Stopping Christie's Corporate Feeding Frenzy in Camden

A former NJ DOE employee continues to send us news of from his/her former workplace, where incompetent and corrupt corporate toadies now pretend to do the work once done by educators and administrators concerned with the welfare of children and their education.   To demonstrate the point, see what is happening in Camden and other New Jersey areas blighted by poverty.

If it were not for organizations like the Education Law Center in Newark, the corporate raiders running the DOE would have already turned over urban public education in New Jersey to the corporate foundations and hedge fund managers to feed upon, as they use their unmonitored charter schools to miseducate, to culturally sterilize, and to behaviorally neuter the children of the poor.

Below is the Camden story from the Courier-Post Online, and below that is David Sciarra's letter referenced in the piece:

The Education Law Center is questioning a request for proposal made under the Urban Hope Act, and approved by the school board earlier this month.

The ELC, which advocates for poor urban districts, including Camden, called the district’s proposal, seeking plans for four Renaissance charter schools “premature” because state regulations for the schools are not yet complete, according to a letter written by ELC Executive Director David Sciarra.

Also, the failure of the RFP to adequately solicit the public input and comment “is a glaring omission, and the schedule should be revisited to provide explicit times and locations at which public input can be solicited and considered,” his letter concluded.

Lanning Square School activist Mo’Neke Ragsdale read portions of the ELC’s letter to the school board Tuesday night and promised to provide full copies.

The Department of Eduation responded by saying, “We have provided technical guidance to Camden as they developed their RFP. As we pursue regulations that will be in place prior to our approval of any projects, the Camden RFP also allows the district to request additional information from applicants to conform with the new regulations, if needed.”

The main points that are unaddressed by either the DOE or the district, according to ELC’s review, are:

• Whether students in designated “attendance areas” would be eligible for automatic enrollment in a school built on land conveyed by the School Development Authority, or SDA, and/or Camden to a nonprofit entity, or whether those students would be given only an enrollment preference.

• Whether Camden is prohibited from conveying district-owned land for a Renaissance project without first determining that the tract in question is “no longer desirable or necessary for school purposes.”

• A significant unanswered question is whether the SDA can convey any site in which it has expended public funds for site remediation, site development and design, all of which under the Hope Act must be undertaken by at the “sole” expense of the non-profit entity.

• The RFP does not specify any time, place or mechanism through which public input and comments, which are required, can be heard and the expedited schedule does not provide enough time for the notice of a public hearing.

Also not spelled out, according to the ELC are: site lease or sale information, financing details, details about what defines an attendance area, financial assurances from the proposed operator, various attendance eligibility issues, teacher and staff recruitment and retention, plans for meeting proficiency goals and plans for parental and community involvement.

Sciarra’s letter closed by saying: “We strongly recommend that Camden withdraw the RFP for further development, and to await regulatory guidance. We are prepared to meet with the board its representatives to discuss these concerns and to assist in revising the RFP to ensure that the interests and needs of Camden public school children are properly addressed in any future Renaissance school proposal.”

The board offered no response to the comments after Ragsdale spoke.

Re: Request for Proposals, Renaissance School Project

Dear Ms. Ragsdale:

I am writing in response to your request for Education Law Center

(“ELC”) to review the Request for Proposals for Renaissance

School Project (“RFP”), dated May 18, 2012, recently made

available by the Camden City Board of Education (“Camden”). As

you know, ELC serves as counsel in the landmark Abbott v. Burke

case and, in that capacity, represents children attending public

schools in Camden. Based on an initial review of the RFP, our

preliminary comments are set forth below.

