were unable to cope with the increase in non-instructional tasks. If schools remain understaffed administratively, over time the six Support Centers you outlined in your plan could evolve into a powerful mid-level bureaucracy. Nature and systems abhor a vacuum.

Concerns remain As our coalition reviews the Children First plan, EPP will give you further feedback in areas where there is agreement among our member organizations. Some of our current concerns have been addressed by the plan, but others remain. During these difficult fiscal times, compounded by efforts to restructure a large system, the needs of our most vulnerable students could be ignored in budget and personnel decision making. For this reason, the Educational Priorities Panel makes the following policy recommendations 1) to maintain smaller classes in the early grades, 2) to reduce overcrowding, 3) to maintain funding for special education and preventive services, and 4) to curb the "push-out" practices of some schools.

1. Continue the reduction of class sizes (CSR) in the early grades. There still seems to be some confusion when advocates urge different members of your administration to support class size reduction. A frequent response has been that the city's fiscal woes preclude this type of new investment. This answer does not make sense to us. Possibly the problem is that the question should be better framed: Will this administration continue to use state and federal money to support class size reduction in the early grades? The Department of Education's initial allocation memorandum (BOR #1) states that $88.8 million in state funds and $33.7 million in Title II Part A funds (along with $21 million in ATS Adjuster tax levy) are supporting the creation of 1,586 classes at an average of 20 students. We urge your administration to maintain this program and not lobby the NYS legislature, as previous administrations have done, to eliminate the state requirement that class sizes be reduced in return for hiring more teachers with the $88 million or to use state Class Size Reduction funds for gap closing.

Research shows CSR is the most effecive intervention High-quality research has consistently found that low-income, urban students make significant learning gains when placed in smaller classes in kindergarten or first grade and that these gains are sustained if they remain in smaller classes up through the third grade. This research indicates that the CSR program is one of the most effective interventions funded by the state to help young children in low-income neighborhoods. Research findings are mixed when it comes to the impact of class size reduction in the higher grades, especially if only for one year or one subject. This seems to be borne out by the difficulty of removing middle schools from the state's list of low-performing schools, despite the fact that as far back as 1999, under the administration of Chancellor Crew, at least 10 percent of state funds for early class size reduction have been used to reduce class sizes in SURR middle schools. In light of this experience, we are perplexed at the continual re-emergence of class size reduction as a key strategy for turning around middle schools. Is there data that has not been made public about improvement of SURR middle schools with smaller class sizes? If so, could this data be shared with us?

While any reduction in class size is welcome, a scatter-shot approach to using limited state funding is not. With state funding for CSR frozen at $88 million for New York City, only 32,000 children are in smaller classes. We hope that your commitment to shield instruction from budget cuts includes a commitment to keep class sizes at current levels, and to maintain state and federally funded classes at 20 students from kindergarten to third grade. During the recession in the early 1990's, the school system provided waivers so that class sizes from first to third grade could be increased beyond 25 students. Class sizes in the higher grades grew even larger. EPP is hopeful that under your administration the current recession will not result in a similar pattern.

2. Develop new strategies to reduce overcrowding. The news that 8,000 more seats have been created by the elimination of district offices of community and high school superintendents confirms EPP's perception that better utilization of existing school buildings is needed. In EPP's recently released study, Castles in the Sand, we found that Department of Education documents for 2001 show that, system-wide, there were 26,623 more seats than students in elementary school buildings. Over capacity at the middle school level, with an excess of 39,585 seats, is even more extensive. In December and January, EPP members visited two middle schools where classrooms have been set aside for pre-kindergarten to second grades classes. Both schools have experienced a better school atmosphere by having these age groups share a building. EPP supports a more extensive use of k-to-8 schools and the placement of early-grade annexes in middle schools.

