Dear Petitioners,

The Schools of Tomorrow Implementation Committee (STIC) met on the evening of February 24 and voted to retire all options except one, effectively keeping Williams open.

Unfortunately, Williams is underrepresented on STIC. During this meeting, a small group of parents were able to vote in ways that protected their own schools while retiring options that placed other schools at risk. This structure creates a significant conflict of interest, as parents from a select few schools are positioned to make decisions that directly benefit their own communities at the expense of others.

Given the long-term impact of these decisions, it is critical that the process be more balanced, representative, and transparent. I urge the district to reconsider how STIC is composed and how decisions of this magnitude are made.

The below message was carefully researched and drafted by a concerned parent just like us which nicely points out some fundamental flaws:

Dear Members of the Schools of Tomorrow Implementation Committee,

Thank you for the time you have devoted to this process. I am a parent at Williams
Elementary, writing to share four data concerns and one legal compliance
question the committee should have before finalizing any recommendation to the
Board. I am not asking you to abandon the process — I am asking that the
recommendation rest on the most accurate data available.

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1. Williams already passes every standard this process was designed to
achieve — and closing it cannot be justified by SDC or equity
considerations.
Williams is currently classified as ideal (CPG = 3) in SJUSD's own Status Quo
workbook — the only closure candidate that already meets the district's ideal-size
standard. It is not being closed because it fails any metric. It is being used as a
tool to improve other schools' metrics, a rationale that deserves scrutiny
regardless of which option the committee recommends.
On SDC: this committee voted 22-1 to protect recently-consolidated SDC
programs from being moved again — a recognition that SDC relocation causes
serious, specific harm. The American Bar Association is direct: "the individualized
nature of special education directly clashes with the large-scale disruption of
school closings," requiring IEP teams to reverify appropriate services within tight
IDEA timelines, with no guarantee of continuity of the staff or program the child
depends on. That commitment is right. But protecting Simonds' SDC requires
exactly one thing: keeping Simonds open. It does not require closing Williams.
Conflating those two goals creates a false dilemma — and that false dilemma is
doing a great deal of work in the options analysis.
The argument that Simonds must stay open and therefore Williams must close
assumes closing Williams is necessary to make Simonds viable. SJUSD's own
scoring says the opposite. Option 5 — Williams open, Simonds open —
achieves 47% of schools at ideal size immediately. Option 5.2 — which closes
Williams and redirects its students — achieves only 42%. The committee is being
asked to permanently eliminate an already-ideal school community on the premise
that doing so improves district-wide outcomes. The district's own numbers show it
makes them worse.
The deeper premise — that Simonds will continue declining and needs Williams'
students to survive — rests on projections from the same methodology that
projected Simonds would grow to 734 students by 2023. Actual enrollment was
518: a miss of 216 students, nearly 30%. Meanwhile, the most recent actual CDE
data shows Williams enrolled 580 students in 2024-25 — an increase of 21
students, the only meaningful reversal of its decline trend in recent years. The
school projected to be declining is growing. The school whose projected future
size justifies this closure has a 30% error in its history. If the projection is wrong
again, an already-ideal school community will have been permanently eliminated

based on a forecast with a documented track record of being wrong about
Simonds specifically.

On equity: the relevant measure is not which schools remain open, but which
students bear the cost of displacement. Options that close Williams send its 529
students — already in a stable, ideal-sized school — into disruption to marginally
improve metrics elsewhere. The peer-reviewed research is clear: students who
experience school closure are 4.8% less likely to attend college, 4.7% less
likely to complete college, and earn 3.4% less annually at ages 25–27 (Kim,
2024, Annenberg Institute at Brown University). These lifetime harms persist even
when test scores recover — short-term stabilization does not capture the full cost.
The largest closure study ever conducted — 1,522 closures across 26 states —
found only 45–48% of displaced students transferred to higher-performing
schools; the rest lost up to 80 days of learning (CREDO, Stanford University,

2017). Closing an already-ideal school imposes documented, measurable, long-
term harm on a specific set of children — harm the district's metrics do not

measure and its timeline does not allow the community to fully consider.

