Dear HCPSS Board of Education members,

I respectfully request that you do not approve the draft Policy 6010: School Attendance Areas that Superintendent Martirano has proposed. For the sake of all HCPSS families, it is extremely important to constructively reform this policy and refrain from making any changes that will overcomplicate the school redistricting process and/or unnecessarily broaden the scope of redistricting.

With this in mind, I urge you to make the following changes to Policy 6010 before approving its final new form:

REQUESTED CHANGE: Please remove the line "with the goal of balancing measurable socioeconomic factors across schools" from the proposed new section III. B. 3. b., which reads:

“Socioeconomic composition of each school’s student population using applicable socioeconomic data, with the goal of balancing measurable socioeconomic factors across schools”

JUSTIFICATION: Balancing measurable socioeconomic factors across schools is an impossible goal to accurately gauge and maintain year-over-year, and significantly overcomplicates the redistricting process. Including this as a formal goal of redistricting will lead to thousands more students moved than would otherwise be necessary to re-balance capacity utilization among all schools, as demonstrated by certain polygon moves made during the 2019 redistricting process.

The original language for section III. B. 3. b. only included socioeconomic factors as a consideration under reasonable conditions for specific moves. There is a big difference between considering socioeconomic factors for select specific moves, when reasonable, versus establishing the balancing of socioeconomic factors across all schools as a plan-wide goal.

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REQUESTED CHANGES: For section IV. D (page 7), please restore the language that states that the Area Attendance Committee (AAC) meetings are subject to the Maryland Open Meetings Act (OMA). Please also include clear language that states that AAC meetings should be fully recorded, with transcripts & audio recordings available for public release.

JUSTIFICATION: The proposed change to section IV. D (page 7) that reads “The Superintendent/designee will take summary notes of the AAC meeting(s) and make these summary notes available to the public”.

The proposed changes remove the language from the current Policy 6010 that states “AAC meeting(s) are subject to the Maryland Open Meetings Act (OMA).”

These revisions are a concerning step backwards in transparency and accountability. The original language regarding Area Attendance Committee (AAC) meetings being subject to the Maryland OMA should be restored. This includes where the term “OMA” is crossed out on pages 7, 11, and 14.

Additionally, the limitation to only release summary notes to the public is unnecessarily restrictive. Important nuances to discussions and dissenting opinions of individual committee members are oftentimes sanitized and left out of summary notes.

Full recordings and/or transcripts provide the public with important insight into the decision-making process. AAC meetings should be public and should be recorded, with recordings publicly accessible and should not be restricted by Policy 6010 from being recorded, saved & publicly released.

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REQUESTED CHANGE: Please add language to Policy 6010 that allows students who receive an IEP/504 plan at any point during the academic year that a particular redistricting plan is approved to be exempt from redistricting and be allowed to remain at their current school.

JUSTIFICATION: The application process for a student to receive an IEP or 504 plan is so long that even if a family applies during the first week of school, the plan almost certainly will not be finalized before the Board votes to approve a redistricting plan.

The goal of this redistricting exemption is to provide stability for students who are in need of such extra supports. However, with the current cutoff date set as the day that the Board votes to approve a redistricting plan, this exemption only benefits students who received a plan in previous academic school years and does not help students who are in immediate need and attempting to receive extra supports.

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REQUESTED CHANGE: Please add language to Policy 6010 that states that “balancing capacity utilization across all schools” is the primary goal of redistricting and that sets the prioritization order of all redistricting considerations that are defined in Section “III.B.”.

JUSTIFICATION: In the current version of the Policy, the factors are listed in the following order: 1. Facility Utilization 2. Community Stability 3. Demographic Characteristics of Student Population. There is no clear language on whether the numbered order indicates priority.

A prioritized order needs to be firmed up as clearly as possible. “Facility Utilization” (minimization of overcrowding) must be the primary goal driving every redistricting move. Moves should rarely ever occur between two schools if neither of the schools are over-capacity.

When polygon moves are required to re-balance capacity among certain schools to alleviate severe overcrowding, then community stability & distance from a polygon to its current school & proposed new school should be the next clear prioritization.

Wording should be added to Policy 6010 that emphasizes that whenever possible, polygons that must be redistricted to re-balance capacity should be moved to their next closest school (by driving distance….not as the crow flies), and that polygons should be moved to keep contiguous communities/neighborhoods together (no street-splitting).

Also, the factor "Community Stability" should not just be a consideration that is equal to other factors such as student demographics — it should be set as the clear priority for every polygon move that is require to alleviate overcrowding.

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REQUESTED CHANGE: Please either completely remove Section B. 3. “Demographic Characteristics of Student Population” or add language that emphasizes that student demographic characteristics should only be considered for individual redistricting moves where there are two or more schools capable of receiving students from a particular polygon (for the primary goal of balancing capacity utilization) that are similar in driving/walking distance to the polygon but have differing student demographics.

JUSTIFICATION: As is, including Section B. 3. “Demographic Characteristics of Student Population” as a primary/overarching factor for redistricting overcomplicates the process and leaves the door open for Board members and the Superintendent to create far more disruptive and larger-scale redistricting plans than would otherwise be necessary to balance capacity utilization, all for the sake of attempting to balance student population characteristics that are impossible to consistently gauge or maintain year-to-year, and which redistricting should not be used to balance. These include:

1. “Race/ethnicity, gender, gender identity, socioeconomic status, sexual orientation, language, culture, religion/beliefs, mental and physical ability, disability, age, and national origin” (included in the HCPSS definition of “diversity”)

2. “Academic performance of students in both the sending and receiving schools as measured by current standardized testing results”

3. “The level of English learners as measured by enrollment in the English for Speakers of Other Languages (ESOL) program”

First and foremost, race-based school assignments were determined to violate the Equal Protection Clause of the 14th amendment of the U.S. Constitution by the Supreme Court in 2007 ( "Parents Involved in Community Schools v. Seattle School District No. 1")

Regarding the rest of the characteristics listed in this section, given the turnover of students from year to year, it will be practically impossible to accurately measure these characteristics per polygon, maintain a balance of these characteristics from year-to-year and impartially apply them across all schools.

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Thank you for your consideration of these changes to Policy 6010 and for all that you do for the HCPSS community.

Sincerely,

[INSERT NAME HERE]