The response is unanimous: withhold state funding until DOE comes up with a better proposal!

On August 6, Class Size Matters faxed an open letter to NY State Education Commissioner Mills, with the signatures of over 200 parents, PTA presidents, Community Education Councilmembers, education advocates, and other key leaders, including Robert Jackson, Chair of the NYC Council Education committee and the original CFE plaintiff.

The letter urges the state to reject the city's class size reduction proposal, submitted on July 16 as part of its "Contract for Excellence", and to withhold funding until and unless the city prepares an actual, enforceable five year reduction plan, as mandated by law.

The city is obligated to come up with a five year plan, showing continuous and measurable reductions in class size, to receive the additional funding that will come to our schools as a result of the Campaign for Fiscal Equity (CFE) case, according to the budget passed by the State Legislature last spring.

Earlier, we sent Commissioner Mills a longer letter, explaining in detail why the the city's submission is inadequate. For those who are interested in taking a look at our analysis, it is posted (in Word) here. In brief, the Department of Education's proposal fails to comply with the law for the following reasons:

It does not include even the outlines of a five year class size reduction plan, as required. Even as a one year plan, it lacks sufficient funding, space and direction.

The so-called "Fair student formula" used to allocate dollars deprives resources to reduce class size to half of all schools, including 47% of our failing schools – those that according to law and good policy should be addressed first.

The schools that were selected for “class size coaching” are too few in number, and the process itself of "coaching" will lead to uncertain results.

There is no alignment with the capital plan, as the law mandates -- and thus there is no provision of the additional space that will be necessary.

The class size “targets” mentioned in the document appear to be based on speculation alone, and are so minimal they will be difficult to measure, given the chronic inaccuracy of the city’s class size data. In many grades, the “targets” for class size appear to be higher than would result from enrollment decline alone.

The funds the city wants to spend on its testing initiative, under the heading of additional "time on task" should be disallowed -- as all these new standardized exams will take time away from learning rather than extend it.

Instead of a thoughtful systematic plan, this proposal is fatally flawed -- haphazard, scattershot, and indifferent to the law and the regulations. It is unlikely to lead to a significant reduction in class size in any grade.

We asked that the state require that the city spend at least $100 million next year hiring teachers to reduce class size, targeted first to our failing schools, and immediately prepare a long-term plan, providing sufficient funding and space through a more expansive capital budget, so all students in this city will be able to receive appropriate class sizes within five years.

Since the city revealed its proposal in July, it has met with overwhelming criticism from parents and teachers alike. Here is what Noreen Connell of the Educational Priorities Panel wrote about the response:

Despite the absence of a coherent document and with as little as five days’ notice, close to 900 individuals testified before NYC Department of Education officials, predominantly PTA presidents and other parent leaders. A smaller proportion of those giving oral testimony, but still significant in number, were classroom teachers. Education advocates, elected officials, and civic and union representatives were the balance of participants. ... all substantive public testimony expressed disappointment or anger about the plan’s objectives. Such widespread public rejection calls for the NYS Department of Education to work with city school officials to develop a more acceptable plan.

Her are links to the letters to Mills from Assembly Education Chair Cathy Nolan, Assemblymember James Brennan, City Council Education Chair Robert Jackson, the Campaign for Fiscal Equity ( pdf), Advocates for Children (pdf), the League of Women Voters (pdf), the Women's City Club (pdf), the United Federation of Teachers, and the Educational Priorities Panel -- each asking that funding be withheld until the city comes up with a better proposal.

What will the Commissioner do? Stay tuned.