PUBLIC ADVOCATE FOR THE CITY OF NEW YORK

Letitia James


1 CENTRE STREET NEW YORK NY 10007 TEL 212 669 7200 FAX 212 669 4701 WWW.PUBADVOCATE.NYC.GOV


July 21, 2014

Deputy Mayor Richard Buery
Deputy Mayor for Strategic Policy Initiatives
City Hall, Office of the Mayor
New York, NY 10007

Dear Deputy Mayor Buery:
As an appointed member of Mayor de Blasios school space working group, I amwriting
to share my policy recommendations for the working group. My office has a deep
interest in the issues that school co-locations create for schools, families, and students. I
am hopeful that the working group will consider these proposed recommendations in our
ongoing effort to address this important issue. I look forward to continuing my work with
you, the working group, and the rest of the administration on finding equitable solutions
for all schools that are or will be co-located.
POLICY RECOMMENDATIONS:
The Blue Book Task Force and School Space Working Group Must Establish
Formal Lines of Communication - The Blue Book working group and the
school space working group must have formal mechanisms in place that allow
these two groups to communicate so each can review and consider the respective
recommendations of the other. Because these working groups have
complementary roles, it would be a lost opportunity if neither group knows or
understands what the other is doing. To date, these two groups have not met.
Provide Capital Funding for UPK and Community Schools - The Mayors two
most significant educational initiatives to date, Universal Pre-K (UPK) and
Community Schools, are to be applauded; however, because of co-locations,
many schools do not have adequate space to provide these important new
programs. The local non-profit Class Size Matters completed a report that found
that elementary school buildings are at a critical level of 97.4 percent mean
target utilizationwith a median utilization of 102 percent. Our schools are
severely overcrowded and these initiatives can only be successful if they are
supported by capital dollars. There is no indication that the Department of
Educations (DOE) $12 billion capital plan for FY20152019 includes any money
to build new space to accommodate these programs. The DOE and the School
PUBLIC ADVOCATE FOR THE CITY OF NEW YORK
Letitia James


1 CENTRE STREET NEW YORK NY 10007 TEL 212 669 7200 FAX 212 669 4701 WWW.PUBADVOCATE.NYC.GOV
Construction Authority should include specific funding for the UPK and
Community Schools initiatives in their 5-year plan and ensure class sizes reflect
New York States Contract for Excellence (C4E) funding that supports class size
reduction.
Space Planning Must Take Into Account New State Law Mandating School
Space for Charter Schools - New State legislation requires that charter schools
must be allowed to co-locate in a traditional public school or DOE must otherwise
find or pay for such space. There are currently 183 charter schools in New York
City, 119 of which are co-located with other schools. Because of the new State
law, the City is required to find or finance space for 22 new charters that have
been approved to open in the next two school years. In addition, the 2010 State
law that governs the number of charter schools in New York City allows for an
additional 52 charter schools, all of which will be entitled to space paid for or
provided by DOE. Further complicating the school space situation, any new or
existing charter school can expand its grade levels through high school, and the
new State law also requires the City to provide or pay for space for these new
grades. School space planning must develop policies and procedures that take into
account this new State legislation moving forward and produce plans that
consider the requirements of this legislation and account for possible out-year
growth.

All Co-Located Schools Must Accept Shared Lunch Periods - One of the
recommendations the school space planning group made to address the lunch
scheduling problem was to have different schools on the same campus eat lunch
at the same time. I support this policy and believe it would alleviate some of the
scheduling problems that cause some children at co-located schools to eat lunch
unacceptably early or late in the school day. For this policy to be effective, all
schools on campus must agree to share lunch periods. It is my understanding that
some charter schools, such as Success Academy, have been reluctant to have
their students interact with other students on campus, especially those attending
traditional public schools. This refusal to work cooperatively exacerbates the
already-contentious relationship between charter and non-charter school students
and parents at co-located schools. If DOE is providing free space to charter
schools, then we must be firm in requiring shared lunch periods to ensure that all
children eat lunch at a reasonable hour and that we improve district and charter
relationships. DOE must make this a policy for all co-located schools or we will
not be successful in addressing this issue or others like it.
PUBLIC ADVOCATE FOR THE CITY OF NEW YORK
Letitia James


1 CENTRE STREET NEW YORK NY 10007 TEL 212 669 7200 FAX 212 669 4701 WWW.PUBADVOCATE.NYC.GOV


Thank you for taking the time to review my policy recommendations. I look forward to
your response.



Sincerely,


Letitia J ames
Public Advocate for the City of New York