Two weeks after the DOE first presented the Community Education Council for District 3 with two proposals for rezoning the Upper West Side, CEC 3 has concluded that both are too flawed to vote on.

Maps of the DOE's two rezoning proposals

In its official response, which CEC 3 released Friday along with responses from individual schools, CEC 3 asks for a new plan based on official school capacity data, a revised conception of school zones, and an expectation of class size reduction. The densely packed response also asks the DOE to consider leasing as a short-term solution to the district’s space needs and emphasizes the unique identities of the district’s special programs, the advantages of grandfathering in any new zones so that siblings are kept together, and the need for a new school building.

An important question, the CEC argues, is whether the time is even right for rezoning, given the DOE’s own self-proclaimed constraints in planning for future space needs. From the response:

You have said that DOE does not plan for children until they register for seats. If the DOE is unable to anticipate how many children will be yielded by new construction, then perhaps this period of massive new construction in our district is NOT the best time to be redrawing zone lines.

The council will address the issue further at its public meeting Wednesday. CEC 3’s entire response is worth a read — it’s a useful summary of many of the issues districts and neighborhoods face when trying to negotiate an overcrowding plan with the DOE. The response is posted in full after the jump.

To: Roser Salavert, Marty Barr, and John White
From: Community Education Council of District 3
Re: CEC response to DOE preliminary proposal for addressing overcrowding on the Upper West Side
Date: October 10, 2008

Dear Roser, Marty and John:
Thank you for the opportunity to comment on the preliminary proposals presented to the District 3 community on September 17, 2008. CEC3 has considered the two proposals and facilitated discussion among schools and community leaders. For a number of reasons, we are not able to vote yes or no on these preliminary proposals in their current form. For example, we have concerns with the numbers used by the DOE to claim that 1,500 seats could be realistically freed up in the district without changing sibling, special education, and continuity policies that allow families who move out of a catchment zone to continue attending school in that zone.

In the spirit of a back-and-forth discussion, we invite the DOE to prepare a second generation proposal that
• Is based on target building utilization goals set forth in the Blue Book
• Uses kindergarten (or K-1) data rather than k-5 data to capture trends (as at PS 87) and more precisely determine how many out of catchment non-sibling seats are expected to be available in coming years at each school.
• Keeps schools at the center of their zones where possible, and tries to zone apartments directly facing a school (as at PS163) to that school.
• Recognizes that PS199 in particular requires an immediate solution for the fall of 2009.
• Considers leasing space as a way of gaining seats in the short term that can be accomplished more quickly than building new schools and with less conflict than moving schools.
• Acknowledges the likely need for new school capacity to be built or leased, and answers specifically why in light of this likely need, no action is being taken on the rare opportunity presented by the Riverside South location currently being offered by the developer Extell (in parcels L, M & N), which will not magically reappear in four or five years if the DOE changes its mind when the new high rises in District 3 are occupied. CEC members would like to be present at discussions between DOE and developers.
• Shows what it would take for the Department of Education to achieve target class size goals of 20 in kindergarten through third grade and 23 in upper elementary grades in District 3.

As part of an effective plan to alleviate district overcrowding, the rezoning tool should be used sparingly, fairly and with precision.
• New zone lines should be used to resolve specific cases of overcrowding, not to reinvent how students are assigned to schools.
• The term “zone utilization rate” is a brand-new term that has no history. There is no consensus that setting a “target zone utilization” of 83% would be a desirable premise for the UWS. Target building utilization rates are a preferable basis for assessing catchment needs as they reflect actual usage by the community.
• We recommend retaining the mechanism currently in place for giving priority to zoned kids, then siblings, then district kids, then out of district, combined with a well-run lottery conducted in the early spring. This system can lead to efficient building use.
• In cases where needs of catchment elementary schools conflict with needs of non-catchment schools and trade-offs are required, priority should be given to the needs of the catchment elementary schools.
• In cases where established and successful programs are in place, (as at PS166) space should be allocated for those programs and this should be built into the zone size.
• New York City’s government failed to plan for school seats to match new construction. We should not exacerbate this failure by favoring new construction over existing housing when drawing new zone lines.
• In order to assess potential impact of any new zoning proposal, the community needs more information about the formulas used by DOE to analyze how many school seats correspond to a given number of housing units, city blocks, or areas proposed for rezoning.
• A logistical point: in future iterations of the proposal could you please number the pages, label streets on maps, and keep zone colors consistent between versions.

You have said that DOE does not plan for children until they register for seats. If the DOE is unable to anticipate how many children will be yielded by new construction, then perhaps this period of massive new construction in our district is NOT the best time to be redrawing zone lines. Whether or not zoning is used as one approach, the CEC sees that school relocations may be necessary as a means of alleviating some of the worst overcrowding, but only as a last resort.

We would like to emphasize some principles that should guide any plan:
• A new school is needed in the southern part of District 3, or will be within the time frame needed to construct a school if one were approved today. Without a new school we (as well as all other community leaders who have studied our situation) do not believe the overcrowding in our district can be properly addressed.
• The District 3 community values its successful tradition of providing a variety of learning environments for our children. The D3 lottery system was developed to permit fair access to these schools and give parents an opportunity to seek a school that matches their children’s learning style. We recommend preserving the lottery system. Movement among catchments is a means of maximizing the quality of education for all our children.
• Keeping siblings together at one school is one of the strongest values expressed by families in our district. We recommend that siblings be grandfathered in during any transitional zoning period.
• Expanding populations of kindergarteners will likely lead to expanding populations of middle schoolers in a few years, and we would like to know how the DOE plans to address that issue.
• Schools at the northern end of our district, which are not being considered under this current proposal, are nevertheless suffering from space pressures due to forced sharing with charter schools. This issue must be addressed before overcrowding in District 3 is resolved.

Attached are the responses to your proposal received from District 3 schools, and some block-by-block commentary on the new zone lines presented in September. We look forward to continuing this conversation.

Sincerely,
The members of CEC3:
Elizabeth Schell
Teresa Arboleda
Terry Gray
Morton Schuster
Jennifer Freeman
Christina Palmer
Olaiya Deen
John Davidge
Erma Jones Mason
Robin Klueber