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Attachment 1
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CHARTER SCHOOL PETITION REVIEW FORM:International Studies Language Academy
CALIFORNIA DEPARTMENT OF EDUCATION
Key Information Regarding International Studies Language Academy
Proposed Grade Span and Build-out Plan
Table 1: 2018–23 Proposed Enrollment
TK–Transitional Kindergarten/K–Kindergarten
NA–Not Applicable. Grade levels not served.
Grade / 2018–19 / 2019–20 / 2020–21 / 2021–22 / 2022–23TK/K / 96 / 96 / 96 / 96 / 96
1 / 96 / 96 / 96 / 96 / 96
2 / 24 / 96 / 96 / 96 / 96
3 / 24 / 36 / 96 / 96 / 96
4 / 24 / 36 / 50 / 96 / 96
5 / 24 / 36 / 50 / 50 / 96
6 / 60 / 72 / 72 / 120 / 120
7 / 90 / 120 / 120 / 180 / 180
8 / NA / 90 / 120 / 120 / 180
9 / NA / NA / NA / NA / NA
10 / NA / NA / NA / NA / NA
11 / NA / NA / NA / NA / NA
12 / NA / NA / NA / NA / NA
Total / 438 / 678 / 796 / 950 / 1056
Proposed Location
International Studies Language Academy (ISLA) proposes to locate in northeast Los Angeles in the greater Glassell Park community. The petitioner proposes to be located on a site near 2727 Crestmoore Place, Los Angeles, CA 90065 in Board District 5 and Local District Central (Attachment 3, pp. 22 and 27).
Brief History
On November 7, 2017, the Los Angeles Unified School District (LAUSD) voted to deny the petition of ISLA by a consent vote. On January 16, 2018, the Los Angeles County Board of Education (LACBOE) voted to deny the petition of ISLA by a vote of four to one.
Lead Petitioner
Guendalina Ajello Mahler, Lead Petitioner
SUMMARY OF REQUIRED CHARTER ELEMENTS PURSUANT TO CALIFORNIA EDUCATION CODE SECTION 47605(b)
*Petition updates needed due to the passage of Assembly Bill 1360 on March 13, 2017.
Charter Requirements Pursuant to CaliforniaEducation Code Section 47605(b) / Meets Requirements
Sound Educational Practice (California Education Code [EC] sections 47605[b] and [b][1]) / No
Ability to Successfully Implement the Intended Program
(EC Section 47605[b][2]) / No
Required Number of Signatures (EC Section 47605[b][3]) / Yes
Affirmation of Specified Conditions (EC sections 47605[b][4] and [d]) / No
Exclusive Public School Employer (EC Section 47605[b][6]) / Yes
- Description of Educational Program (EC Section 47605[b][5][A])
- Measurable Pupil Outcomes (EC Section 47605[b][5][B])
- Method for Measuring Pupil Progress (EC Section 47605[b][5][C])
- Governance Structure (EC Section 47605[b][5][D])
- Employee Qualifications (EC Section 47605[b][5][E])
- Health and Safety Procedures (EC Section 47605[b][5][F])
- Racial and Ethnic Balance (EC Section 47605[b][5][G])
- Admission Requirements (EC Section 47605[b][5][H])
- Annual Independent Financial Audits (EC Section 47605[b][5][I])
- Suspension and Expulsion Procedures (EC Section 47605[b][5][J])
- Retirement Coverage (EC Section 47605[b][5][K])
- Public School Attendance Alternatives (EC Section 47605[b][5][L])
- Post-employment Rights of Employees (EC Section 47605[b][5][M])
- Dispute Resolution Procedures (EC Section 47605[b][5][N])
- Closure Procedures (EC Section 47605[b][5][O])
Standards, Assessments, and Parent Consultation
(EC sections 47605[c][1] and [2]) / Yes
Effect on Authorizer and Financial Projections (EC Section 47605[g]) / No
Teacher Credentialing (EC Section 47605[l]) / No
Transmission of Audit Report (EC Section 47605[m]) / Yes
Goals to Address the Eight State Priorities (EC Section 47605[b][5][A][ii]) / Yes
Transferability of Secondary Courses (EC 47605 [b][5][A][iii]) / NA
REQUIREMENTS FOR STATE BOARD OF EDUCATION-AUTHORIZED CHARTER SCHOOLS
Sound Educational Practice
ECsections 47605(b) and (b)(1)
5 CCRsections 11967.5.1(a) and (b)
Evaluation Criteria
For purposes of EC Section 47605(b), a charter petition shall be “consistent with sound educational practice” if, in the SBE’s judgment, it is likely to be of educational benefit to pupils who attend. A charter school need not be designed or intended to meet the educational needs of every student who might possibly seek to enroll in order for the charter to be granted by the SBE.