First and foremost, Section 13 of the Urban Hope Act (UHA)

requires the Commissioner of Education to adopt regulations to

effectuate the purposes of the Act. N.J.S.A.18A:36C-13. We are

unaware as of this date that the Commissioner has issued the

required rules, even in draft or proposal form. As a result, the

RFP is premature and should not have been issued by Camden,

especially since there are a several significant issues that

require State guidance. Some of these issues include whether

students in designated “attendance areas” would be eligible for

automatic enrollment in a Renaissance School built on land

conveyed by the School Development Authority (“SDA”) and/or

Camden to a non-profit entity, or whether those students would be

given only an enrollment “preference.” N.J.S.A. 18A:36C-8. As

you are aware, this is a major area of concern related to the

Lanning Square project if Camden abandons having the NJ School

Development Authority build a new Camden school in order to

facilitate a non-profit Renaissance School project on the site.

Another major issue necessitating regulatory guidance is whether

Camden is prohibited from conveying district-owned land for a

Renaissance School project absent a determination that the tract

in question is “no longer desirable or necessary for school

purposes.” N.J.S.A.18A:36C-12. Further, there remains a

significant question as to whether the SDA can convey any site in

which it has expended public funds for site remediation, site

development and design, all of which under the UHA must be

undertaken by at the “sole” expense of the non-profit entity.

N.J.S.A. 18A:36C-7 and 12.

In addition to these issues, the RFP, as drafted, fails to

address critical elements for any proposal to finance, construct

and operate a Renaissance School project. Some of these

deficiencies include:

1) information and details on the site and whether it will be

acquired or leased, the prospective terms of the lease or sale,

and the parties, including any third parties or governmental

entities to be involved in the transaction;

2) information and details on the proposed financing of school

construction, including the extent to which per pupil revenue

will be needed to support servicing the anticipated construction

debt;

3) identification of the proposed enrollment attendance area, the

student and family demographics of the students to be enrolled in

the proposed area, and an assessment of those particular students

for academic, social and health services, and other needs to be

addressed by the proposed school project;

4) the financial ability of the non-profit to pay for planning,

design, code compliance and other necessary professional

services, since these costs are the “sole” responsibility of the

non-profit entity under the UHA;

5) the manner in which the proposal will address the admission of

students to the Renaissance School, including the prohibition in

the UHA against any discrimination on the basis of intellectual

or athletic ability, measures of achievement or aptitude, status

as a handicapped person, proficiency in the English language, or

any other basis that would be illegal if used by Camden;

6) the manner in which the proposal will ensure automatic

enrollment of all students residing within the designated

attendance area, and the policies and procedures to be employed

in such key areas as special education, school discipline,

alternative education, and student transfers to other schools;

7) if the attendance area will not be subject to automatic

enrollment in that area, the manner in which the students will be

admitted, including any proposed lottery for student selection;

8) a plan for attracting and retaining effective teachers and

other support staff, in light of the prospective academic and

other needs of the prospective student enrollment;

9) the plan for achieving the student proficiency goals

established for renewal in the UHA;

10) the cooperative arrangements, if any, that will be made to

coordinate educational programming, curriculum, assessment,

support services for students with disabilities and other special

needs, and other critical areas with the Camden district and

other Camden public schools; and

11) plans for parental and community involvement in the school.

Finally, the UHA requires that the selection process be subject

to public input and comment. N.J.S.A.18A:36C-4(b)(15). While

the RFP notes this statutory requirement, the timeline provided

in the RFP does not specify any time, place or mechanism through

which public input and comments could be collected or heard.

Furthermore, the expedited schedule does not provide sufficient

time for provision of notice for a public hearing at which public

input and comments could be heard. The failure of the RFP to

make any provision to satisfy the public input and comment

requirements of the UHA is a glaring omission, and the schedule

should be revisited to provide explicit times and locations at

which public input can be solicited and considered.

In light of the absence of State regulations implementing UHA,

and many concerns highlighted above, we strongly recommend that

Camden withdraw the RFP for further development, and to await

regulatory guidance. We are prepared to meet with the Board its

representatives to discuss these concerns and to assist in

revising the RFP to ensure that the interests and needs of Camden

public school children are properly addressed in any future

Renaissance School proposal.

Sincerely,

David G. Sciarra

Executive Director