C4DC Proposed Revisions to COMP Plan Education Facilities Element

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Proposed Revisions to the Office of Planning offered by the signed members of the Coalition of DC Public Schools and Communities on the Comprehensive Plan Education Facilities Element 

The Comprehensive Plan Education Facilities Element proposed by the Office of Planning (“OP”) currently under consideration by the Council includes a number of excellent components and rhetoric. However, in some important respects the document includes proposed policies and rhetoric that undermine some of the important principles it espouses and in others key priorities should be even more forcefully advanced. With a modest number of revisions the document can be greatly improved. The themes captured in the proposed changes to the OP draft are shown below and an annotation of the specific changes follows.

  • Unequivocally establish that the key priority in the next decade is to ensure an excellent matter-of-right path from PK through high school in every community. Achieving that goal lay at the heart of ensuring equity and fairness and supporting the long-term growth of the city.

  • Call for rational correlation of changes in school capacity and location of school capacity to accommodate realistic expectations of need recognizing that significant overcapacity drives up costs and dilutes the dollars available to directly serve students sending them to administrators building owners and operators. Recognize that achieving a rational approach will require coordinated planning between the sectors and caps on additional capacity in areas with significant excess capacity.

  • Reject the idea of co-location of charter schools inside DCPS buildings as the path to rationalize capacity and need. Such an approach would make a mockery of the core goal of delivering an excellent matter-of-right system from PK through 12 in every community. As has been seen in other jurisdictions, co-location invites operational challenges with dual administrations in one building and maximizes administrative cost as opposed to investing in direct service to students.

  • Emphasize the importance or retaining publicly owned facilities and green space to ensure we can fully serve our families for generations. There has been relentless pressure for the city to cede building and green space to private entities. It is critical that it maintain adequate infrastructure to fully serve families and communities.

In short, in enacting a Comprehensive Plan Education Facilities Element, the Council should set the District on a path to address the consistent calls from District residents for great matter-of-right schools in their communities, sparing them reliance on a lottery and the need to shuttle their children around the city while also creating a fiscally responsible approach that will maximize investment used to directly serve students. 

Signed:

Ward 2 Education Council, Ward 3 Wilson Feeder Education Network, Ward 4 Education Alliance, Ward 6 Public Schools Parent Organization, Ward 7 Education Council, Ward 8 Education Council, 21st Century School Fund, DC Fiscal Policy Institute, EmpowerEd, Senior High Alliance of Parents, Principals and Educators, Teaching for Change, Washington Lawyers Committee for Civil Rights, Washington Teachers’ Union, Education Town Hall, Educatindc.net

Description of Proposed Changes

1200.2             Noting that there are specialized programs in both DCPS and the charter sector.  There had been a reference to specialized programs in the charter sector in 1205.2, but the reference should apply to both sectors and fits naturally here. 

1200.3                          Referencing matter-of-right and feeder systems. This echoes language from paragraph 1200.2 above and is consistent with the spirit of that paragraph and, for example, of paragraph 1202.1 (making clear that “DCPS is responsible for educating Washington, DC’s children and provides a school of right for every compulsory school-age child”) and paragraph 1208.2a. (noting that in the 2014 Student Assignment Process “{t}he overwhelming input from parents and District residents was that families want a District-wide system of neighborhood public schools that is equitably invested in and provides predictable and fair access to high-quality schools in all of the city’s communities.”)

1200.4             Underscoring the importance of retaining public facilities and green space. This idea is included elsewhere in the document but it is an important enough idea that it should be referenced in the introduction. 

1200.5             Adding a reference to the forward looking work that needs to be done to complete the modernization of our schools and confront the fact that the schools that have yet to be fully modernized are dominantly east of the river.

1200.8             Injecting a note of humility regarding the impact of the Element. (Not a critical set of changes). 

1201.1             Adding a reference to the importance of matter-of-right schools and feeder systems after the reference to the goal of strengthening local communities consistent with the change in paragraph 1200.3 above. Indeed, this change merely serves as a clarification since it is the matter-of-right schools and the feeder systems which are the most closely tied to communities and the goal in the paragraph of building and strengthen communities as opposed to citywide lotteries or application processes.

