to the Contracts for Excellence (C4E) law, the DOE is supposed to be reducing class
size in all grades, and in the fall of 2007, submitted a plan to do so in along
with annual targets and five year goals.
Yet class sizes have risen every year since then. The DOE finally released its latest proposed C4E plan
for the current (2012-2013) school year on Feb. 18 for public comment, long
after most of the C4E funding has been spent.
The deadline for public comment is March 18; please send your comments
to the DOE by emailing email@example.com
; please copy Commissioner King at firstname.lastname@example.org
The DOE has
failed NYC children in many ways but in no way more disappointing than in its failure to live up to its legal
and ethical commitments to our children to reduce class size. See my 20 questions sent to DOE below.
From: Leonie Haimson [mailto:email@example.com]
Sent: Monday, February 25, 2013 4:21 PM
Subject: twenty C4E questions
1. Why do you not present any data on class size in your proposed
citywide plan, your failure to meet class size reduction targets in the
past, or any information about your goals for class size moving forward?
2. Why is there no mention on the C4E webpage about the provision in
the state law that obligates NYC to have a plan to reduce class sizes in all
3. What happened to last year’s class size reduction
proposal? Was it approved by the state and if so, where is it
posted? There is no approved C4E plan posted on your website since 2009-2010.
4. What does this
statement mean: “Due to major fiscal changes and challenges since the
induction of C4E, NYCDOE and SED are having ongoing communication about
NYCDOE’s class size requirements.” What does the state want you to
accomplish in the area of class size, and if so, what is the problem?
5. Why is there is NO deadline for public comment noted either on the
or on the public
comment page. Nor is the deadline mentioned on any of the individual
documents in English and foreign languages linked to on that page. How do
you expect the public to know about the deadline if it is not mentioned on
6. Of the list of public hearings at CECs on the public comment
page: seven are missing, and of those listed, eight are scheduled after
the March 18 deadline for public comment has passed. What is the purpose
of a public hearing to give feedback if it occurs after the deadline has
7. 7. Have you made any attempt to alert parents of your C4E proposal
and/or inform them as to how they can comment on it, other than posting these
documents on your website?
8. Why have you not scheduled any borough-wide hearings as
required by the C4E law?
9. Given that it is already the end of February and the funds have
already been allocated and mostly spent, what is the purpose of holding
hearings at all?
10. Can you explain the following statement on your C4E proposal: “Please
note, as indicated in the FY12 SAM, NYSED allowed NYCDOE to take a portion of
the 17.53% reduction from year 1 Maintenance of Effort funds. This leaves $348
million for school allocations and district-wide programs in FY13 and $182
million of year 1 MoE embedded in Fair Student Funding for a FY13 total C4E
amount of $530 million. This presentation represents the $348 million.”
What does this mean, and how exactly are the rest of the C4E funds being spent?
1 11. What is the relationship of the maintenance of efforts funds
referred to above, to the $30 Million in Maintenance of Effort funds listed on p.
10 of your summary?
12. What does maintenance of effort actually mean, given that DOE has
not maintained effort on its own support for staffing, but has cut school
budgets repeatedly over the last five years, leading to sharp increases in
13. Why have you not allocated any “targeted” or district-wide
funds for class size reduction in this or any previous C4E plan, given that
reducing class size is a requirement in the law, the top priority of NYC
parents in the DOE’s learning environment surveys, and the state’s highest
court in the CFE case said that lower class sizes would be necessary to provide
NYC students with their constitutional right to a sound basic education?
14. How do you expect to track whether principals have
used their available C4E funds appropriately, given vague assurances like
“minimize class size growth”?
15. You write: “With the guidance and approval of
the State Education Department, the NYCDOE has remained committed to monitoring
class size through a cross section of schools that represent high class sizes
and low performance.” Which schools are these are why are you
just promising to “monitor” class size? Shouldn’t you be monitoring and
reducing class size in these schools and citywide?
16. Why did the DOE eliminate the Early grade class size
funding program in 2010, despite the promise in your C4E plan to keep it?
17. Why did DOE decide in 2011 to stop capping class
sizes at 28 for grades 1-3?
18. Why did you instruct principals to raise class sizes
to the contractual maximum in general ed and inclusion classes, as part of your
special education initiative? Don’t these students need especially small
classes to be successful?
19. Why has the DOE failed to align the “Blue Book” utilization
formula or its school capital plan to any class size reduction goals, other
than those in K-3 , even though this is required by state law?
20. How will schools ever be able to reduce class
size if DOE insists on co-locating new schools in their buildings, taking up
every available inch of space?