Making a Farce out of ARC, part three: Articles 4, 5 and 6 of KPR's failed policy revision

This post continues the article-by-article analysis of the changes to KPR’s policy on accommodation reviews already underway, as per the draft-in-progress document presented to the Board of Trustees by the Resource Committee in January of 2010. As we go, we are learning how a lack of attention to policy revisions on the part of Trustees allowed KPR administrators to influence a document which would allow them maximum power over school closures, in contravention of the research and direction provided by the Ontario Ministry of Education.

The orientation of the former guidelines toward school closure is made clear in article 4, previously titled “Identification of Schools for Closure” and revised to “Identification of schools for the Accommodation Review Process.” The procedure implied by the earlier policy was one in which a small elementary school would be put under review by Board officials and a decision be made to close it, whereupon the Accommodation Review process would kick in to provide, as the previous policy stated, “input regarding the implications of the proposed school closure.” This was the function of Accommodation Review Committees in the past.

The 2009 Ministry guidelines state clearly that Accommodation Review Committees are meant to actually review a range of possible options for dealing with challenges posed by declining enrolment. This is a different function entirely.

In the old process, a closure was proposed by a Board Superintendent, and an ARC was struck to provide input on the ramifications of that decision. In the new process, an ARC is to be struck to consider at least one possible path suggested by Board officials and to compare it with other options either already on the table or of its own devising. The revised KPR policy simply strikes out the references to “closure,” and changes the ARC’s role from providing “input” to providing “recommendations.”

In article 5, it is unclear why the language provided by the Ministry was not employed. Instead, the guidelines are rephrased in a way that is not strictly sensible but rather quite awkward, referring vaguely to the “outcomes” which are “in keeping with the Board’s mission, vision and values.” It is not stated what the mission, vision and values are, or if they are subject to change over time but must always be the same. This wording change again has nothing to do with the guidelines.

In 5.2.1, the Ministry-specified reference to the Board’s educational and accommodation “objectives” has been changed to “expectations.” Again, this has nothing to do with the guidelines, but has significant implications otherwise. Instead of aiding the Board in reaching their objectives, as the Ministry requires, KPR’s ARCs will “review their expectations” and make their decision according to these expectations. This change in wording reinforces the top-down decision-making style that the Ministry ARC policy was designed to counter.

KPR policy-writers robotically revise their terminology

Also in 5.2.1, the old ARC policy language regarding “weighing the value of the school” by considering the School Valuation Framework has been retained, while the name “Information Profile” has simply been substituted for “Valuation Framework.” The new Ministry guidelines do not use the word “weigh,” and the wide range of kinds of “value” are clearly intended to go beyond mere quantification or weighting. No attempt has been made at KPR to actually rewrite the policy to reflect the intent of the new guidelines, but rather the new terminology robotically substituted. Because the purpose of the previously existing policy was quite different from the intent of the new Ministry guidelines, this is where problems of internal incoherence really begin to show themselves.

5.2.2 states that “all meetings of the committee shall be open to the public.” This makes perfect sense under the old policy, but makes no sense for the revised version being constructed supposedly according to new Ministry guidelines. No other Board has been as sloppy as KPR in retaining this vestige of a previous policy whose intent and function differed significantly from the new Ministry policy. As seen in the recent accommodation review of Peterborough secondary schools and in the previously petitioned decision regarding the closure of Cramahe PS, the stipulation that all meetings be public resulted in a poorly-executed process which satisfied no one.

5.2.4 includes a change, this time apparently actually in response to Ministry guidelines, specifying that the ARC will “submit” its report specifically to the Director of Education rather than to unspecified “senior staff.” The Ministry guidelines use the word “deliver.” The alteration of this one word, which itself has nothing to do with the intent of the guidelines, hints at a tone of authoritarianism. Its implications are greater, however, when the following provisions are taken into account.

Ministry guidelines specify that the ARC, after “delivering” its report to the Director to make public via Board website, is to “present” the report to the Board. KPR alters the Ministry wording to state, strangely, that the ARC will determine who will present the report to the Trustees. This nominally “empowering” language actually opens up the possibility for senior staff to influence ARC members to give up their right to present the report directly to the Board. In the end, ARC Chair Don Blair, a Board Superintendent, made the presentation of the report to the Board, along with Rusty Hick. However, there is no record in the minutes of the final ARC meeting regarding a conscious choice being made for Blair to present the report.

