RYH Comments on CPS Draft Guidelines for School Actions 2017-18

By law, CPS must publish Draft Guidelines for School Actions every school year by October 1st. Once published, CPS provides a public comment period. This year's comment period ended on October 20 at 5:00pm. At this time, CPS is reviewing the submitted comments. They may or may not revise the published Draft Guidelines. The Final Draft Guidelines will be used to determine school actions. On December 1st, CPS will announce school actions.

The below comments were submitted to CPS by RYH on Friday, October 20, 2017.

There must be a PAUSE in any newly proposed CPS school actions for the 2017-18 school year.

  1. Current school level space utilization data is NOT available to the public. By law, this data is due to the CPS website by December 31st of each year. The data due on December 31, 2016, is not published yet. We believe this is a violation of the law, thus, any newly proposed school actions should not proceed for the 2017-18 school year.

  2. While CPS released a Preliminary Draft Update to the Educational Facilities Master Plan in July 2016, there has been no real effort on the part of CPS to inform the public of its existence and to solicit public comment. This document should be driving school actions planning and decision making. Without public comment and without a revised update, any newly proposed school actions should not proceed for the 2017-18 school year.


Below are our comments on the content of the CPS Draft Guidelines for School Action 2017-18.


The language written into the law must be used throughout the Draft Guidelines (and in any forthcoming transition plans). For example, “welcoming” school should not be used. The legal term is “receiving” school which more accurately depicts the situation.

There is no connection between these Draft Guidelines and the Educational Facilities Master Plan. The 10 Year Master Plan and its future updates should be setting school action criteria.

A real, comprehensive facilities plan with a robust, authentic community engagement process is sorely needed for CPS.


While the Draft Guidelines are supposed to “…be created with the involvement of local school councils, parents, educators, and community organizations…” (I. Preamble) we have yet to see any evidence of any kind of robust process to include local school councils, parents, educators, and community organizations. We have noted this for several years now in submitted comments.


For each of the school action types (II. Criteria, A. Co-location; B. Reassignment Boundary Change; C. Phase-Out; D. Consolidation of Closure), the Draft Guidelines state that the CEO may propose the school action only if “...the school(s) principal, parents or community members have requested...” that particular school action. The use of “or” instead of “and” is problematic. School actions are a serious disruption and should involve the school(s) principal, parents, AND community members. We strongly believe the LSC should be added in as well.  Our suggested change is that the CEO may propose the school action only if “...the school(s) principal, parents, LSC or ALSC, and community members have requested…”

Criteria regarding the sustainability of the school action, criteria that call for a transparent cost-benefit analysis of one type of school action versus another, and criteria that call for analysis of one type of school action versus alternatives such as new construction, need to be included.

In each of the school action criteria, there is a list of “other information” that the CEO may consider in deciding whether to propose a school action. This is too vague to serve as criteria. For example, how is “school leadership” a criterion? What specifically about the school leadership would serve as criteria? And which of the “other information” might be prioritized over another?

Other relevant factors are absent in terms of a co-location school action: the proximity of the current schools to the shared facility, the ease of transportation between the old and new locations, and the compatibility of extra-curricular programming between the schools. These should be criteria for deciding whether to co-locate the schools, but they are not included.

Using narrow metrics for “failing to meet or make reasonable progress toward achievement of the content standards or pupil performance standards identified in the school agreement” (II. Criteria, D. Criteria for Consolidation or Closure, 3b.) as it relates to the criteria for closing a contract school is not comprehensive enough. Closing a school, whatever the type, is a significant destabilization of a community of children and youth with potentially long-lasting effects on educational outcomes. A comprehensive review of the quality of the school should be undertaken, which includes those attending the school and their families, before such a serious action is considered. Every effort should be made to direct resources to schools which have needs, to help improve educational outcomes, before a closing is considered.   Please see our statement submitted 2 years ago in support of Amandla charter school.


More detail is needed to describe the “Process to request proposals” (V. Definitions) which is the process the school(s) principals, parents, LSC, and community members would follow to propose a school action:

  • “Process to request proposals” in not written in the law nor is there a process written in the law. We applaud that school communities can bring forth proposals but the process needs to be codified into law and described in detail in these Draft Guidelines.

