Feedback on Boundary Process from Cathy Reilly
August 2, 2024
Dear Deputy Mayor Kihn, Jenn Comey, and Michael Akin,
This is my feedback on the Student Assignment and Boundary Study Process. I appreciate the chance to weigh in and hope that it will inform future convenings. As I get more distance from the process, I have felt more distressed about some of what follows. We spent so much time with some communities and so little with others that will be affected in the future. I do have the experience of the two committees 10 years apart. I hope we can capture some of what the first offered that we did not have this time in the next iteration. If I can I will try and send on more thoughts that capture that.
The Advisory group was a strong and thoughtful group. The choice to have the number of members on the committee reflect the proportion of DCPS students from the different wards of the city worked. I felt the decision to have the government as voting members compared to the practice in 2013 to have them present and contributing but not voting, had mixed results. I can share more on this if it would be helpful.
One Geographic Feeder Pattern: One goal of both the 2013 and 2023 committees was to ensure that for consistency and equity that all students would have the geographic right to one feeder pattern. This would be clear and would not negate other programmatic rights. Everyone still has the ability to participate in the lottery.
Recommendation #8 accomplished this. It acknowledged that a 10-year ramp from the 2014 recommendation to implantation was more than sufficient for families to make plans. It reads: “DCPS shall effective SY2025-26 sunset the 2015 revisions that extended the phase in policy for families assigned to a new middle school until 2022. This sunsetting ensures that every middle school attendance zone boundary will consist of the select elementary attendance zones designated to it and no students will have multiple middle school geographic rights” [1]
The executive put forth this recommendation, the committee approved it and then the executive essentially rescinded it. The reasoning from the executive that there has been inadequate time for communication and notification could have been resolved with a one or two year further extension. The lack of clarity, given that there is a map, could have come with a list of the addresses affected confirmed.[2] Instead there is just a statement that: DCPS will specifically review the following phase-in policies from the 2014 study due to the lack of clarity and communication with families (particularly during and after the pandemic), which will remain in effect pending DCPS’s review.[3]
There is no end date or even commitment to honor these policy recommendations in the communication. This recommendation was advanced by two different advisory groups 10 years apart. The Mayor could have stated in March of 2023 that she is going to retain dual geographic rights for this select community and maintain the dual feeder pattern for Kelly Miller.[4] She could have acknowledged she was making an exception for only these 2 groups and provided her reasoning. We could have debated and engaged publicly then.
Pending further explanation, I am left to assume that a community can always make an end run around this process with little public justification. The statements I made to these communities (that this policy would be implemented) and the trust they placed in me and this process was betrayed. While the final say was always with the Executive, I assumed it would apply to new recommendations that came from the committee, not ones that originated with the executive.
This undermined the integrity of the process. In 2014 it made some sense because it was a new Mayor. That was not true this time.
Time: The meetings were kept to roughly two hours which was not enough time. I would recommend either more meetings or more time at the monthly meeting to allow for more closure.
Groupings: DCPS is an agency under the Mayor. There is no way that this does not affect the discussion even with some speaking more openly. The citywide group to wrestle with potential recommendations that would be citywide was almost completely government with charter, lottery, the DME. DCPS was not able to attend all of the meetings and representatives of the geographic groups were consulted at the end with the writing of the final recommendations. This group was more of a government group with input from the advisory committee members at the end of the time. I believe this should have had representation from the geographic groups or it could have been conducted with the whole group as it was at the end. I found the framing and the process here very difficult. I hope this whole piece can be rethought.
Time on Maury Minor versus time in wards 7 and 8 on reasons for staying and leaving DCPS
I felt the focus on Maury Minor and the enormous amount of time spent there to promote integration meant that time was not spent on understanding why families particularly in wards 5, 7 and 8 were travelling from their neighborhood school and why some were staying. Under enrollment is a huge issue and the travel time and inequity between these wards and ward 3 in particular was only addressed at the very end with recommendation #17 . We could have done far more with this and it would have informed socio economic and racial integration. We got a hint at the in- person meeting with Sousa that this would have been productive. This was really unfortunate and a missed opportunity. The one recommendation requiring DCPS to go further with program equity should have been more fleshed out during the process. We will see if it goes anywhere. I think this piece of the process should be re-examined.
Equitable Access: I realize the working theory is that equitable access is providing a preference for students to travel to schools outside of their neighborhood to schools that are perceived as higher quality using the limited measures that we have. I continue to disagree with this definition and would have wished for more of an effort to discover what families would like to see at their schools or in their neighborhoods so the longer travel would not be necessary. Could they have closer to home, the quality that they are travelling to?
Joint Planning: According to Recommendation 23, the DME work with PCSB and DCPS on an aligned and transparent planning process to be completed by December of this year. I look forward to the opportunity for public feedback on the plan and on the process. It is my hope that there be a clear acknowledgement and adjustment noting that DCPS is by far the largest LEA and it is the publicly managed infrastructure. It is not just one of 67.
Contractors: It was my experience that the WXY had a system and format that they wanted to follow. I did not feel it was a good match for the challenges that we are facing. There were adjustments but overall, we still jumped to the policy levers before enough exploration of why. Also, the scenarios were confusing. Perhaps I was spoiled by the experience with a local contractor last time and the knowledge and expertise that comes with that.
I do understand how difficult these issues are. We all made compromises. I appreciated being a part of both groups. I learned and continue to learn from these processes. I will not be on the next panel in 10 years. I do hope that the lessons learned will inform it however especially the area where the process was undermined.
Thank you,
Cathy Reilly
Member of the 2013-2014 DC Advisory Committee on Student Assignment and the 2023 Boundary and Student Assignment Study Advisory Committee.
[1] https://dcgov.app.box.com/v/2023dcboundaryreport
· [2] Dual Wells & Deal rights: homes in the 6300-6600 blocks of 16th St NW (west-side,
even #’s only) and 1600 blocks of Tuckerman, Underwood & Van Buren St’s NW. (In-bounds for Brightwood ES but west of 16th St NW)
Dual MacFarland & Deal rights: all of Crestwood: all who are west of 16th St NW in the 3900-5000 blocks between Shepherd St NW & Colorado Ave NW; most of 16th Street Heights: everyone north of Arkansas Ave NW from 16th St NW to Georgia Ave NW up to Longfellow St NW.
Dual MacFarland & CHEC rights: homes east of 16th St NW, south of Quincy St NW, west of Georgia Ave NW, and north of Park Rd NW.
[3] https://docs.google.com/document/d/1G4AgFlT8x7_JZhG_CzgOkB8T-Jaout2jOahoPVWSVFk/edit?usp=sharing
[4] Dual middle school rights
• For families residing in the MacFarland MS and Ida B. Wells MS boundaries who
had been previously zoned to other middle schools (see the attached map).
• For families whose children attend Kelly Miller MS and have a dual middle
school right to Eastern HS.
The right of siblings of a child attending their zoned school prior to the implementation
of the 2014 boundary changes to attend either their original or newly zoned school.
DCPS will prioritize this review after its implementation planning for the 2024 Boundary Study
recommendations.
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