Newark Board of Education Where Passion Meets Progress Roger Leon Superintendent December 13, 2019 Dr. Lamont Repollet, Commissioner New Iersey Department of Education PO. Box 500 Trenton, 08625?0500 RE: Roseville Community 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 Roseville Community Charter School, in accordance with For the reasons set forth herein, we recommend 'and request that the application be denied. The application should be denied for two reasons, each of which is sufficient to deny the application: Renewal of Roseville would exacerbate the already great strain on the district schools in Newark, and Roseville fails to enroll and serve a cross-section of Newark?s school- age population. Renewal of Roseville 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, or 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 of the 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, 1In the Charter School Program Act, the Legislature required a'comprehensive study of, among other things, such impacts of the State?s charter school program. 2 The author of Left Behind? acknowledges that ?charter school growth is indeed challenging district budgets? in Newark and Camden. 765 Broad Street - Newark, New Jersey 07102 - 973-733-711 6 - 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 ofthese impacts is apparent in Newark, given the expansion of charter schools in the District in recent years. Roseville?s 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. On the specific indicator ofimpact on student achievement, the median student growth percentile Roseville has performed less well than the School District overall: according to its School Performance Summary Report for 2017?2018, its scores were 34 in English language arts and 19.5 in mathematics. In contrast, the District?s scores were 48 in English language arts and 46 in mathematics. In other words, Roseville has been less successful than District schools in helping students achieve academic growth. Further, the application shows that there is nothing distinctive or innovative about Roseville?s educational program. 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 3 Bruce D. Baker, ?Exploring the consequences of charter school expansion in US. cities,? Economic Policy Institute [2016), available at 765 Broad Street 0 Newark, New Jersey 07102 - 973-733-7116 - Dr. Lamont Repollet, Commissioner December 13, 2019 3 Page 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 Roseville 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. (2) Roseville fails to enroll and serve a cross-section of Newark?s school-age population. Roseville?s academic program offerings are a serious concern, and should alone provide a basis for non-renewal ofits charter. See See also (?The admission policy of the charter school shall, to the maximum extent practicable, seek the enrollment ofa 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 of the student population in District schools")L As to students with special needs, the renewal application narrative states on page 3 that 31 students with disabilities comprised 9.7% of the school?s population in 2018-2019. This appears to be a significant increase from the prior year, when those students were 3.4% of the school?s population, according to the School Performance Summary Report. Both numbers are much lower than the percentage of students with disabilities served in District schools, which was 16.4% in 2017-2018 and 18.7% in 2018-2019. Roseville is not serving its proportionate share of eligible students. - Even as to those it is serving, the application does not describe the programs and services provided in a manner that shows, with any certainty, that the students? special educational needs are being met. The continuum of special education services listed on page 17 of the application narrative seems suspiciously wide for the school?s 31 students with disabilities, and even more suspect for the much smaller number served in 2017-2018. In fact, the narrative suggests that ?a fully staffed child study team? would utilize such variety of services, but it does not say the school 4 Research conducted at the Rutgers Bloustein School of Planning 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 Newark?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 Page i actually offers or provides such services to its students. The narrative also says "[o]ut of district placements are If this means Roseville?s students with disabilities are being placed in District schools, and such placements are treated and funded as ?out-of?district? placements [which is, typically, Newark?s experience), Roseville is not only failing to serve its proportionate share of the community?s eligible students, but also failing to serve even those who choose to enroll in the school. As to English language learners, the application states that 102 of its 319 students, 32%, were of limited English proficiency in 2018-2019. Despite this relatively large number, the description of its services for English language learners (at page 18 0fthe application narrative] depicts a program of English as a Second Language (ESL) only, with no bilingual education program. This suggests that the school either fails to enroll any students who are-eligible for bilingual education or fails to provide its bilingual-eligible students with programs appropriate to their needs and abilities. Whichever is the case, the school fails to serve a cross?section of the community?s school~ age population.- Further, the narrative lists, among the ?changes, activities, and improvements? identified by the school to achieve the goals ofits strategic plan, to ?expand ESL program to include at least 2 ESL teachers who can effectively address the ELL student population.? This amounts to an admission that the school is not only failing to provide a bilingual education program, it also has no staff qualified to teach ESL. Thus, again, it is failing to provide its students with programs appropriate to their needs and abilities. For all of these reasons, we respectfully recommend that the charter renewal application submitted by Roseville Community Charter School be denied. Thank you for your attention to this matter. Respectfully, cc: Newark Board ofEducation Honorable Ras I. Baraka Joseph Zarra Julie Bunt Roseville Community Charter School 765 Broad Street - Newark, New Jersey 07102 - 973-733-7116 -