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June 1, 2012Susan Miller Barker Interim Executive Director Charter Schools InstituteState University of New York 41 State Street, Suite 700Albany, NY 12207Sally Bachofer Assistant Commissioner New York State Education Department89 Washington AvenueAlbany, New York 12234Dear Ms. Barker and Ms. Bachofer:We write to comment on the methodology proposed by the Charter Schools Institute(“CSI”) of the State University of New York (“SUNY”) and the New York StateEducation Department (“SED”) for establishing enrollment and retention targets(“Targets”) for New York charter schools.Although we appreciate your efforts, we do not support the establishment of hardenrollment and retention targets for students with disabilities (“SWDs”), Englishlanguage learners (“ELLs”), and students who qualify for the federal Free and ReducedPrice Lunch program (“FRPL”). The establishment of such targets does not serve theinterests of children.
Institutionalization of Perverse Incentives that Penalize Good Schools
The proposed targets institutionalize perverse incentives for charter schools. Withrespect to the proposed ELL targets, schools are
penalized
for graduating their ELLs fromELL status and
rewarded
for failing to teach their ELLs English.While SUNY and SED have attempted to address this issue by creating a three-year “look-back” period, we do not see how this fixes the problem. Success Academy schoolsstart with kindergarten and first grade, and will eventually grow to eighth grade (and possibly high school). Because the schools do not admit new students beyond thirdgrade, a three-year look-back does not remove the penalty for schools that graduatedstudents from ELL status more than three years ago. Moreover, charter schools arestatutorily mandated to hold random lotteries, subject to allowable admissions preferences, and can only backfill any vacancies from their waitlists—they cannot pick and choose only ELLs, SWDs and students eligible for FRPL. As Success Academy
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schools continue to graduate their ELL students from ELL status, the number of ELLstudents admitted through the random lottery, even if a constant 20% (which is the set-aside percentage for ELLs at Success Academy schools), will comprise a smaller andsmaller percentage of the overall growing student population each year until the schoolsare at scale.To illustrate, the average ELL student in traditional public schools requires more than 5years to graduate from ELL status.
1
By contrast, Success Academy schools, on average,graduate ELL students from ELL status within 2 years. If a new Success Academy ELLfirst grader graduated from ELL status after 5 years (end of 5
th
grade), using thetraditional public school average, the three-year look-back would ensure the studentcould be counted toward the ELL target until he/she finished middle school. Theschool’s
failure
to teach the child English within 5 years would keep the school in goodstanding with respect to the ELL target. But the reality is that any Success Academyschool will likely graduate the student from ELL status within his or her first or secondyear. The three-year look-back would be a grace period for three years, but there wouldstill be four to five years until the end of middle school during which the school would be penalized for having graduated the student from ELL status “too quickly.” Indeed, our middle schools’ ELL percentages should be zero or close to zero because we expect tohave graduated all of our ELL students from ELL status by that point – bizarrely, our successful education of ELL students will actually put us out of compliance with the proposed ELL targets.Likewise, SWD targets are equally problematic. The issue of graduating SWD studentsfrom their Individualized Education Programs and integrating them fully into the generaleducation program is not as critical a focal point as with ELLs because some SWDs willnot be able to do so, given the nature of their special needs. However, the proposedtargets nonetheless institutionalize perverse incentives to over-identify students withdisabilities and to not move students fully into the general education program if and whenthey are able and ready to do so.
Institutionalization of Segregated Schools
The proposed targets have the draconian effect of essentially requiring charter schools to be economically and racially segregated.Integration has been a colossal failure in New York City public schools. Despite itsdiverse population, New York City's schools are among the least diverse in thenation.
2
The school system in New York City is largely divided along racial andsocioeconomic lines—with the overwhelming majority of African American/Hispanic
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1
!!
See
Success Charter Network report,
The Parking Lot of Broken Dreams: How English Language Learner programs in NYC hurt children
, March 2011 (attached as Exhibit 1).
2
Kleinfield, N.R.,
Why Don’t We Have Any White Kids?,
N.Y.
T
IMES
, May 11, 2012,
available at
http://www.nytimes.com/2012/05/13/education/at-explore-charter-school-a-portrait-of-segregated-education.html?smid=pl-share(last visited May 31, 2012) (attached as Exhibit 2).
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and low-income youth attending the weakest traditional public schools in the City, whiletheir Caucasian middle-class counterparts generally attend the best traditional publicschools in the City.
This issue is best illustrated by a tour through New York City Community School District(“CSD”) 3. CSD 3 is located in the west side of Manhattan and includes Central Harlem,Manhattan Valley, the Upper West Side, and Lincoln Center. It encompasses incrediblediversity, both racially and socioeconomically. CSD 3 has 43 traditional public schools.Twelve of those schools (28%) would not meet the proposed FRPL targets.
3
The ten CSD 3 schools that would be furthest from meeting the proposed FRPL targetshave the following characteristics: (1) their student populations are, on average, 30.8%African American or Hispanic,
4
(2) their average 2011 New York State Math and ELAAssessment passage rates were 85.7% and 80.6%, respectively,
5
and (3) they are alllocated in the most affluent areas of CSD 3—below 96
th
Street, with one exception. Bycontrast, the ten schools that would most exceed the proposed FRPL targets have thefollowing characteristics: (1) their student populations are, on average, 84.5% AfricanAmerican or Hispanic,
6
(2) their average 2011 New York State Math and ELAAssessment passage rates were 44.4% and 35.9%, respectively,
7
and (3) all but one arelocated in the least affluent areas of CSD 3—at or above 96
th
Street. The map belowdisplays this location divide with the district schools that would be furthest from meetingthe proposed FRPL targets in blue and the district schools that would most surpass the proposed FRPL targets in red:
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3
Based on data from the Empirical Analysis of School Enrollment Rates using ProposedMethodology,
available at
http://www.p12.nysed.gov/psc/enrollment-retention-targets.html (lastvisited May 31, 2012).
4
Based on data from the New York City Department of Education’s School Demographicsand Accountability Snapshot,
available at
http://schools.nyc.gov/NR/rdonlyres/2DC1923F-96D9-443B-943B F5CBC29C47D0/0/CEP6162011FINAL.xlsx(last visited May 31, 2012).
5
Based on the New York City Department of Education 2010-2011 Progress Reports,
available at
http://schools.nyc.gov/Accountability/tools/report/FindAProgressReport/default.htm(last visited May 31, 2012).
6
See
note 2,
supra
.
7
See
note 3
, supra.
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