Suzanne Wells Testimony – DC Council – Comprehensive Plan Amendment Act of 2020

Committee of the Whole

Bill 23-736

Comprehensive Plan Amendment Act of 2020

November 13, 2020

            My name is Suzanne Wells.  I am the president of the Ward 6 Public Schools Parent Organization.  Our organization is a member of the Coalition for DC Public Schools and Communities.  Thank you for the opportunity to testify today on the District of Columbia’s Comprehensive Plan Amendment Act of 2020.  My testimony is focused on the Educational Facilities Element.  I offer five suggestions for how the draft can and should be improved. 

            First, the proposed Education Facilities Element makes random mentions of the role high quality, matter-of-right schools in every community play in attracting and retaining families with children in the city.  It is important for the Council to explicitly state at the beginning of the Educational Facilities Element the City’s responsibility to provide high-quality, matter-of-right neighborhood schools and feeder systems in all eight wards.  The Comprehensive Plan should also call for city-wide student assignment policies that promote racial and socioeconomic diversity in our matter-of-right schools.

            Second, if the Council is interested in being fiscally responsible, it should be very concerned about the sections of the proposed Educational Facilities Element that suggest  investing in new school capacity. In school year 2017/2018, the city had approximately 21,000 empty seats across DCPS and the charter sector.  Since 2018, DCPS has opened one new selective high school, and expanded one selective high school.  In the past two years, the Public Charter School Board (PCSB) has opened six new elementary, middle and high schools, and expanded existing charter schools.  Having this much excess educational facilities capacity is expensive.  It results in spreading our education dollars thinly across many schools, and often prevents the city from investing in the types of programming students deserve.  Our city needs to be much more intentional about making school opening decisions based on projected student enrollment.  The Educational Facilities Element should underscore the need for such planning ,and certainly should not broadly encourage additional capacity.

            Third, while the District is to be commended for its commitment to DCPS school modernizations, there are three changes that could strengthen the proposed plan relating to the modernizations.  First, any further school modernizations should set a target for net zero energy use.  Second, there need to be more resources devoted to maintaining the schools that are modernized to protect the investments the city has made in these buildings.  And, third, there should be a date certain to complete full school modernizations for all our schools.  Many of the schools yet to be modernized are east of the river.  Every community deserves a fully modernized school. 

Fourth, Section 1203.3 suggests studying neighborhood impacts when locating DCPS and public charter schools. Studying these impacts is curiously limited to only situations when schools are located in non-school facilities.  We have numerous instances of controversial openings of new schools steps away from existing schools.  I think the intent of studying impacts when locating schools is wise, but this section should be revised to require an educational impact assessment for any new school opening regardless of the type of facility the school is located in.

            Finally, section 1208.15 on the Reuse of DCPS School Surplus Space should be stricken because it encourages co-location of charter schools in under enrolled DCPS school buildings. Co-location was the subject of substantial controversy during recent debates on the 2020 Budget Support Act.  At that time, Councilmembers claimed a co-location amendment did not encourage such co-locations but merely set the terms of them. The Educational Facilities Element explicitly encourages such co-locations.  Locating a charter school in an under enrolled DCPS school building could significantly limit options DCPS has to utilize its facilities, and would work directly against the overarching goal of strengthening the matter-of-right feeder systems around the city.  


Sandra Moscoso Testimony – DC Council – Comprehensive Plan Amendment Act of 2020

Testimony of Sandra Moscoso

Committee of the Whole Hearing on B23-736, Comp Plan
November 12, 2020 @ 10am

Good morning Chairman and Councilmembers. I am Sandra Moscoso, a parent of two students at School Without Walls High School and president of the school’s Home and School Association, I am secretary of the Ward 6 Public Schools Parent Organization, a member of the Ward 2 Education Council, and a former Capitol Hill Montessori at Logan Education Campus and former BASIS DC charter parent. 

I am here to discuss education facilities and express opposition of section 1203.4, which calls for co-location of “public charter schools within significantly underused DCPS facilities.” 

The Comprehensive Plan is based on the Deputy Mayor for Education’s 2018 Master Facility Plan (MFP), which in turn is based on recommendations from the DME’s 2018 study. 

However, not the DME study, nor the MFP are supported by any kind of comprehensive education plan inclusive of DCPS and charter sectors. While we can predict needs for seats via population projections, without a strategy or coordination about how to fill those needs, any facilities planning is nonsensical and reactive – just like the proposed co-location. 

I urge Council to insist that the DME work with DCPS and the DC Public Charter School Board on a Comprehensive education plan and only after that is in place, address the role of facilities in supporting citywide education objectives.

As stated in section 1200.24, the Comp Plan should ensure “that investments in schools promote equity and excellence, serve the needs of all students, and provide access to educational skills and development opportunities across all eight wards through matter-of-right neighborhood schools and Districtwide public schools.” 

Vulnerable schools should be adequately funded, so they can support and grow their existing communities and programming. 

These schools should not be asked to bear the burden of lack of planning by our city.

And on a personal note, my children were enrolled in a co-located school for 5 years. I can confidently share that co-location introduced difficulties around design and scheduling of shared spaces, in particular when pedagogy was not aligned across programs. It’s not worth it. Please strike section 1203.4.

A second concern I would like to raise with the Comp Plan is the risk of loss of access to green space by DC Public Schools students under section 805.12, which ”Encourages shared-use agreements for green spaces owned by District government and DCPS.” 

We all saw how this played out last year with Jelleff field, where a private school who can afford to pay, received years of priority access to a public space during peak after school hours. 

This also happened when Ellington Field was moved out of DCPS’ control to be managed by DPR, introducing shared use agreements and creating a situation where public school students risk competing with private entities over the use of public school space. It is worth noting that DC charter outdoor spaces are not subject to these “shared-use” agreements. 