1202.1             Removing the reference to DCPS as a “traditional” LEA. The qualifier is not necessary. 

1202.4             Clarifying, consistent with 1202.3, that much of the enrollment growth has been in the early grades and also making clear that retaining students in the 6 to 12th grades remains an important challenge if we hope to retain families in the city. It is the case that there has been significant growth in grades 6 to 12 in some parts of the city but not all. The growth in some parts of the city illustrates that we can achieve growth in these grades and should strive to. 

1202.5             Pivoting from the OP draft suggestion of a need for significant new capacity. This is a substantive change. The data since 2016 does not support a need for significant new school capacity now or any time soon. In the meantime, significant excess capacity drives up operating costs and makes it more difficult to focus dollars on students. The fact that population trends have fallen short of predictions does not necessarily have the same implications in the housing space where there has been a shortage. But in the school space where there is significant excess capacity, slower population and enrollment growth is cautionary and must be accounted for. Indeed, if as is emphasized elsewhere, the city seeks to ensure the success of its existing schools including its matter-of-right schools and feeder systems, the sensible approach is to invest in the schools we have rather than exacerbate a capacity glut. 

1202.6             Continuing the substantive shift described above for paragraph 1202.5

1202.8             Tempering the OP draft treatment of the 2018 Master Facilities Plan as if it had been embraced by the city. The Council declined to endorse it. It should be treated as ideas put on the table by the DME as opposed to as a consensus document and the self-congratulation surrounding it should be toned down. This is another place where the redline suggests a substantive pivot.

1202.9                          Continuing the substantive shift described above for paragraph 1202.8. 

1202.10                      Moving language from later in the Office of Planning draft (after current paragraph 1202.15) to where it will fit more naturally. 

1202.11                      Adding a new paragraph as part of the substantive shift described above for paragraph 1202.8 and very importantly removing the endorsement of policy prescriptions in the 2018 MFP particularly the encouragement of co-location of charter schools in DCPS buildings. That is a very controversial idea that runs directly contrary to the goal of strengthening matter-of-right schools and feeder systems. Co-location instead would cap them. In each debate on this subject to date, city leaders have claimed that steps in this area neither encourage nor discourage such co-locations. The passage here would encourage them based on the un-embraced recommendations in the 2018 MFP. It is very important that such language be removed. 

1202.12                      Adding a new paragraph as part of the substantive shift described above for paragraph 1202.8

1202.13           Making clear that it is DCPS facilities and grounds that serve as community assets. That idea is already included in the paragraph with the reference to DCPS engagement, but the proposed change clarifies and makes the paragraph consistent. 

1202.15           Reflecting the movement of text with much of the text deleted after current paragraph 1202.15 appears in paragraph 1202.10 above. 

1203.2             Strengthening the call for a real MFP by changing “supporting” the DME in generating a long-range MFP to requiring it. The Proposed 2018 MFP fell short of what was required. The Council should require a real MFP soon. 

1203.3             Strengthen the requirement for assessments before new or expanded public charter or DCPS schools are opened. 

1203.4             Eliminating the affirmative encouragement of co-location of charter schools in DCPS buildings. Such a policy would directly contradict the over-arching goal of ensuring successful matter-of-right schools and feeder systems in every community. It may be that certain co-locations could be appropriate, but the blanket encouragement of co-location generally would be a significant mistake and destructive. 

1203.5             Cutting the reference to using PDR lands to address facility needs from population growth. The main message of this paragraph is not to use these spaces for schools. The draft should not step on that message. The city currently has ample capacity and as underscored elsewhere in the comments and edits the emphasis in the short and medium term should be on investing in and better utilizing those assets. 

1203.8             Continuing the removal of the affirmative encouragement of the co-location of charter schools at DCPS schools. See comments on 1202.10 and 1203.4 above. 

1203.9             Strengthening calls to complete the 2018 MFP process and echoing themes such as preserving public buildings and green space and strengthening matter-of-right schools and feeder system promoted elsewhere in the markup. 