For purposes of EC Section 47605(b)(1), a charter petition shall be “an unsound educational program” if it is either of the following:
(1)A program that involves activities that the SBE determines would present the likelihood of physical, educational, or psychological harm to the affected pupils.
(2)A program that the SBE determines not likely to be of educational benefit to the pupils who attend.
The charter petition is not“consistent with sound educational practice.”
Comments
The petition states that the TK/K through grade seven elementary program at ISLA intends to follow the 90/10 two-way dual language immersion model in four languages: English and French, German, Italian, or Spanish.
The petitioner does not present a sound plan for its projected enrollment layout. ISLA projected starting enrollment is 438 in Fiscal Year (FY) 2018–19 to 796 by FY 2020–21, for an increase of over 80 percent over two years (Attachment 4). The described program poses challenges that would be best met through gradual implementation as was seen at Franklin Elementary in GUSD which added one language at a time beginning with Spanish in 2003, German in 2008, Italian in 2009, and French in 2012.
The CDE finds that in year one, ISLA would be offering dual immersion in all four target languages in grades TK/K, grade one and grade seven only, immersion in two languages in grade two through grade five, but no immersion at all in grade six. Grade six is offered acquisition only in four target languages. In year two, ISLA offers immersion in four target languages in TK/K through grade two, immersion in two target languages in grade three through grade six, acquisition in four target languages in grade six, immersion and acquisition in four target languages in grade seven, and immersion only in four target languages in grade eight.
The CDE estimates that to operate the year one program ISLA will need 24 teachers. However, the petition states that in 2018–19, it will need 20 teachers and the projected budget includes only 20 teachers (Attachment 3, p. 46 and Attachment 4, p. 9). Therefore, in year one ISLA understates certificated staffing by four.
In year two, 2019–20 ISLA will need an additional eight teachers, for a total of 36. However, the projected budget only includes 35 teachers (Attachment 4, p. 11). Therefore, in year two ISLA understates certificated staffing by one.
The petitioner’s ability to recruit and hire qualified teachers in four languages prior to the start of the 2017–18 school year is problematic and compromises the educational program. The petitioner states they will explore alternative teacher credentialing such as exchange and sojourn credentials. The complexities of the educational program, beginning with four different languages, makes this educational program highly unlikely to be implemented in a manner which will benefit students.
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Attachment 1
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ISLA Pupil Distribution TK/K through Grade Eight (with 1:22 teacher to pupil ratio)
The CDE created this table to capture the ISLA enrollment plan and target language distribution for year one. All information was taken from tables included in the petition (Attachment 3, pp. 35–37, and p. 47). The following notes pertain to the table below:
- N/A – Program not offered in specified language
- ACQ – Acquisition model instruction
- IMM – Immersion model instruction
- Grade two through grade five will not be offered German and Italian immersion.
- Grade six will not be offered French, German, Italian, or Spanish immersion.
- Grade seven will not be offered French, German, Italian, or Spanish acquisition.
- Grade eight will not be offered acquisition or immersion programs.
- The acquisition program requires pupils to take two language courses in their chosen target language: one course will emphasize grammar, vocabulary, and the written language; and the other will prepare pupils to communicate orally.
Year One Grade Level / French ACQ / French IMM / German ACQ / German IMM / Italian ACQ / Italian IMM / Spanish ACQ / Spanish IMM / Total Pupils / Total Teachers
TK/K (90/10) / N/A / 24 / N/A / 24 / N/A / 24 / N/A / 24 / 96 / 4
1 (90/10/ / N/A / 24 / N/A / 24 / N/A / 24 / N/A / 24 / 96 / 4
2 (80/20) / N/A / 12 / N/A / N/A / N/A / N/A / N/A / 12 / 24 / 2
3 (70/30) / N/A / 12 / N/A / N/A / N/A / N/A / N/A / 12 / 24 / 2
4 (60/40) / N/A / 12 / N/A / N/A / N/A / N/A / N/A / 12 / 24 / 2
5 (50/50) / N/A / 12 / N/A / N/A / N/A / N/A / N/A / 12 / 24 / 2
6 (25/75) / 15 / N/A / 15 / N/A / 15 / N/A / 15 / N/A / 60 / 4
7 (25/75) / N/A / 23 / N/A / 22 / N/A / 22 / N/A / 23 / 90 / 4
8 (25/75) / N/A / N/A / N/A / N/A / N/A / N/A / N/A / N/A / 0 / 0
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Attachment 1
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Ability to Successfully Implement the Intended Program
EC Section 47605(b)(2)
5 CCR Section 11967.5.1(c)
Evaluation Criteria
For purposes of EC Section 47605(b)(2), the SBE shall take the following factors into consideration in determining whether charter petitioners are "demonstrably unlikely to successfully implement the program":
(1)If the petitioners have a past history of involvement in charter schools or other education agencies (public or private), the history is one that the SBE regards as unsuccessful, e.g., the petitioners have been associated with a charter school of which the charter has been revoked or a private school that has ceased operation for reasons within the petitioners’ control.
