April 2023 ACCS Public Comment - Items 1, 2, and 3

• Commenter’s first and last name: Eric Premack
• Organization affiliation: Charter Schools Development Center

General public comment or agenda item number: 1, 2, and 3

Commissioners and Liaisons:

I am writing with concern regarding agenda Items 1-3, but especially with respect to those schools recommended to be subject to severe funding cuts in Item 2.

We have significant procedural and substantive concerns. In brief these include, but are not limited to the following:

Procedurally:

• We are concerned about the lumping-together of proposed funding cuts for a large number of different schools (17 by our count) on a single agenda item, along with limiting testimony to one minute. Addressing these complex, high-stakes matters in one minute simply is not practical nor reasonable. Schools subject to proposed or potential funding cuts should be allowed reasonable time on the agenda to address the often-complex issues. We believe this is do-able within the larger agenda time frame if handled properly.
• We also fear that many schools were not notified of the proposed cuts. We have spoken with several of the schools recommended to be subject to cuts and all inform us that they received no notification of the proposed funding cuts (all double-checked their incoming email, including “spam” folders and confirmed they received no notice).
• Relatedly, we also are concerned that schools are receiving incomplete or inaccurate information regarding their options, meeting procedure, and other matters.

Substantively:

• The portrayal of the key criteria for determining funding presented in the agenda packet is not complete and/or is inaccurate. It is vitally important that the Commission understands what the law actually provides on point and the larger context and legislative intent, which is not conveyed.
• Most of the schools recommended to be subject to funding cuts actually do meet the intentionally-flexible “mitigation” criteria specified in the controlling statutes and regulations and deserve full funding.
• In several cases, the agenda packet inaccurately describes many schools’ information and/or omits key points that a school submitted, often to their detriment.
• In several cases, the agenda packet dismisses schools’ reasoning out-of-hand, proffering no justification for doing so beyond empty, declaratory assertions.
• This inaccurate and/or incomplete portrayal of the criteria and facts magnifies our concerns about the procedural concerns noted above (e.g., it expands the time schools reasonably need on the agenda because in addition to making their case, many also need extra time to refute inaccurate points in the packet).

I would be happy to address these issues in more detail with anyone concerned.

Sincerely,
-Eric Premack

Eric Premack | Executive Director
Charter Schools Development Center, Inc.
Sharpening public education's cutting edge for over 25 years

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