May 9, 2005

Dear President O’Neill and Members of the Board of Education:

      On behalf of the MCCPTA Executive Board and the MCCPTA
Delegates, we submit these additional comments on the Committee Working Draft of Policy FAA (revised on April 21, 2005).  We have worked diligently over the past weeks to study the proposed and updated revision to Policy FAA, soliciting input from our membership.  On April 25, the MCCPTA Delegate Assembly, representing more than 40,000 parent
members, unanimously voted as follows:

MCCPTA opposes the Board of Education’s adopting the revised Long Range Educational Facilities Policy (Committee Working Draft).  The proposed new policy significantly reduces participation by the Board of Education, the PTAs, and the public in the facilities planning process.  A policy change of this magnitude should be thoroughly discussed by the whole Board and the public. There is a no compelling need to adopt this policy this spring without any hearing or adequate time for public participation.

MCCPTA acknowledges the effort that went into calling a special meeting of the Board of Education Policy Committee on April 21, 2005.  We appreciate every opportunity to provide the BOE with input from our PTA leadership.  However, participation in the April 21, 2005 meeting was by invitation only.  Parents at the local school level, citizens who have lived through boundary changes or who are looking toward choice plans, members of local homeowners and civic associations were not invited.  Moreover, while MCCPTA made every effort to share the April 21 revisions with its membership, distributing the revision at the April Delegate Assembly and posting the MCPS press release to both the delegate listserve and the MCCPTA electronic Bulletin, there has simply been inadequate time to carefully consider important and necessary revisions. The current Committee Working Draft became available on April 25, 2005 and the comments are due by May 9, 2005.   Many of our local PTAs will not even have had a single meeting between the time the revisions were released and the comment period closes.

MCCPTA is aware that the Board must immediately respond to State law by updating the capacity calculation table  in Policy FAA. The Policy Committee, however, even in the revised April 21, 2005 Working Draft proposes elimination of salient language from Policy FAA concerning community representation and participation. We remain deeply concerned that critical due process protections such as notice and public comment prior to implementing new requirements are still absent from many sections of Policy FAA even after the revisions.  Rescinding the protections provided by the current policy should not be done without sound compelling reason nor without deliberate and open discussion. Our request is that only those revisions that are time critical be made immediately and that the timeline for comment and discussion be extended while the Board offers other opportunities for public input similar to the advisory committee process adopted for reviewing the special education policy and the family and community based partnerships policy.

From our perspective, Policy FAA is an important document that provides critical protections for the community’s ability to participate in facilities-related processes. The committee’s proposed revision goes far beyond addressing the minor technical details required by State law and threatens citizens’ confidence in their ability to be heard. It would go a long way toward our understanding of the Policy Committee’s position if the Committee could provide a sound, comprehensive argument for its proposed revision. We have been told that the revisions must be done and that problems must be fixed. The specific weaknesses in the policy have never been enumerated and the actual problems that exist due to the current policy have never been specified. Delay of the final revisions will allow the Board to facilitate a better understanding of its position. Indeed, some of the proposed revisions seem to run contrary to the spirit of the National School Board Association policies which encourage school boards to maintain significant supervisory Authority over policy. Moreover, the National School Boards Association’s Leadership Insider is replete with references to the best practices of encouraging "broad public involvement in facilities decisions" (May 2004, page 1).  We urge you to ensure that Policy FAA, standing alone, satisfies this goal and we ask that you set the tone by providing greater inclusion at the drafting stage.

As always, MCCPTA stands ready to participate in a process that can lead to the development of a revised policy, which serves the interests of all students by maintaining the Board’s oversight authority and preserving the valued participation of parents, teachers, students and communities.

                        Respectfully submitted,

                        Cindy Kerr,
                        President, MCCPTA