Please strike section 805.12.

Thank you for your time. 


Matt Frumin Testimony – DC Council – Comprehensive Plan Amendment Act of 2020

Testimony of Matthew Frumin on the

Comprehensive Plan Education Facilities Element

Thank you for this opportunity to testify on this important subject.

My focus today is not on the land use issues will be the focus of much of the testimony, but on the Education Facilities Element that is intended to offer a vision for the education infrastructure in our city.  Settling a clear vision is critical to our success in this all important area on which so much of the city’s growth and future depend. 

There is much to commend in the proposed Education Facilities Element, but also important things that can and should be fixed by the Council in its review process so that as enacted it: 

  • Unequivocally establishes that the key priority in the next decade is to ensure an excellent matter-of-right path from PK through high school in every community.  Achieving that goal lay at the heart of ensuring equity and fairness and supporting the long-term growth of the city.  The goal is almost universally endorsed, but rarely followed through on.  The current draft endorses the goal, but then, as is all too common, significantly undermines it with specific proposed policies. 
  • Calls for rational correlation of the addition of new school capacity and location of such capacity to accommodate realistic expectations of need, recognizing that achieving rationality will require coordinated planning between the sectors.  The current draft implies a significant need for new capacity based on projected enrollments based on estimates formulated years ago.  Even before COVID, the actual increases in enrollment lagged the projections. Meanwhile, in many parts of the city, we already have significant overcapacity.  That excess capacity drives up costs and dilutes the dollars available to directly serve students sending them to administrators and building owners.  Fiscal responsibility requires a rational approach to new school capacity that has been sorely lacking.  
  • Rejects the encouragement of co-location of charter schools inside DCPS buildings.  Such an approach would make a mockery of the core goal of delivering an excellent matter-of-right system in every community and as has been seen in many jurisdictions invites operational challenges and with dual administrations in one building maximizes administrative cost as opposed to investing in direct service to students.  The suggestion in the draft to encourage such co-locations is drawn from the proposed 2018 Master Facilities Plan that the Council declined to embrace.  The Council should not embrace it here through the back door. 
  • Reflects the expectation that the city will significantly invest in its low enrolled matter-of-right schools including through completing the full modernization of all DCPS schools by a date certain (the vast majority of which that remain to be completed and are not yet slated for full modernization are east of the river) in an effort to attract students, achieve long-term economies of scale. Invest in the schools we have before further feeding excess capacity.

For years, even as there have been loud calls and strong support to ensure great matter-of-right schools offering families predictability from PK through high school n every community in the city so that families need not be at the mercy of a lottery, every community enjoys the social capital of great schools and District taxpayers are not burdened with per student costs significantly inflated by excess capacity, we have effectively drifted without a vision, some times wrongly believing our power to shape this critical local service was more limited than it actually is. 

The Comp Plan Education Facilities Element offers an opportunity to stake out a sensible vision. The Council should work with the draft proposed by the Office of Planning, making relatively modest revisions, to create such a vision and establish a broad roadmap for success in this all important area on which so much of the city’s growth and future will turn. 

We stand ready to support you in that effort and would happily share specific, redlined proposed revisions to the current draft. 

Thank you for your time and attention to this matter. 


Cathy Reilly Testimony – DC Council – Comprehensive Plan Amendment Act of 2020

Testimony on the Comprehensive Plan Amendment Act of 2020 – November 13, 2020

My name is Cathy Reilly, the executive director of the Senior High Alliance of Parents, Principals and Educators, a member of C4DC. I am also a part of the Ward 4 Ed Alliance. Thank you for this opportunity to testify on the District’s Comprehensive Plan Amendment Act of 2020, Educational Facilities Plan Amendment. 

DCPS by right public schools offer environmental and other social benefits for green space, storm water management, recreation, social cohesion, and even political franchise.  This comp plan can acknowledge that publicly owned, governed and managed properties bring the full education, social, recreation, and environmental benefits to communities.  It can establish that the key priority in the next decade is to ensure an excellent matter-of-right path from PK through high school in every community as it notes in 1200.3.

The plan states in section 1202.1 that DCPS is responsible for educating Washington DC’s children and provides a school of right for every compulsory age child.  The Comp plan can protect and provide a roadmap for DCPS to be able to fulfil that responsibility. 

In order to Strongly support the goal of making neighborhood schools an appealing school of choice, where students’ academic and personal achievements are nurtured, so that children do not have to travel long distances across the District “ as noted in 1204.10: 

The plan:

  • Should recommend maintaining public inventory with shorter leases in order to retain the ability to expand if necessary to fulfill the DCPS core responsibility.  DCPS has transferred 39 buildings to private ownership or long term rental agreements with charter schools. There is excess capacity of at least 22,000 seats across both sectors.  The City can no longer afford to expand specialty and charter enrollments creating greater inefficiency in its land use and in budget priorities. We can prioritize providing program and fill our existing seats.  (omit 1208.15)
  • Should limit co-location to within a sector. The recommendation for charter schools to co-locate in DCPS buildings essentially caps and limits DCPS enrollment making it more difficult to meet its responsibility .  (amend 1203.4, 1203.9)
  • Should prioritize and protect the green space, playgrounds and athletic facilities our publicly owned schools have for posterity. (additional language)
  • Should complete the modernization of DCPS schools as part of the city’s infrastructure by a date certain.  (additional language in 1204.2)

Much of the data and information are out of date and the Council will need to figure out how to address this. A major inaccuracy is that the DME did not do an educational facilities master plan–just study–and the “plan elements” of the study were rejected by the Council. The repeated praise for and inclusion of this 2018MFP plan should be reconsidered and amended or omitted. 

Thank you and I look forward to working with you on this going forward.