BILL ANALYSIS                                                                                                                                                                                                    �



                                                                  AB 1032
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          Date of Hearing:   April 17, 2013

                           ASSEMBLY COMMITTEE ON EDUCATION
                                Joan Buchanan, Chair
                    AB 1032 (Gordon) - As Amended:  April 9, 2013
           
          SUBJECT  :   Charter schools:  facilities

           SUMMARY  :  Establishes additional guidelines in a school  
          district's requirement to make school facilities available to  
          charter schools.  Specifically,  this bill : 

          1)Specifies that in exercising its discretion in determining  
            appropriate facilities to offer to eligible charter schools  
            operating within a school district, a school district shall  
            give the same degree of consideration to pupils attending  
            schools operated by the school district as pupils attending  
            charter schools. To ensure that facilities are shared fairly  
            among all public school pupils, including those in charter  
            schools, in allocating reasonably equivalent facilities to  
            charter schools operating within the school district, a school  
            district shall consider the following:

             a)   The impact of the facilities offer on pupils attending  
               schools operated by the school district and the in-district  
               pupils attending, or proposed to attend, the charter  
               school. In considering  this impact, the school district  
               shall do the following:
               i)     Seek to minimize disruption to the educational  
                 program of pupils attending schools operated by the  
                 school district and the in-district students attending,  
                 or proposed to attend, the charter school.
               ii)    Not unnecessarily move pupils attending district  
                 schools from their current schools.

             b)   The useable space at the comparison school sites  
               operated by the school district as well as all useable  
               space at facilities owned or leased by the charter school  
               when considering reasonably equivalent facilities to be  
               allocated to a charter school.  For purposes of determining  
               conditions reasonably equivalent for the charter school's  
               in-district students, useable space shall not include space  
               that cannot be used for educational purposes due to safety  
               concerns, topography, lack of improvement, or other  
               conditions. The school district shall also exclude from its  








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               consideration space that is not used by the school district  
               for instructional purposes and space that is used solely by  
               private organizations to provide services with nonschool  
               district resources.

          2)Specifies that a school district is not required to provide  
            additional facilities to a charter school if the charter  
            school owns or leases facilities for the year for which it  
            seeks allocation of facilities and the owned or leased  
            facilities are able to accommodate in-district students in  
            conditions reasonably equivalent to those in which the  
            in-district students would be accommodated.

          3)Specifies that in evaluating a facilities request or  
            formulating a facilities offer, arithmetical precision is not  
            required.  Instead, the school district shall use reasonable  
            good faith methods to evaluate a facility request or formulate  
            a facilities offer.

          4)Provides that the Legislature finds and declares that this  
            bill does not change the scope or effect of, and furthers the  
            purposes of, the Smaller Classes, Safer Schools, and Financial  
            Accountability Act because it ensures that public school  
            facilities are shared fairly among all public school pupils.

           EXISTING LAW  :

          1)Expresses the intent of the people that public school  
            facilities should be shared fairly among all public school  
            pupils, including those in charter schools.  (Education Code  
            (EC) Section 47614)

          2)Requires each school district to make available, to each  
            charter school operating in the school district, facilities  
            sufficient for the charter school to accommodate all of the  
            charter school's in-district students in conditions reasonably  
            equivalent to those in which the students would be  
            accommodated if they were attending other public schools of  
            the district.  Facilities provided shall be contiguous,  
            furnished, and equipped, and shall remain the property of the  
            school district.  The school district shall make reasonable  
            efforts to provide the charter school with facilities near to  
            where the charter school wishes to locate, and shall not move  
            the charter school unnecessarily.  (EC 47614)









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          3)Specifies that each year each charter school desiring  
            facilities from a school district in which it is operating  
            shall provide the school district with a reasonable projection  
            of the charter school's average daily classroom attendance by  
            in-district students for the following year. The district  
            shall allocate facilities to the charter school for that  
            following year based upon this projection. If the charter  
            school, during that following year, generates less average  
            daily classroom attendance by in-district students than it  
            projected, the charter school shall reimburse the district for  
            the over-allocated space at rates to be set by the State Board  
            of Education (SBE).  (EC 47614)

          4)Provides that facilities requests based upon projections of  
            fewer than 80 units of average daily classroom attendance for  
            the year may be denied by the school district.  (EC 47614)

          5)Defines "operating," to mean either currently providing public  
            education to in-district students, or having identified at  
            least 80 in-district students who are meaningfully interested  
            in enrolling in the charter school for the following year.   
            (EC 47614)

           FISCAL EFFECT  :  Unknown

           COMMENTS  :  In 2000, voters passed Proposition 39, which gave  
          districts the opportunity to seek approval of a local education  
          bond based on a 55% vote rather than a 2/3 vote under specified  
          conditions.  The initiative also enacted provisions in the  
          Education Code to require school districts to make school  
          facilities available to charter schools operating in the  
          district.  Facilities are required to be reasonably equivalent  
          to facilities pupils would receive if the pupils were to attend  
          district schools.  School districts are required to make  
          reasonable efforts to provide the charter school with facilities  
          near where the charter school wishes to be located.  School  
          districts may not move the charter school unnecessarily.  