  • Where is the transparency to the school community and the general public around what was submitted via the “Process to request proposals” (V. Definitions)?

  • What is the process to vet the proposals submitted via the “Process to request proposals” (V. Definitions)?

  • How is the school community, surrounding neighborhood, and general public involved in the process to review the proposals submitted via the “Process to request proposals” (V. Definitions)?

  • What is the timeline for all of the above bullet points? It seems there would need to be an interim period for all of the above and that it should happen BEFORE December 1.

  • How will CPS provide evidence that an authentic, robust community process occurred where the proposal can be vetted publicly to ensure that it is in the best interest of the entire school community as well as the surrounding neighborhood? We have this concern because of the following recent events:


We are also concerned about using the current School Quality Rating Policy (SQRP) to determine whether one school is a “higher performing school” (V. Definitions) than another. The SQRP has several major flaws. The input statistics are heavily dependent on test scores, 65% for elementary school and more than 30% for high school. And, as research by WBEZ showed in 2014, high school students are primarily sorted by test scores before they enroll; meaning that a large portion of the variance in high school ratings is determined before any student even sets foot in the door as a freshman.

Test scores are primarily a measure of the socio-economic demographic characteristics of a school community. Other factors, included in the policy with the intention of capturing non-test-related success, like attendance and college enrollment and persistence, are also heavily affected by family income. Even the so-called “national growth percentile” statistic calculated using NWEA test scores, a measure created solely for use in the school quality rating policy for CPS elementary schools, is still strongly correlated with the percentage of low-income students at a school.  A statistical analysis of 2016-17 SQRP level ratings for elementary schools and for high schools shows that overall level rating is negatively correlated with a school’s percentage of low-income students; the fewer low-income students at a school, the higher the level rating assigned. (1)

A necessary condition for closure is the existence of a “higher performing” school to move children to, and higher-performing schools will disproportionately be schools with wealthier children. Lower-performing schools will be those with poorer student bodies. Thus, the school action guidelines are biased towards disrupting the education of poorer students via school closures and consolidations by shuttering their home institution and then displacing them.


RYH Comments on the Flawed Space Utilization Formula

The CPS Space Utilization Standards are the sole basis for determining a facility’s enrollment capacity. As Raise Your Hand testified repeatedly during the 2012-13 school year, and over & over since then, the CPS Space Utilization Standards use a flawed formula and are educationally unsound.

The maximum efficient level is equal to 36 students per classroom, a level far beyond the upper limit on recommended class sizes. The formula assumes that all schools have the same ratio of ancillary classrooms to homerooms, regardless of the actual number of rooms used by outside agencies, special education, or other school programs. For example, a school sharing space with Chicago Park District, teaching many special education students, or offering specialized academic programs will appear underutilized under CPS standards, when in fact the school is at capacity. The formula also does not account for the actual size of the classrooms in a building, which often vary by over 400 sq. feet. The problem is that CPS does not survey the actual use of rooms when deciding whether a school is under-used or overcrowded.

It was nice to hear in Summer 2015, from Jimm Dispensa, that there is a process within the school action procedure that involves CPS visiting the school and physically assessing the real school utilization situation. We hope this procedure can be added into the published CPS School Utilization Standards (from 2011) and we still hope CPS will change their flawed formula.

We would like to note that we are especially concerned about the impact to schools with high special education populations that have been rendered invisible under the current space utilization formula.

It is very problematic if consideration of school actions use the current CPS Space Utilization Standards as a baseline. The formula needs to be changed to align with accepted educationally sound best practices on calculations of space utilization in schools. In the proposed Draft Guidelines, a school action can occur if “...the combined projected enrollment is within the facility’s enrollment efficiency range as defined by CPS’s Space Utilization Standards…” This flawed formula for Space Utilization Standards will be used to determine the “enrollment efficiency range” of a school and thus to determine whether that school has room for another school to be co-located in its building, will experience a reassignment boundary change, or whether a school will be consolidated or closed.

As long as criteria and decisions are based on the current Space Utilization formula, CPS is not making sound educational decisions for buildings and the children within.



(1) This is true for bivariate and multivariate regressions, with the intensity of the effect varying in the multivariate regressions depending on the model specification.








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