1204.1             Addressing the fact that a couple of years have passed since the draft was generated and there have been some changes in the investment since then and some changes to the number of schools yet to be fully modernized or scheduled for such modernization. The edits also confront the reality that many of the yet to be fully modernized schools are east of the river. 

1204.2             Adding the idea of using modernizations to address overcrowding and taking out reliance on the Proposed 2018 MFP that was not endorsed by the Council.  

1204.10           Making clear the importance not just of matter-of-right schools but feeder systems from PK to 12th grade and stressing, as in the edits to 1202.4, the importance of the success of schools serving grades 6 to 12 in feeder systems. 

1205.2             Deleting reference to charters hosting specialized programs and moving it to 1200.2 above. Adding a reference to the reality that while many District laws and regulations apply to both DCPS and charter schools, charter schools are not subject to all of the laws and regulations governing DCPS. 

1205.4             Clarifying the material after the reference to the rules governing providing access to DCPS schools by charter schools to outline how many schools have been transferred to date and the state of the DCPS inventory. The OP draft could be read to encourage turning over more DCPS buildings to charter schools. It is important to note, however, that the loss of more buildings by DCPS would make building successful feeder systems serving many communities more difficult and that buildings are need for swing space as we complete the modernization of the schools yet to be fully modernized. 

1205.6             Echoing comment relating to paragraph 1202.13. Here it is clear that they are talking about DCPS schools in the context of potential transfers to charter schools but the edit makes that explicit. 

1205.7a           Removing the suggestion in the OP draft that uniform funding is a requirement. There was a lawsuit on this subject and the Attorney General and the Council took the position that the city was at liberty to provide funding outside of the formula. The suit claiming that it was not was dismissed. The modest edit here preserves the city’s vindicated position.

1206.1             Capturing the reality that students at private schools in the District include children from outside of the District.  `

1208.1             Clarifying that while reliance on population projections will be important, the city cannot rely on the projections in the Comprehensive Plan and the enrollment estimates in the Proposed 2018 MFP as they are clearly out of date with growth lagging the now out-of-date projections. As noted in the comment to the edits in paragraph 1202.5, the implication of the lagging growth might be different in the housing space where there is a shortage than in the school space where there is a glut of capacity. 

1208.2             Reinforcing that projections related to schools are particularly tricky given that perceptions of the quality of schools can have a dramatic impact on the appeal of cities and communities. If the city seeks growth, successful schools will necessarily be at the heart of the long-term growth of the city. 

1208.5             Making clear again that the 2018 MFP was proposed but not endorsed.

1208.6             Reflecting the reality that the Proposed 2018 MFP projections have not been realized suggesting slower enrollment growth than assumed. Given that, it is important to revisit the projections rather than rely on projections we know are not accurate. See comment to paragraph 1208.1 above.

1208.7             Continuing the point relating to paragraphs 1208.1 and 1208.6 above. 

1208.8             Continuing the point relating to paragraphs 1208.1, 1208.6 and 1208.7 above.

1208.9             Tempering some self-congratulation and underscoring the idea already in the paragraph that it will be important to retain school facilities and grounds, and making clear that that includes retaining DCPS school capacity. 

1208.10           Continuing the emphasis added in paragraph 1208.9 above. 

1208.11a         Noting again that it is matter-of-right DCPS schools that have been and are anchors for communities. 

1208.14           Following through again on the cut of the affirmative endorsement of the co-location of charter schools in DCPS schools. 

1209.1             Noting again that it is matter-of-right DCPS schools that have been and are anchors for communities and underscoring again the importance of successful matter-of-right feeder systems in every community. 

1209.2             Noting again that it is matter-of-right DCPS schools that have been and are anchors for communities. 

1210.1             Clarifying that it is matter-of-right DCPS schools that must be included in community planning. It is the matter-of-right schools and feeder systems that are most closely linked to community development. Meanwhile, currently, the city has no authority over the location of charter schools. 

1210.2             Fixing a typo. 

1210.4             Spelling out a term.