In 5.3, regarding the makeup of the ARC membership, previous language has again been only slightly modified. The new Ministry guidelines call for parents, educators, Board officials and community members. KPR policy calls for the same, but the previous framework calling for the specific Superintendent for the specific school proposed for closure to be a member of the committee has been changed to “senior staff.” A peculiarity arises as there are in the updated KPR policy two provisions for school council representatives, one from the “identified school” and one for each “identified area school.” This makes no sense except when one considers that the earlier wording for the second item was “receiving school,” denoting the school which would be receiving an extra load of students due to the closure of the other. Again, the sloppiness of these revisions suggests that little time was put into considering how the new ARCs were intended by the Ministry to function.

In 5.4, KPR policy specifies that “senior staff responsible for student accommodations will be responsible for facilitating the work of the ARC.” Presumably, this was interpreted by Hick as implying that a senior staff member actually chair the ARC as well as being a member of it. In this regard, it is interesting to note former Minister of Education Dave Cooke’s conclusion after reviewing the closure of King Edward Elementary in Barrie several years ago that Board staff should not be members of the ARC. You can read his report here.

Dave Cooke, former Minister of Education, has some advice for KPR

5.5 holds another crux of the problematic KPR policy. It specifies a maximum of four meetings of the ARC. Item 5.5.1 is key, stating that “the accommodation committee shall meet on a maximum of four occasions for the purpose of seeking community input and feedback for options on accommodating students who may be affected by a school closure or consolidation.” The new wording has merely added the word “consolidation” to “closure,” and substituted “may” for “would.”

This is the most egregious example of the ignorance on the part of the policy-writers of the origin, purpose, intent, and the letter of the new Ministry guidelines and of the role ARCs would play moving forward. The language has not been updated in any significant way from the earlier policy. The idea of having a maximum of four meetings makes no sense whatsoever regarding the new guidelines. The Ministry specifies a minimum of four public meetings of the ARC, devoted to accepting feedback not on “options on accommodating students who may be affected by a school closure” but on the accommodation options themselves, which the ARC is expected to help create.

In the Peterborough secondary school review process, no detailed options were in fact presented for feedback until the third ARC meeting, where only the most basic options were presented (i.e. the five possibilities inherent in a review whose starting point was simply that one school of four should close, or the status quo maintained). The “pros and cons” listed there include comment on nothing but enrolment/capacity ratios. No details of the way each scenario would play out in terms of staffing, financials, boundaries, long-term demographics, community impact, or other factors were given at all. As a result of KPR’s sloppy and contradictory policy writing, at its final meeting the committee had not yet even reached the point at which it was meant to begin its deliberations. For comparison’s sake, have a look at this 34 page report made by an Ottawa-Carleton ARC recently.

5.6 and 5.7  are entirely newly worded articles, the only ones in the document. 5.6 is a lengthy paragraph calling for a consensus model for decision-making. The implication is that discussion should take place co-operatively toward a decision which is acceptable to everyone to some extent, rather than debate taking place toward a vote on the various options presenting themselves. Once again, this is not motivated by the Ministry guidelines, and it is unclear where this idea comes from. Many other Boards allow their ARCs to vote on various options as their process reaches a conclusion.

The old article 7.2 has been entirely struck out. It was the earlier document’s provision for the Director of Education to provide his or her own analysis of and comments on the report to the Board. Taking it out entirely is a puzzling move, as the Ministry guidelines plainly call for Board administration to provide its own analysis of the report. The original article also called for such commentary and analysis to be made public, however, which may have been the motivation for cutting it entirely.

6.2 continues the pattern of simply making minor changes to the earlier language in spite of the fact that the new guidelines call for a quite different process. KPR’s policy continues to be focused on school closures. 6.3 states that “where the Board decides to close the identified schools” the closure will take place by the beginning of the next school year unless the Board decides otherwise. Ministry guidelines, however, state that “if the Board votes to close a school or schools, it must outline clear timelines” around this.

Our analysis is nearly complete. Thanks for hanging in on this journey through the tangled web of KPR policy!

 Fortunately, KPR has saved a treat for we who have made it all the way to the end. Article 6.6 is among the most bizarre in the entire document, and fully reveals the problems with simply making “minor language changes” over the period of a decade as Ontario education policy evolved.

The existing policy allowed for the possibility of a second committee being formed to facilitate the “smooth transition” to the new school configuration – a committee with a makeup of membership similar to the original ARC.

Note that KPR’s policy-writers in January of 2010 simply added in the words “Accommodation Review” prior to “committee,” showing a complete lack of understanding of both the original policy and the revisions. In effect, the policy provides for the Board to strike a second ARC to deal with the decisions made by the first!