Newark Board of Education Where Passion Meets Progress RogerLe?n Superintendent December 13, 2019 Dr. Lamont Repollet, Commissioner New Jersey Department of Education PO. Box 500 Trenton, RE: M.E.T.S. Charter School Charter Renewal Application Dear Commissioner Repollet: Please accept these comments on behalf of the Newark School District in response to the charter renewal application submitted by M.E.T.S. Charter School, in accordance with For the reasons set forth herein, we recommend and request that the application be denied. We respectfully recommend that the charter renewal application be denied for two reasons, each of which is sufficient to deny the application: renewal of M.E.T.S. would exacerbate the already great strain on the district schools in Newark, and (2) M.E.T.S. fails to enroll and serve a cross? section of Newark?s school-age population. (1) Renewal of M.E.T.S. would exacerbate the already great strain on the district schools in Newark. As a threshold matter, we respectfully submit that the Commissioner should deny any and all applications for new charter schools and charter renewals unless an applicant shows that it would serve, 01? currently serves, a specific educational need. Charter schools in Newark currently serve one-third of the District?s total student population. By 2023, charter schools are projected to serve over 50% of the District?s total student population, based on charter applications and amendments approved prior to 2018. While a comprehensive study of the impact of the charter school program on Newark?s students, staff, parents, educational programs, and finances has never been conducted,1 the fiscal and programmatic impact of such a large proportion ofthe District?s students being served in charter schools is indisputable.2 A study by the Rutgers University Bloustein School of Policy and Planning states that in 2017?2018, 1 In the Charter School Program Act, the Legislature required a comprehensive study of, among other things, such impacts of the State?s charter school program. N.I.S.A. 2 The author of Left Behind? acknowledges that ?charter school growth is indeed challenging district budgets? in Newark and Camden. See, 765 Broad Street - Newark. New Jersey 07102 973-733-7116 - Dr. Lamont Repollet, Commissioner December 13, 2019 2 Page charter payments were anticipated to account for 23% of the Newark School District?s total revenues. In fact, they account for approximately 30% ofthe District?s 2019-2020 budget. As that budget is barely sufficient to meet the District?s needs, the impact of such a large payment stream cannot be understated. A study published by the Economic Policy Institute discusses the impact of charter school expansion on students in predominantly urban, predominantly low?income urban areas such as Newark: - Few are paying attention to the breaches of legal rights of students, parents, taxpayers, and employees under the increasingly opaque private governance and management structures associated with charter expansion. . Expansion of charter schooling is exacerbating inequities across schools and children because children are being increasingly segregated by economic status, race, language, and disabilities and further, because charter schools are raising and spending vastly different amounts, without regard for differences in student needs. Often, the charter schools serving the least needy populations also have the greatest resource advantages. . With the expansion of charter schooling, public districts are being left with legacy debts associated with capital plants and employee retirement systems in district schools while also accumulating higher risk and more costly debt in the form of charter school revenue bonds to support new capital development.3 Each of these impacts is apparent in Newark, given the expansion of charter schools in the District in recent .years. application fails to show that renewal of its charter would have any positive impact on the Newark School District or its students, or that the school?s continued existence would have any impact in Newark other than to exacerbate the already great strain on the District?s schools. Its reported student performance on statewide assessments is lower than that of Newark?s district schools: 29.2% proficiency in English language arts, as compared with the School District?s 35%. math scores are not reported.) On the specific indicator of the school?s impact on student achievement, median student growth percentile M.E.T.S. has similarly performed less well than the School District overall: according to its School Performance Summary Report for 2017-2018, its scores were 38 in English language arts and 36 in mathematics. In contrast, the School District?s scores were 48 in English language arts and 46 in mathematics. In other words, M.E.T.S. has been less successful than District schools in helping its students achieve academic growth. 3 Bruce D. Baker, ?Exploring the consequences of charter school expansion in US. cities,? Economic Policy Institute [2016), available at 765 Broad Street - Newark, New Jersey 07102 - 973?733-7116 Dr. Lamont Repollet, Commissioner December 13, 2019 3[Page Further, the application shows that there is nothing distinctive or innovative about its educational program, nor does the school serve any underserved population. Thus, the school cannot be found to serve the purpose of the Charter School Program Act, which is to assist in promoting comprehensive education reform ?by providing a mechanism for the implementation of a variety of approaches which may not be available in the traditional public school classroom.? More specifically, charter schools are intended and expected to [among other things) ?encourage the use of different and innovative learning methods.? M. As M.E.T.S. offers no such different or