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Mayor Bloomberg, NYC Dept of Education, CEC District 15: Maintain Existing District 15 Zoning & Reject the Proposed Rezoning

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The Coalition of Residents for Fair Rezoning is a grassroots effort to protect the future of Brooklyn's children and our community. The current DOE proposal seeks to rezone the boundaries of PS321, PS107, and PS10 in an unfair, elitist, and ineffective manner.

First, the claim is that PS 321 and 107 are currently too overcrowded.  The new plan replicates and worsens this condition, rather than alleviating it, and disrupts PS10 in the process. In fact, according to the 2011-12 Blue Book, the Aquinas Building currently has the capacity to serve 229 students. With this proposal, the DOE now claims that the building can accommodate 275-335 students when it re-opens as a new school in September 2013. That represents as much as a 46 percent increase over existing capacity estimates without any expansion to school facilities. We are extremely skeptical that the Aquinas building can realistically accommodate 335 students and are also worried that the DOE is not accurately estimating how many students will reside in the proposed zone given the agency’s historical challenges in forecasting how emerging residential developments will affect enrollment growth in the long term. There are already several large-scale residential projects under construction in Gowanus within the proposed school zone and given current trends, there are likely to be more large developments on the blocks between 3rd and 4th Avenues within the proposed zone in the near future. It seems very unlikely that the DOE will be able to maintain enrollment within the projected total range at the new school over the next few years. As a result, this school will almost certainly become one of the most overcrowded in the community by the time it reaches full scale, particularly since it appears destined to be tightly packed even under the most optimistic projections.

Further, we note the implications of enrolling only two classes per grade in a such a small facility. This arrangement leaves very little room for error in enrollment projections. Even a few additional students beyond the anticipated 50 per grade will create challenges with “breakages” and maintaining class sizes below limits allowed under UFT contract regulations. In addition, a school with such small total enrollment will struggle to fund salaries for specialty teachers (e.g., science, music, art, PE) given that overall school budgets are tied to enrollment. This is especially true for the years when the school would be phasing in and have total enrollment of just 100 students. How will the DOE ensure that the school provides physical education classes and art classes mandated by state law, particularly during the initial school phase-in period?

It is equally unclear how the proposed school will provide special education services to students during its first few years of operation. How will this new school opening with just 100 students and 4 teachers provide mandated support and intervention for students with disabilities?  It seems unlikely that a cohort of 100 students will have enough students with disabilities to deliver services at a cost-efficient scale?  Will those students be denied admission to the new zoned school due to their disabilities and, if so, where will they go? Another challenge for such a small school is fundraising. Larger schools in this community are able to raise significant sums through their PTAs, but a school at this scale would be drawing from such a small pool of parents that the capacity for fundraising would be severely blunted – at least during the first few years of operation.

We are also deeply concerned that the current proposal doesn’t deal with the underlying policy issues that are really driving overcrowding in the district. Right now, the DOE has a policy that creates “perverse incentives” that encourage people to sell their homes or rent-and-relocate as soon as their children are enrolled in “desirable” schools. The net effect of that policy is that – over time – as many as 30 to 40 percent of students in popular neighborhood schools live outside their school zone. Under the proposed zoning changes, there is every reason to believe that this perverse incentive will continue to play out as in the past, ultimately yielding little remedy to the overcrowding problem. People will move as soon as their kids are safely enrolled in their desired school, with new families moving into the homes they just vacated. As a result, elementary-aged children in both those families will all still be enrolled in those schools, exacerbating the already high number of non-zoned kids those schools serve. This proposal will not resolve the overcrowding problem in our schools in any meaningful way. Rather than kicking the can down the road, the DOE needs to take a hard look at current enrollment policies and consider making long-overdue changes that will benefit students in D15 and in other overcrowded schools citywide.

It is disturbing that the CEC appears to view the rezoning proposal as leverage.  Our homes are not currency the CEC can trade to win a long-sought victory at PS 133 regardless of the validity of concerns raised by families who will directly suffer under the new zoning. While the goals the CEC has for PS 133 seem laudable, it is absolutely unfair to disregard the important concerns of families in other parts of the district in order to achieve that singular goal. Further, given the purported goal of increasing diversity, it would be particularly ironic if the CEC's efforts to preserve diversity at PS 133 threatened the already limited diversity at PS 321, PS 39, and PS 107. Specifically, the boundaries for PS321, one of the least diverse elementary schools in Brooklyn, will be reduced to specifically exclude the most racially diverse block (the Census block group bounded by 3rd Street to the south, 5th Avenue to the east, 1st Street to the north, and 4th Avenue to the west). The proposed rezoning for PS107 similarly eliminates those Census block groups with the highest percentages of minority residents. PS10 will be overburdened with displaced students, which will decrease the space available in PS10 for handicapped and special needs children. The children zoned out of PS321 and PS39 will be forced into a new (yet, per the DOE's admission, highly overcrowded) school that the DOE has acknowledged as inadequate in its structure and space. This proposed rezoning will bifurcate and polarize our neighborhood into "upslope" vs "downslope".  We also hope that the CEC will think about the impact of this proposal on the larger Park Slope community beyond parents and students alone.

Due process is equally important both from a legal and moral viewpoint. Inexplicably, the public was intentionally excluded from the rezoning process until a deal was reached among "key stakeholders" (i.e., select school principals and select elected officials). Public meetings were not properly advertised, nor were any Spanish language materials prepared. An unacceptably limited comment period has been provided.

We would like to conclude by proposing some alternative strategies that might more effectively and immediately address overcrowding without the unintended consequences of the current rezoning proposal:

•Creating a Pre-K and Kindergarten Annex in the Aquinas building to house all early grade students. Instead of taking five years to reach scale, the Aquinas building would immediately and dramatically relieve capacity pressures in the two most overcrowded Park Slope schools.

•Creating a GT or magnet program that will encourage Park Slope families to voluntarily choose the new school over their current zoned options, alleviating overcrowding and expanding choice without destabilizing real estate markets. Right now, many Park Slope parents send their kids out of the neighborhood for GT programs, and many more GT-eligible students would likely accept GT admissions offers if they could do so while staying in their neighborhood.

•Creating a specialty school/program with an appealing theme or focus that will encourage families to voluntarily choose the new school over their current zone schools. This could include options such as a dual-language program, an ASD NEST program, an inclusion program (as at the popular Children’s School), an arts-themed school, or a replication of the Brooklyn New School – any of which would appeal to parents who are currently unable to get seats in existing local programs or who don’t wish to send their children far out of the neighborhood to take advantage of available programs not offered here in Park Slope.

Mr. Mayor, Chancellor Walcott, and members of the Community Education Council, we implore you to immediately reject the Proposed District 15 Rezoning. We thank you for your time.

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