Chicago Educational Facilities Task Force SCHOOL ACTIONS COMMITTEE
COMMENTS on CHICAGO PUBLIC SCHOOLS’ 2015-2016 DRAFT SCHOOL ACTIONS GUIDELINES
Submitted on Behalf of the Committee by Chairperson Valencia Rias-Winstead
The School Actions Committee of the CEFTF is recommending that Chicago Public Schools Draft School Actions
Guidelines be revised, to state the following:
Just as there will be no school closings proposed or taken, the CEO also will not propose any other School
Actions. CPS is in a period of financial stress and uncertainty, which presents challenges to determine and
support the full costs associated with taking School Actions. Furthermore, the 10-Year Educational
Facilities Master Plan must be revised and updated by January 2016. CPS’ public engagement and planning
process for updating the EFMP will provide the opportunity to examine and evaluate CPS’ past School
Actions, carefully examine best practices used in other school districts, and develop new or revised policies
to promote long-term, comprehensive facility planning that is sustainable and equitable for the District as
a whole.
Why CPS’ CEO Should Refrain from Proposing School Actions
The CEFTF School Actions Committee recognizes the current strain on CPS funding and resources, and that a
resolution of its FY2016 budget deficit is not yet in hand. At this time, it is unknown when and how the budget
deficit will be addressed. The CEO has publicly stated that without additional revenue, CPS may have to lay off
“thousands” of additional teachers in January 2016. Undertaking further School Actions in this climate of
uncertainty and instability will only exacerbate these circumstances, and incur additional expenses for CPS.
The school district has very recently had another turn-over in leadership. The new Leadership Team has not yet
had a meeting with the CEFTF to review the requirements of IL P.A. 97-0474, discuss the challenges of updating
and revising the 10-Year Educational Facilities Master Plan (EFMP) due in January 2016, or review the
Recommendations made by the CEFTF in its June 2014 Report. Rather than propose any School Actions now
(to be implemented in the 2016-2017 School Year), CPS should take the remainder of the current school year
to address its financial crisis, and allow the new Leadership Team to work with the CEFTF and other
stakeholders on developing a more robust and comprehensive EFMP.
Most importantly, a "hiatus" on any further School Actions now, would send the public an important and
reassuring message that CPS is working to establish stability and provide continuity for our students. More
changes to Attendance Area Boundaries/Student Re-Assignment, and/or proposals for more Co-Locations will
only contribute to the current climate of instability, and would further disrupt students’ education. We submit
the following additional rationales for your consideration:
Co-Locations
Co-Locations are complicated and costly. While CPS may hope to make more “efficient” use of available facility
capacity, the district will incur costs to open new Charters in traditional neighborhood public schools. If a CoLocation involves relocating an existing school (charter or non-charter) to a shared facility, CPS will incur
moving costs, and very likely capital costs to reconfigure the host school to accommodate the school moving
into that facility. If a Co-Location results in the closure of a building, CPS will incur the costs of emptying the
facility, and have to pay to secure and maintain a vacant building. CPS still has nearly three dozen vacant
buildings that have yet to be re-purposed from the 2013 School Closings and previous closings.
Additionally, too little is known, understood, and disclosed about the student outcomes and costs of current
Co-Locations. The Draft School Action Guidelines do not provide the public with adequate information about
the costs/benefits, sustainability, or management of existing Co-Locations. Similarly the new CPS Leadership
CEFTF School Actions Committee Comments on Draft School Actions Guidelines | 10.22.15
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Chicago Educational Facilities Task Force SCHOOL ACTIONS COMMITTEE
COMMENTS on CHICAGO PUBLIC SCHOOLS’ 2015-2016 DRAFT SCHOOL ACTIONS GUIDELINES
Team likely has not had the time to compile, review, or assess CPS current Board policies and procedures to
manage Co-Locations. To our knowledge, CPS has never conducted or published a formal evaluation of the
problems experienced or the benefits derived from past and current Co-Locations. In contrast, over the five
years since its creation, the Task Force has received numerous public comments raising concerns about
management of Co-Locations, problems with use of shared space, inequities in facilities investments, lack of
planning or transparent procedures to ensure equitable space use in shared buildings, and the lack of effective
processes to resolve conflicts and disputes between schools sharing the same building. The CEFTF School
Actions Committee strongly urges CPS to undertake an open, inclusive evaluation of existing Co-Locations,
before proposing any more of them.
The Draft School Actions Guidelines do not provide specific, quantifiable criteria as to how the CEO would
determine which schools could or should be co-located in the same facility, other than a reference to CPS’
Space Utilization Formula. This formula has been highly controversial and was challenged on numerous
occasions during the 2013 school closings as both inaccurate and inadequate in accounting for the adaptive
and creative use of school and classroom spaces that schools have done. CPS has not revisited or revised its
Space Utilization Guidelines since they were first published in January 2012 to comply with IL P.A. 97-0474.