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2. The enrollment projections driving these recommendations have a
documented 19.1% historical error rate — with no confidence intervals
published.
In 2017, SJUSD commissioned Davis Demographics to produce 7-year enrollment
projections based on Fall 2016 data, using the same methodology as the current
forecasts. Compared to actual CDE enrollment data for 2023–24:
Metric Value

Mean absolute error 19.1%

Schools within ±10% 9 of 24 (37.5%)
Schools off by more than 20% 9 of 24 (37.5%)
Simonds: projected to grow to
734

Actual enrollment: 518 (−29%
miss)

A 19% mean absolute error means a school projected at 400 students could
plausibly land anywhere from 324 to 476. For schools near the 535-student ideal
threshold, that margin is the difference between CPG = 2 and CPG = 3. The
current projections present single-point estimates with no uncertainty bounds —
the Board is being asked to permanently close school communities based on
forecasts with a demonstrated error rate of nearly one in five students.

For Williams specifically, the projections assume continued decline — but the most
recent actual CDE data shows Williams enrolled 580 students in 2024-25, an
increase of 21 students (+3.8%) over the prior year, the only meaningful reversal
of the decline trend in recent years. A 7-year forecast projecting continued decline
for a school that just grew is not a reliable basis for permanent closure. I would
ask the committee to request that staff publish confidence intervals for current
projections and explain how the 2024-25 enrollment increase at Williams was
incorporated into the current forecasts.

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3. The Metric 11.2 error was not a footnote — it corrupted the committee's
deliberations from the beginning.
Staff has acknowledged and apologized for the Metric 11.2 calculation error and
provided corrected scores. But that acknowledgment has a direct implication for
process integrity: the committee deliberated with wrong numbers throughout.
Every discussion of peer displacement, every vote touching on student disruption,
every option comparison — all conducted against a false baseline.
On January 27, eleven members — a majority of those present — voted to elevate
minimizing student disruption to the committee's first-order criterion. The motion
failed only because it required a two-thirds supermajority; the vote in favor
outnumbered the vote against 11-10. Those eleven members cast their votes on
the basis of peer displacement figures that understated the true harm. Had
members seen the correct numbers, which show Option 5 as the only option
achieving zero peer displacement, support for that motion may well have been
even stronger. More members supported making disruption the top criterion than
opposed it. The two-thirds threshold — not the will of the committee — is what
stopped it.
The corrected scores are now available, but the committee has not had the
opportunity to deliberate with them — the options were compared, ranked, and
refined against figures staff has since admitted were wrong. I am asking the
committee to acknowledge this plainly in its recommendation to the Board: the
central community-impact metric was miscalculated throughout the process, the
correct data changes the relative standing of the options, and the Board should
weigh that before treating this recommendation as fully informed.

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4. Closing Williams will require hundreds of children to cross Almaden
Expressway — a road the data shows is as dangerous as any 55 mph
highway.(85 accidents on 2024-2025, Santa Clara County classifies as high injury network")
SJUSD's Metric 8.4 flags roads with a 55 mph posted speed limit. If Williams
closes, the majority of its students will be reassigned to Graystone or Simonds —
schools on the opposite side of major roads like Almaden Expressway, posted at
50 mph. The 5 mph difference does not translate to a meaningful safety distinction
for a child on foot.

The AAA Foundation found pedestrian fatality probability at 50 mph is 75% —
compared to 83% at 55 mph. NHTSA reports 45 mph is the most common
posted speed at which pedestrian fatalities occur, accounting for 18.3% of all
pedestrian deaths nationally. IIHS has documented a 100% fatality rate for SUV
strikes at 40 mph and above. Children ages 5–7 are 12 times more likely to
misjudge traffic gaps than adults, and a young child's reaction time can be up to
33 times slower — meaning a vehicle at 45 mph covers approximately 55
additional feet before a child begins to respond.
This is not hypothetical. San José has officially designated Almaden Expressway a
Vision Zero Priority Safety Corridor. Since 2022 there have been four
confirmed pedestrian fatalities on this corridor — a double fatality in January
2022, and deaths in December 2023 and March 2025. The 2023 death directly
triggered a $4.2 million Santa Clara County Measure B safety project at
Camden/Almaden, an official acknowledgment that the road as configured is
incompatible with pedestrian safety.