(2)The petitioners are unfamiliar, in the SBE’s judgment, with the content of the petition or the requirements of law that would apply to the proposed charter school.
(3)The petitioners have presented an unrealistic financial and operational plan for the proposed charter school (as specified).
(4)The petitioners personally lack the necessary background in the following areas critical to the charter school’s success, and the petitioners do not have a plan to secure the services of individuals who have the necessary background in curriculum, instruction, assessment, and finance and business management.
The petitioners are not able to successfully implement the intended program.
Comments
The ISLA petitioners are not able to successfullyimplement the intended program due to an unrealistic financial and operational plan including aggressive enrollment assumptions, ability to recruit qualified teachers for the two-way dual immersion program in four different languages, and the ability to secure a facility.
Fiscal Analysis
The CDE reviewed the ISLA projected budget and multi-year financial plan and concludes that the multi-year financial plan is not fiscally viable due to negative ending fund balances of $589,769; $1,035,813; and $1,539,012 with no reserve for FY 2018–19 to 2020–21, respectively, due to the number of teachers needed to implement the educational program.
ISLA projected the rental expenditure to be 18 percent of state revenue. The rental expenditure appears to be understated by $64,750 in FY 2018–19, however, ISLA does not include the feasibility of the lease expenditures.
Additionally, the ISLA petitioner does not describe the type of facility needed to operate the size and scope of projected enrollment and the education program proposed in the charter, and does not currently have an intent to lease or a lease agreement for a facility. ISLA did not apply for Proposition 39 facilities.
The ISLA multi-year projected budget includes the following projected pupil enrollment (Attachment 4 and Attachment 3, pp. 28–29):
- 438 TK/K through grade seven in 2018–19
- 678 TK/K through grade eight in 2019–2020
- 796 TK/K through grade eight in 2020–21
- 950 TK/K through grade eight in 2021–22
- 1,056 TK/K through grade eight in 2022–23
However, using comparable enrollment data of surrounding LAUSD schools (Attachment 2, p. 1), all of which have been in operation for a minimum of eight years, the CDE finds that ISLA’senrollment projections are aggressive in comparison to the schools where pupils would otherwise be required to attend. The CDE finds that ISLA’s aggressive enrollment assumptions, if not met each year,could threaten the fiscal viability of the charter.
Revenue
The ISLA multi-year projected budget includes start-up loans totaling $525,000 and a Public Charter Schools Grant Program (PCSGP) funding of $375,000. As neither are guaranteed funding, the CDE excludes them from the budget analysis.
Required Number of Signatures
EC Section 47605(b)(3)
5 CCR Section 11967.5.1(d)
Evaluation Criteria
For purposes of EC Section 47605(b)(3), a charter petition that “does not contain the number of signatures required by [law]” …, shall be a petition that did not contain the requisite number of signatures at the time of its submission …
The petition doescontain the required number of signatures at the time of its submission.
Comments
The ISLA petition contains the required number of signatures at the time of its submission.
Affirmation of Specified Conditions
ECsections 47605(b)(4) and (d)
5 CCR Section 11967.5.1(e)
Evaluation Criteria
For purposes of EC Section 47605(b)(4), a charter petition that "does not contain an affirmation of each of the conditions described in (EC Section 47605[d])" …, shall be a petition that fails to include a clear, unequivocal affirmation of each such condition. Neither the charter nor any of the supporting documents shall include any evidence that the charter will fail to comply with the conditions described in EC Section 47605(d).
Criteria / Criteria Met(1)[A] charter school shall be nonsectarian in its programs, admission policies, employment practices, and all other operations, shall not charge tuition, and shall not discriminate against a pupil on the basis of disability, gender, gender identity, gender expression, nationality, race or ethnicity, religion, sexual orientation, or any other characteristic that is contained in the definition of hate crimes set forth in Section 422.55 of the California Penal Code. Except as provided in paragraph (2), admission to a charter school shall not be determined according to the place of residence of the pupil, or of his or her parent or guardian, within this state, except that any existing public school converting partially or entirely to a charter school under this part shall adopt and maintain a policy giving admission preference to pupils who reside within the former attendance area of that public school. / No
(2)(A) A charter school shall admit all pupils who wish to attendtheschool.
(B)If the number of pupils who wish to attend the charter schoolexceeds the charter school’s capacity, attendance, except for existing pupils of the charter school, shall be determined by a public random drawing. Preference shall be extended to pupils currently attending the charter school and pupils who reside in the school district except as provided for in Section 47614.5. Preferences, including, but not limited to, siblings of pupils admitted or attending the charter school and children of the charter school’s teachers, staff, and founders identified in the initial charter, may also be permitted by the chartering authority on an individual charter school basis.