Since 2012 CPS has had four different CEOs. The School Actions Committee strongly recommends that as part
of the updating of the district’s 10-Year Educational Facilities Master Plan, CPS should revisit and consider
revising its Space Utilization Guidelines. We have identified four schools that Charter applicants have
requested to be co-located: KIPP has requested Co-Locations at Rezin Orr HS, Henry H. Nash Elementary, and
Emmett Louis Till Math & Science Academy, while New Life Academy wants to co-locate a new charter HS at
Hirsch Metropolitan HS. Such requests assume that CPS’ space utilization analyses are accurate, but it is
unclear if this is truly the case, or whether these requested Co-Locations would be sustainable in terms of
shared space utilization. These Charter applicants are asking CPS to make piecemeal decisions to allow such
Co-Locations, even though CPS lacks a coherent and transparent set of policies for planning and managing such
arrangements. IL P.A. 97-0474 was enacted to remedy the district’s past history of piecemeal, non-transparent
decision making, by requiring CPS to undertake comprehensive long-range facilities planning.
Attendance Area Boundary Changes/Student Re-Assignment
CPS’ process and methods for altering attendance area boundaries are not transparent or well-understood by
CPS families and the public. The most recent Board policy was passed a decade ago (Board Report 05-0622PO1, Section 703.2, adopted June 22, 2005). This section of the CPS Policy Manual has not been revisited since
then, or revised to align with the requirements for long-range facility planning in IL P.A. 97-0474.
A careful re-examination of CPS’ approach to altering attendance area boundaries is needed. In a school
district that promotes choice, and is a blend of traditional neighborhood school; Magnet, selective enrollment
and specialty schools; and a rapidly growing number of Charter Schools, rationalizing Student Assignment
policy is a complex challenge, and requires an open process of public engagement. The much-needed review of
this area of CPS policy should also be informed by careful examination of best practices in use by other public
school districts.
Proposing changes now to Attendance Area Boundaries (for the 2016-2017 School Year) will only add to the
uncertainty and stresses which CPS families, students and schools already face. For years, CPS families have
repeatedly testified to various Boards of Education and the CEFTF that the school choice system is confusing
and they struggle to access it. There are numerous barriers facing parents/guardians to utilize CPS’ web-based
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Chicago Educational Facilities Task Force SCHOOL ACTIONS COMMITTEE
COMMENTS on CHICAGO PUBLIC SCHOOLS’ 2015-2016 DRAFT SCHOOL ACTIONS GUIDELINES
School Options applications, public notices, and other tools. Many parents may not even be aware of what
their school’s current attendance boundaries are, or when and how they have been altered in recent years.
While CPS offers an online "School Locator" app that displays current boundaries, the district must be mindful
that routine access to computers and the Internet is not readily available to approximately 50% of CPS families.
In short, the public and CPS families have not been engaged in developing attendance area boundaries. Public
hearings, when held, have been poorly advertised and sparsely attended. There is a lack of awareness on the
part of the public about what CPS Student Assignment policies currently are; and how students, parents, and
educators can add their voices to the decision making process. In contrast, several of CPS’ Community Action
Councils (CACs) have proposed that CPS should have a clear and transparent approach to Student Assignment
that supports the vertical integration and coordination of elementary “feeder” schools to middle schools and
high schools. While determining Student Assignment and Attendance Area Boundary policies is complex, these
decisions have lasting and far-reaching ramifications for neighborhoods and the district system-wide, and
impact future enrollment projections and long-term facility planning. Therefore the CEFTF School Actions
Committee strongly urges the CEO to undertake a careful review of CPS’ current policy, and study best
practices alternatives before proposing any more Attendance Boundary Changes.
Summary: All of the "School Actions” defined in the 2011 state law have costs associated with them, and have
important consequences for students, schools, and communities, and for the future development of the school
district as a whole. They should not be undertaken without further deliberation, expanded public input, and
careful study of "best practices" used by other school districts, to ensure transparency, a broad understanding
by the public, and public acceptance of CPS’ policies. Instead of proposing more School Actions now, CPS
would help students greatly by providing stability and continuity. CPS should fully evaluate the costs and
benefits and student impacts of recent and future School Actions first. CPS has a great opportunity to shift
public attention and its staff’s energies to working with all stakeholders to update the CPS EFMP through a
holistic, inclusive and comprehensive planning process. To advance this work, the CEFTF School Actions
Committee is submitting two examples from other major urban school districts, that demonstrate model
policies that can result in improved, more comprehensive and equitable facilities plans:
1) The Final Report of the DC Public Schools about their 10-month planning and public engagement process,
which led to policy reforms for modernizing and rationalizing DCPS’ Student Assignment Policies. This
Report is based on best practices for public engagement, as well as best practices in weighing the
importance and ramifications of Student Assignment for achieving the school district’s educational goals in
an equitable manner.
2) The New York City Dept. of Education Chancellor’s “Regulation A-190” (and Attachments) for the planning,
approval, and implementation of “Significant Changes in School Utilization and Procedures for the
Management of School Buildings Housing More Than One School.” This Regulation requires highly detailed
“Building Utilization Plans” for Co-Locations, safeguards to ensure equitable and educationally sound use
of shared facilities, and clear policies for local management and governance of them.
The Illinois General Assembly charged the CEFTF with researching best practices in educational facilities
management, ensuring broad public input into CPS’ facilities-related decision making, and monitoring CPS’
implementation of the requirements of IL P.A. 97-0474. The School Actions Committee is carrying out these
mandates by urging the school district to embrace a “hiatus” from taking School Actions until such time as the
district carries out an expanded and comprehensive public engagement process to update the EFMP. The
School Actions Committee members look forward to working collaboratively with CPS and other stakeholders
on these important issues.
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