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5. A required equity analysis has not been published — and it must cover
every protected class affected by every option, including Williams.
KRON4 has reported the proposed closures would displace approximately 36% of
SJUSD's Black elementary students and close Lowell Elementary, which is 92%
Latino. No equity analysis addressing these disparate impacts appears in any
published Schools of Tomorrow materials.
Staff has indicated California Education Code §41329 does not apply because
SJUSD is not in "financial distress" as that statute defines the term. This is
technically correct — §41329 applies to districts under formal state receivership,
and SJUSD holds a positive budget certification. But the equity analysis obligation
does not arise from §41329 alone. Three independent requirements apply
regardless of financial status:
• California Government Code §11135 prohibits disparate impact on protected
classes in any state-funded program — regardless of intent. A private right of
action exists under §11139. This statute was not affected by the December
2025 federal Title VI rule change; it is California state law.
• California Education Code §§200 and 220 prohibit racial discrimination in any
program of an institution receiving state financial assistance.
• California Attorney General Bonta's April 2023 guidance, sent to every
superintendent and board member in California, explicitly states these
requirements apply to all districts considering closures. It requires analysis of

whether criteria have disparate impact on protected groups, whether less-
discriminatory alternatives were evaluated, and whether any disparate impact is

justified by important educational goals. The AG applied this framework to
Oakland Unified — not in state receivership — demonstrating this is not
theoretical.

Asian Americans are a protected class under these statutes — under race,
national origin, and ethnic group identification independently. The Almaden Valley
is one of San José's most concentrated Asian-American communities, and
Williams' enrollment reflects that. A complete §11135 analysis must assess the
impact of each option on each affected school community, not only the aggregate
district-wide impact on Black and Latino students. An analysis that documents
displacement of one protected class while ignoring what closing Williams does to
its Asian-American community is facially incomplete.
More fundamentally, options that close Williams do not reduce racial harm — they
trade it, reducing displacement of one protected class while increasing
displacement of another. Government Code §11135 does not permit that tradeoff
as a defense. A policy that harms one protected group to benefit another is a
reallocation of discriminatory impact, not a less-discriminatory alternative.
I am formally requesting that the committee ask staff to produce before any Board
vote: (1) a written racial and ethnic impact analysis for each option on each

affected school community including Williams, (2) documentation that less-
discriminatory alternatives were evaluated, (3) an explicit analysis of whether any

option reallocates rather than reduces racial harm, and (4) a legal opinion on the
district's obligations under Government Code §11135 and Ed Code §§200 and
220.

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In summary, I am asking the committee to consider five things:
1. Williams already meets every standard this process was designed to
achieve — it is the only closure candidate classified as ideal in SJUSD's own
workbooks. Neither the SDC argument nor the equity argument justifies closing
it; Option 5 protects both Williams and recently-consolidated SDC programs
simultaneously.
2. Enrollment projections have a 19.1% historical error rate — and Williams'
actual enrollment grew last year. The Board should see confidence intervals,
not single-point forecasts, and staff should explain how the 2024-25 enrollment
increase was incorporated into current projections.
3. Metric 11.2 was miscalculated throughout the entire deliberative process.
The 11-10 vote on the committee's most contested criterion was cast on figures
staff has since admitted were wrong. The Board should be told this explicitly.
4. Closing Williams will send hundreds of children across Almaden
Expressway — a road with four confirmed pedestrian fatalities since 2022, a
75% pedestrian fatality rate at 50 mph, and a Vision Zero Priority Safety
Corridor designation. Any option requiring those crossings needs a safe-routes
analysis before the Board votes.
5. An equity analysis is legally required under Government Code §11135 and
Ed Code §§200 and 220 — which apply to all districts regardless of

financial status. Staff's §41329 response does not address these independent
obligations. The Board should not vote before this analysis is published and the
district's legal exposure assessed.

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I recognize this committee has worked for months under a difficult timeline and
with enormous community pressure. I am not asking you to slow the process
indefinitely. I am asking that the recommendation you make to the Board be built
on the strongest possible data, correct calculations, and full legal compliance —
because the decision you hand them will be permanent.
Thank you for reading this, and for your service to our students.
Respectfully,
[Parent Name] Williams Elementary Parent [Contact information]

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Attachments available upon request:
• Davis Demographics: "7-Year Student Population Projections" (June 2017,
based on Fall 2016 data) vs. CDE actuals — 24 schools:
• CDE cumulative enrollment data showing Williams +21 students in 2024-25
• Almaden Expressway pedestrian safety analysis (AAA Foundation, NHTSA,
IIHS, Vision Zero, fatality records)