(C)In the event of a drawing, the chartering authority shall make reasonable efforts to accommodate the growth of the charter school and, in no event, shall take any action to impede the charter school from expanding enrollment to meet pupil demand. / Yes
(3)If a pupil is expelled or leaves the charter school without graduating or completing the school year for any reason, the charter school shall notify the superintendent of the school district of the pupil’s last known address within 30 days, and shall, upon request, provide that school district with a copy of the cumulative record of the pupil, including a transcript of grades or report card, and health information. This paragraph applies only to pupils subject to compulsory full-time education pursuant to EC Section 48200. / No
The petition does notcontain the required affirmations.
Comments
The ISLA petition does not contain the required affirmations. The application process and admission preferences are in conflict with the required affirmations as well as EC Section 47605(d)(1). The ISLA petitionrequiresparents and guardians who wish to enroll their pupil to complete an application form, which indicates the pupil’s living situation and residency (Attachment 3, p. 208). Additionally, the petitioner did not provide a signed affirmation document (Attachment 3, pp. 10–11).
Exclusive Public School Employer
EC Section 47605(b)(6)
5 CCR Section 11967.5.1(f)(15)
Evaluation Criteria
The declaration of whether or not the district shall be deemed the exclusive public school employer of the employees of the charter school for the purposes of the Educational Employment Relations Act (Chapter 10.7 [commencing with Section 3540] of Division 4 of Title 1 of the California Government Code), as required by EC Section 47605(b)(6), recognizes that the SBE is not an exclusive public school employer and that, therefore, the charter school must be the exclusive public school employer of the employees of the charter school for the purposes of the Educational Employment Relations Act (EERA).
The petition doesinclude the necessary declaration.
Comments
The ISLA petition includes the necessary declaration (Attachment 3, pp. 11 and 259).
THE 15 CHARTER ELEMENTS
1. Description of Educational Program
EC Section 47605(b)(5)(A)
5 CCR Section 11967.5.1(f)(1)
Evaluation Criteria
The description of the educational program …, as required by EC Section 47605(b)(5)(A), at a minimum:
Criteria / Criteria Met(A)Indicates the proposed charter school’s target student population, including, at a minimum, grade levels, approximate numbers of pupils, and specific educational interests, backgrounds, or challenges. / Yes
(B)Specifies a clear, concise school mission statement with which all elements and programs of the school are in alignment and which conveys the petitioners' definition of an "educated person” in the twenty-first century, belief of how learning best occurs, and goals consistent with enabling pupils to become or remain self-motivated, competent, and lifelong learners. / Yes
(C)Includes a framework for instructional design that is aligned with the needs of the pupils that the charter school has identified as its target student population. / Yes
(D)Indicates the basic learning environment or environments (e.g., site-based matriculation, independent study, community-based education, technology-based education). / Yes
(E)Indicates the instructional approach or approaches the charter school will utilize, including, but not limited to, the curriculum and teaching methods (or a process for developing the curriculum and teaching methods) that will enable the school’s pupils to master the content standards for the four core curriculum areas adopted by the SBE pursuant to EC Section 60605 and to achieve the objectives specified in the charter. / Yes
(F)Indicates how the charter school will identify and respond to the needs of pupils who are not achieving at or above expected levels. / Yes
(G)Indicates how the charter school will meet the needs of students with disabilities, English learners, students achieving substantially above or below grade level expectations, and other special student populations. / Yes
(H)Specifies the charter school’s special education plan, including, but not limited to, the means by which the charter school will comply with the provisions of EC Section 47641, the process to be used to identify students who qualify for special education programs and services, how the school will provide or access special education programs and services, the school’s understanding of its responsibilities under law for special education pupils, and how the school intends to meet those responsibilities. / Yes
The petition doesoverall present a reasonably comprehensive description of the educational program.
Comments
The ISLA petitionpresents a reasonably comprehensive description of the educational program.
Educational Program
The petition states that the TK/K through grade seven elementary program at ISLA intends to follow the 90/10 two-way dual language immersion model, providing literacy and academic content to pupils in English and French, German, Italian, or Spanish. In two-way dual language immersion programs, the target language is spoken and pupils are instructed in the target language for a specific percentage of the pupil’s instructional day. In the 90/10 model, pupils in TK/K and grade one spend 90 percent of their day learning in the target language, learning content (i.e. math and social studies) and literacy in that language, and 10 percent of their day learning in English, developing oral academic language. In each grade thereafter, more English is added until the pupils spend half of their day in English and the other half in the target language by about grade five (Attachment 3, pp. 40–41).