          The statutory provisions are not detailed, and even with  
          regulations adopted by the State Board of Education (SBE), a  
          number of lawsuits have been filed throughout the state.  This  
          bill is sponsored by the California School Boards Association  
          (CSBA) in an attempt to clarify some of the provisions in  
          statute.  This bill is based on various court decisions in order  
          to create standardized policies throughout the state.  








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          The author states, "Frequently, school districts and charter  
          schools spend large amounts of time and money in legal disputes  
          over the determination of "reasonably equivalent" conditions.   
          Protracted litigation resulting from school facilities disputes  
          does not benefit students in either a charter or district  
          school.  While court cases have attempted to strike a fair  
          balance between the needs of all public school students (whether  
          charter or district), existing law does not provide enough  
          clarity.  Different appellate districts disagree and interpret  
          the law differently.  Explicitly stating that the school  
          district needs to give the same degree of consideration to  
          students attending district operated schools as students  
          attending charter schools (for purposes of determining  
          reasonably equivalent facilities) will provide much needed  
          clarity and reduce the various interpretations of law."

           Process for requesting facilities  .  The provisions enacted by  
          Proposition 39 specify that charter schools interested in  
          seeking district facilities must provide the school district  
          with reasonable projection of the charter school's average daily  
          classroom attendance by in-district students for the following  
          year.  Regulations specify that the request must be made in  
          writing on or prior to November 1 of the preceding year, and  
          among others, the request must include information regarding the  
          district school site and/or general geographical area in which  
          the charter school wishes to locate and information regarding  
          the charter school's educational program relevant to facility  
          needs.    

           Equal considerations  .  The author states that while the statute  
          expresses the intent to ensure that facilities are shared fairly  
          by in-district and charter pupils, the statute directs schools  
          districts not to move the charter school unnecessarily from  
          where it wishes to locate without regard to the impact on  
          district students.  This has resulted in district students being  
          displaced in order to provide charter schools with facilities.   
          For example, last year, Capistrano Unified School District  
          closed an elementary school, displacing over 200 students, in  
          order to provide the schoolsite to a charter school.  In Los  
          Angeles, a charter school sued the district because the district  
          did not allocate space at the charter school's preferred site  
          (Los Angeles Intern. Charter High School v. Los Angeles Unified  
          School District).  In 2012, an appellate court found the  
          following:  "A holding that the District must provide facilities  








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          a charter school requests, on demand and without regard to  
          overcrowding or the impact on other public school students,  
          would tip the balance too far in favor of the charter  
          school?..The District acted well within the bounds of its  
          discretion and in compliance with the writ's directives when it  
          offered LAICHS space . . . to avoid displacing hundreds of other  
          students from their neighborhood schools."  

          This bill specifies that when determining appropriate facilities  
          to offer to charter schools, school districts shall give the  
          same level of considerations to pupils attending district  
          schools and pupils attending charter schools.  This bill also  
          requires school districts, in allocating reasonably equivalent  
          facilities, to seek to minimize disruption of the educational  
          program of pupils attending schools operated by the school  
          district and the in-district students attending, or proposing to  
          attend, the charter school; and not unnecessarily move pupils  
          attending district school from their current schools.  
           
          Reasonably equivalent  .  State regulations specify that the  
          standard for determining whether facilities are sufficient to  
          accommodate charter school students in conditions reasonably  
          equivalent to those received by district pupils is based on a  
          comparison group of district schools with similar grade levels  
          as those offered by the charter school.  The regulations also  
          require a school district to provide a charter school with the  
          same ratio of teaching station (classrooms) to average daily  
          attendance as those provided to district students attending  
          comparison group schools.  The school district shall also  
          allocate specialized classroom space (e.g., science  
          laboratories), and/or provide access to non-teaching station  
          space (e.g., kitchen, multi-purpose room, etc.) commensurate  
          with those provided by the comparison group.

