Comments on CPS Draft Guidelines for School Actions 2016-17 and CPS Draft 10 Year Master Facilities Plan Update

Remarks as prepared for the October 21, 2016 Chicago Educational Facilities Task Force (CEFTF) general meeting and school actions committee meeting, presented by Jennie Biggs on behalf of Raise Your Hand.

Comments on CPS Draft Guidelines for School Actions 2016-17

We applaud that you have added in that school actions can come at the request of “principals, parents, or community members.” We hope that there will be a robust process to ensure that the school community is heard, that their proposal is taken seriously, and that the proposal is vetted to be in the best interest of the entire school community as well as its surrounding neighborhood. Further, there should be a clear procedure for “principals, parents, or community members” to submit their proposals. How were principals, parents or community members supposed to know that “Public comments on the Draft Guidelines may be submitted on-line, via e-mail at and web survey at” (III. Process for commenting on Draft Guidelines, p. 3)?

We are concerned that 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 caution you on 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, C. Criteria for Consolidation or Closure, 3b.) as it relates to the criteria for closing a contract school. Please see our statement submitted last year in support of Amandla charter school:

“While Raise Your Hand has been strongly opposed to charter proliferation during times of massive deficits and chronic underfunding of existing schools, we are deeply committed to advocating for a just and fair school rating policy that takes multiple measures, currently unrecognized by CPS, into school evaluation. We believe that opening and closing schools without firmly adhering to an improved vision of school success beyond test scores and other limited factors, is failed policy. Families across Chicago deserve a more honest picture of what’s happening inside school buildings. Education researchers and professionals have detailed the main measures for school success for decades. In addition, any school rating system should be used to determine what supports and resources schools need, not to make punitive decisions.”

The school actions criteria in the Draft Guidelines for School Actions for the 2016-17 school year are inadequate.

First, 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’d 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.

Second, 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 about the school leadership would matter? And which of the “other information” might be prioritized over another?

Third, 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.

Fourth, there are no criteria regarding the sustainability of the school action or a criteria that calls for a transparent cost-benefit analysis of one type of school action versus another or one type of school action versus alternatives, like new construction.

Fifth, there is no connection between these criteria and the Educational Facilities Master Plan. The 10 Year Master Plan should be setting school action criteria.  

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, this flawed formula for Space Utilization Standards will be used to determine the “ideal” capacity 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 school will be consolidated.

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.

Comments on CPS Draft 10 Year Master Facilities Plan Update

Things to consider: 

  1. 7 new charters are up for a vote at the December BOE meeting.
  2. USDOE gave a grant to IL last year to open 24 new charters in Chicago (and 24 outside of Chicago.)
  3. CPS enrollment decreased by 13,800 students this year.
  4. Between 2013-14, the first school year after the mass school closings, and 2015-2016, the receiving schools lost 8.1% of their enrollment v. a 2.8% drop for other district elementary schools. See table, "Receiving School v. Other Elementary Enrollment Loss" below. Full data available here.
  5. During the 2014-15 school year, CPS charter schools had 12,092 empty seats, 11,062 empty seats if adjusted for missing grades. See tables "Charter Seats Availability" and "Utilization for charters in CPS facilitiesbelow.

The developments and statistics listed above mean it is more vital than ever that CPS has a comprehensive educationally sound plan for facilities planning, as a vital part of quality educational opportunities for all children.

A comprehensive long-term plan (which articulates the role of charters) for the future of public education in Chicago is more necessary than ever.


Will the EFMP Update include the plan for charter expansion/contraction?

Will charter facilities be included in the plan?

Where is the community engagement plan for allowing stakeholders to give feedback, learn about the EFMP, etc.?

Table: Receiving School v. Other Elementary Enrollment Loss





% Change

Receiving Schools





Other Elementary





Table: Charter Seat Availability

Total # of empty seats


Total # adjusted for missing grades