Use QPEF Bonds Public-private partnerships are another way to reduce overcrowding. We understand that New York State could issue $200 million in interest-free bonds under the federally-financed Qualified Public Education Facilities Bond program. Each state is being allowed to develop its own guidelines and regulations for the issuance of these bonds. EPP has urged the Governor and legislative leaders to target QPEF bonds for facilities in overcrowded school districts and to expand Building Aid for leases so that this private-public program succeeds. Your administration, however, needs to indicate whether it wants to encourage private developers to build schools that will then be leased by DOE. These private activity bonds will not increase the city's debt limit and will serve as a much needed stimulus to the economy. For EPP, the greatest benefit will be to reduce overcrowding, especially in Queens where school reconfiguration cannot create additional seats.

3. Your policy to shield the classroom from budget cuts should be expanded to also cover services for children with disabilities. In October, EPP held a budget "summit" to hear reports from community school board members, advocates, and parents on the impact on children of city budget cuts. Of particular concern were reports by advocates that special education services in many districts were being denied with greater frequency than in the past. Two years ago, DOE provided community school districts with greater flexibility and decision making in the use of special education and state and federal categorical funds by folding 45 programs into a $1.5 billion Special Needs/Academic Intervention Services block grant, often called "AIS." The promise that more services would become available to prevent special education referrals has not been kept. Instead, there now seems much more reluctance to provide services even when they are mandated. To EPP, the source of the problem may be that community school districts are being allowed to rollover unspent funds, which at the close of the last fiscal year totaled $108.6 million.

Don't underspend Academic Intervention funds. EPP asks that you determine the source of these FY 02 accruals. If a high proportion of AIS funds were not spent, EPP urges you to not allow districts to under spend AIS funds this year. It is our understanding from OMB and DOE budget documents that the city's budget cuts to districts were not intended to curb spending on services for children with disabilities. Not providing mandated services is not only bad education policy, it is a violation of state and federal law. We await the outline of the Children First plan for students with disabilities, which we hope will also ensure that targeted funding for special education and preventive services will be spent.

4. You need to a) assess if there is an unintended consequence of merit pay and the rating of principals and b) make adjustments in these incentives in order to curb abuses. It may be a coincidence in timing, but shortly after Mayor Giuliani initiated merit pay for principals, EPP began to hear anecdotal reports about students being "pushed out." Some students were being "counseled" by school staff to leave high school and enter GED programs. Others, who had dropped out, were encountering difficulties in re-enrolling in high schools, even "alternative" high schools. GED programs are not supposed to function as an option to a high school education, and alternative high schools are supposed to encourage students to re-enroll, so these stories were surprising.

Don't push teens out. These staff behaviors may represent a complex of motives. Grade retention policies, which have now been in place for over four years, tend to increase dropout rates. Also, budget cuts have resulted in an institutional bias among some high school staff that limited resources should be spent on students most likely to graduate. EPP is concerned about these anecdotal reports about inappropriate staff behavior because they are increasing. The problem has been recently documented in a joint report issued by the NYC Public Advocate's office and Advocates for Children, entitled Pushing Out At-Risk Students, which found that 55,000 students have been discharged annually over the last three years.

We are not familiar with all the criteria used for merit pay or the rating of principals, but EPP suggests that some factors be added so that school staff are not encouraged to increase their drop out and discharge rates in order to eliminate lower-achieving students, and therefore, artificially increase their achievement statistics.

In closing, we want to applaud your recent decision to support the Campaign for Fiscal Equity lawsuit. Should the Court of Appeals rule in favor of the plaintiffs and more resources become available in the near future, you will have an unprecedented opportunity to bring the New York City school system up to the standards of education that are commonplace in school districts in the rest of the state. In the short term, however, EPP understands the budget constraints facing the city and the public school system. Within these constraints, however, we have outlined policy decisions you can make this year that will limit the negative impact of budget cuts on school children and which will create a better school system.

Sincerely,

Marilyn Braveman, Chairperson
Noreen Connell, Executive Director

CC
Deputy Mayor Dennis Walcott, and
Deputy Chancellors Diana Lam & Kathleen Grimm

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