          This bill clarifies that useable space shall not include space  
          that cannot be used for educational purposes due to safety  
          concerns, topography, lack of improvement or other conditions.   
          The bill directs a school district to exclude from its  
          consideration space that is not used by the school district for  
          instructional purposes and space that is used by private  
          organizations to provide services with non-school district  
          resources.  According to the sponsor, "litigation frequently  
          arises regarding the process for allocating space to be counted  
          when evaluating space provided to district students.  For  
          example, if a school district is required to count space that is  








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          not useable as part of the square footage of the site, it must  
          then allocate the same number of square feet to a charter  
          school.  This results in a skewed calculation such that the  
          charter school has greater right to useable space than that  
          afforded district students."

          Excluding space that is not used for "instructional" purposes  
          may be interpreted to exclude non-teaching station space whether  
          or not they are being used.  Non-teaching stations are a  
          required facility component under state regulations.  Staff  
          recommends an amendment to clarify that space that is not used  
          as classrooms, specialized classrooms or non-teaching space  
          shall not be considered.     

          This bill requires a school district to consider the useable  
          space at the comparison school site as well as all useable space  
          at facilities owned or leased by the charter school.  The author  
          and sponsor state that this provision is to address situations  
          where a charter school that has facilities seeks facilities from  
          the district.  In Los Altos, even though the district allowed a  
          charter school to build a multipurpose room on district  
          property, the court concluded in Bullis Charter School v. Los  
          Altos School District (2011) that the district was not allowed  
          to consider the multipurpose room as space provided by the  
          district and was required to provide additional space or access  
          to another multi-purpose room.  The Court of Appeal found that  
          neither the "statute or the regulations address the possibility  
          of such a windfall to a charter school?."  

          This bill specifies that a school district is not required to  
          provide additional facilities to a charter school if the charter  
          school owns or leases facilities for the year for which it seeks  
          allocation of facilities.  The author states that when  
          Proposition 39 was designed, funding was not available for  
          charter school facilities.  Since 2000, the Charter School  
          Facility Grant Program, which provides funds for charter schools  
          located in low-income area to assist in rent and lease payments,  
          and the Charter School Facilities Program under the state  
          education bond program, which provides funds to enable charter  
          schools to construct or modernize charter school facilities,  
          have become available.   

          The bill specifies that arithmetical precision is not required  
          in evaluating a facilities request or formulating a facilities  
          offer.  Instead, the district is required to use reasonable good  








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          faith methods.  Several court cases have concluded that  
          Proposition 39 does not require school districts or charters  
          schools to use fixed, mathematical standards (Sequoia Union High  
          School District v. Aurora Charter High School (2003);  
          Environmental Charter High School v. Centinela Valley Union High  
          School District (2004); Ridgecrest Charter School v. Sierra  
          Sands Unified School District (2005)).  The sponsor cites, as an  
          example, the Environmental Charter High School v. Centinela  
          Valley Union High School District lawsuit where the court  
          recognized that the court's task was not to hold the district's  
          action up to a detailed set of quantitative criteria, but was to  
          "ensure that [the school district] has adequately considered all  
          relevant factors, and has demonstrated a rational connection  
          between those factors, the choice made, and the purposes of the  
          enabling statute."  However, the court in the Bullis Charter  
          School v. Los Altos School District decision supported the use  
          of surveyors, architects, aerial photography, and other  
          professionals based on mathematics, physics and engineering to  
          gather measurements.  The cost for both the charter school and  
          district to hire these specialists were exorbitant.  Moreover,  
          the sponsor states that these "measurements are subject to  
          debate and litigation.  Codifying the precedent that  
          arithmetical precision is not required protects public  
          resources, avoids unnecessary litigation, and furthers the  
          interests of students attending both district operated schools  
          and charter schools."  

          The California Charter Schools Association Advocates opposes the  
          bill and states, "Since 2000, considerable regulatory and case  
          law has grown up around Proposition 39 to provide clear  
          direction to school districts and charter schools about what is  
          a reasonably equivalent facility.  AB 1032 undercuts a  
          substantial amount of current law and perpetuates myths about  
          the impact of charter school facility needs on traditional  
          schools. Unfortunately, AB 1032 reverses the thrust of  
          Proposition 39." 

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          California School Boards Association (sponsor)
          California Association of School Business Officials
          California School Employees Association
          Coalition for Adequate School Housing








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          Riverside County Superintendent of Schools
          Small School Districts' Association

           Opposition 
           
          California Charter Schools Association Advocates
          EdVoice
           
          Analysis Prepared by  :    Sophia Kwong Kim / ED. / (916) 319-2087