innovative methods, or any educational approach or methods unavailable in the District schools, the renewal application fails to demonstrate any need for the school?s continued existence that might justify its negative fiscal impact. M.E.T.S. fails to enroll and serve a cross-section of Newark?s school-age pepulation. academic program offerings are a serious concern, and should alone provide a basis for non-renewal ofits charter. See See also (?The admission policy ofthe charter school shall, to the maximum extent practicable, seek the enrollment of a cross-section of the community?s school age population including racial and academic factors?) Data in the renewal application shows that the school currently fails to address the educational needs of Newark?s most vulnerable students, those with special needs and those identified as English language learners. These students comprise disproportionate segments ofthe student population in District schools.4 As to students with special needs, the renewal application shows that the school serves a much lower percentage of students with disabilities, 10%, than that served in District schools, 18.7%. In short, M.E.T.S. is not serving its proportionate share of eligible students. Even as to those it is serving, the brief description ofthe school?s special education program, on page 15 of the application and page 4 of its appendix, shows that none of the school?s students receive intensive special education services. The school?s special education programs include ?pull?out and resource room services? and a ?study skills/life skills program that is focused on preparing special education students for college life.? It utilizes a ?consultative model? in which ?the general education teacher is the primary individual to present lessons to the students and to implement learning strategies,? and ?a special education teacher visits several classrooms per block and provides assistance to students in the subject area.? The application makes no mention of 4 Research conducted at the Rutgers Bloustein School of Planning 8; Policy shows that the proportion of special needs students has historically been far lower in charter schools than in district public schools. According to the Bloustein School?s report, Newjersey Charter Schools: A Data-Driven View, the percentage of students with special needs in Newark?s District schools is approximately 40% higher than in Newark?s charter schools, and the percentage of Newark students with high-cost disabilities is approximately 17% higher in District schools than in the District?s charter schools. Even more startling, according to the same report, the percentage of students identified as English language learners is approximately 11 times greater in ewark?s District schools than in the District?s charter schools. 765 Broad Street - Newark, New Jersey 07102 - 973-733-7116 - Dr. Lamont Repollet, Commissioner December 13, 2019 4 a programs for students with severe learning disabilities, autism, behavioral disabilities, or those who are medically fragile, and it seems clear that the school has no programs in place to serve students with such needs, although those students make up a large proportion of the special education population in?district schools. If the school does not serve the entire spectrum of students with disabilities those with severe needs as well as those who may be served with less significant supports ?-it cannot be said to serve a cross-section of the community?s school?age population. As to English language learners, the application indicates not only an extremely low number of students with limited English proficiency just five students, 0.7% of the school?s enrollment5 -- but a woefully inadequate understanding ofhow to meet the needs of any such students who may wish to enroll in the school. Specifically, the application states [at page 16) that a student identified as an English language learner ?may be referred for additional assessment to the I 8: RS committee.? That committee, however, is (or should be) designed to meet the needs of students with learning, behavior, or health difficulties, see English language learners do not have such difficulties (except, of course, in specific cases], and their language needs should not be understood or treated as learning, behavior, or health issues. The application further states [at page 5 of Appendix that the school?s focus is ?a full English immersion experience.? While the content of this "experience? is not described, it seems clear that the school offers a minimal level of English language services, given the small number of English language learners enrolled. If it offered a wider range of services, a larger number of English language learners might enroll in the school. Finally, we are generally aware that M.E.T.S. has been placed on a probationary status pursuant to The school?s renewal application should be denied ifit has failed in any way to meet the terms of its probation or to correct the causes for its probationary status. While the comments herein do not directly address those matters, we would welcome an opportunity to do so separately. For all of these reasons, we respectfully recommend that the charter renewal application submitted by M.E.T.S. be denied. 5 In contrast, the District?s School Performance Summary Report shows that the student population included 11.9% English language learners in 2017?2018. That number increased to 13 in 2018?2019 and 16% in 2019?2020. 765 Broad Street - Newark, New Jersey 07102 - 973-733~7116 - Dr. Lamont Repollet, Commissioner December 13, 2019 5 I a Thank you for your attention to this matter. Respectfully, cc: Newark Board of Education Honorable Ras I. Baraka Joseph Zarra Iulie Bunt M.E.T.S. Charter School 765 Broad Street - Newark, New Jersey 07102 - 973-733-7116 -