June 24, 2011 Draft: Seneca Creek Charter School Presentation for the Montgomery County Board of Education:

We would like to congratulate Crossways on receiving recommendation. We believe their application was strong and MCPS was right in approving them. We are of course disappointed in the panel's recommendation to deny SCCS, but it was in reading the explanation of the denial that we were most frustrated, as the points made do not reflect any accurate reading of our application or consideration of our answers. The superintendent's recommendation simply does not hold water. Anyone who reads the Seneca Creek Charter School application available on our website at www.senecacreekcharterschool.org will realize that the reviewers' criticisms are unjustified. We did not have the opportunity to answer all of the questions we were given in the course of our oral presentation to address concerns. We answered all of the questions in writing, but were not permitted to submit most of our written responses. Of course there were lingering questions from reviewers after our oral presentation. It is incredible that we were given questions, not expected to answer them all, ignored by those present, and of course by those absent, and then later criticized for not addressing these concerns. Let's look at these concerns: 1. Well begin with the uncalled-for insult in the first paragraph to a founder with 23 years experience in adult and children's ELL education, whose comment was taken completely out of context. Anyone at that meeting would know that she was referring to her attempt to convince some of the families she works with (teaching adult ESL at Montgomery Works in Germantown) to consider Seneca Creek Charter School. She apparently hasn't had much success so far, which is why she said that perhaps they will try us when we aren't new -- when we've had a couple of years to prove ourselves. This was based on her personal experience and interactions. Please take a look at her responses that she read to the review panel, as well as our ELL plan in the application, to see the depth of ELL expertise that she brings to our founding Board. We are passionate about including ELL students in as much of the school day as possible, Our ELL staffing will be a 0.3 position, supporting all 7 ELL paraeducators, and all 9 SIOP-trained classroom teachers. This is graduate level ELL training. We will be doing minimal "pull-out, " We were never told what ELL staffing was expected of us, or if this was adequate, and we weren't allowed to ask, that was one of the ground rules of the interaction between us and the reviewers. We look forward to a real dialog over the planning year, if there is a deficiency in our proposed solutions. We were also noted deficient for our lack of understanding of SPED populations. No specific concerns are listed. We have a very detailed section on SPED in the application, which we welcome you to judge for yourself. Again, we have answered all the SPED related questions, which are available for your review, but were not available for their review. No questions were asked by the one SPED reviewer that we noticed, so we assumed there were no further concerns. We were even prevented from receiving an answer to a question we had not yet gotten a satisfactory response from (after repeatedly asking our charter liaison) when we finally met the SPED reviewer during the "academics training." This training took place a mere 10 days before we were required to submit our application for review. When, and where direct instruction would be provided and in what subjects. See questions that we weren't able to get to in the presentation, but were answered in writing. The delivery of special education services also was not clear, as the applicants noted that related services would be provided during electives with no acknowledgment of the many logistical or equal access to curriculum issues that would result from this model. See answers - this is a gross misquotation of our application. We addressed this at the meeting, but may not have been heard?

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Further, there was an assumption that ELLs who were not making progress would, as a matter of course, be referred for special education services. See review sheet answers again, this is a gross misquotation of our application, addressed in the meeting. The applicants did not provide an adequate plan for assessments and demonstrated a lack of understanding of the various purposes of assessments, such as formative, summative, and accountability measures to inform instructional planning, to monitor progress, to communicate achievement to students and parents, and to evaluate program effectiveness. Our assessment plan is very detailed. However, we believe these questions resulted from an error, on the part of the charter liaison, in referencing page numbers on the review sheet. The wrong page numbers were referenced for all of the assessments sections, and the reviewer asking these questions must not have seen them. We were not able to get to many of these assessment questions in the oral presentation, but they are included in our written answers, which we were not allowed to submit. Seneca Creek Public Charter Schools plan also would prove daunting for the teaching staff. The teachers would be expected to develop curriculum, instructional resources and plans, and assessments without any clear guidance. This is a misunderstanding and misquotation of our application. Teachers would not be expected to develop all of this without guidance and from scratch, as this implies. They will have extensive support from founders, the principal and the SEER organization. This answer was well-covered in our oral presentation as well as our application, and we can only assume the reviewer was simply not listening or reading - see written answers. The proposal appears to present a series of loosely constructed activities without coherence or connection to content. The majority of the curriculum is not completely detailed yet, but is well underway. We are not an approved school, and our teachers need to undergo SEER training to finalize it. There was an implication in the reviewers' questions that we were expected to supply a complete, aligned curriculum by marking period for every grade level. That was not the expectation delivered to us before the review process. The expectation was to provide examples of how the standards, indicators, and objectives would be addressed in a unit or lesson sequence. We did this to this level of detail for the entire kindergarten year, not just one unit. Above and beyond that, we provided a loosely structured curriculum for the other grades, to be developed in conjunction with MCPS approval and according to a specified timetable. See written answers. There were state-mandated subject areas, with full state curriculum frameworks, such as physical education and health education that were not addressed at all. This is completely false on each curriculum framework, there is a clear "health/P.E." category this is also addressed in one of the few finance questions we were allowed to submit.

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10. The application and later dialogue also included proposals to have parents or paraeducators provide electives to students, which is problematic as it is unclear what training or credentialing would be required. This was not brought up as a concern before now, but we clearly specify that "qualified parents and paraeducators" would teach electives. Let us dialog about this plan. It is a common practice in charter schools to have an elective day like this. 11. The review panel also was not convinced that the applicants presented an educationally sound concept that could be applied across the curriculum in a way that ensured mastery of required clearly delineated objectives. They noted that it was clear how the environmental approach would work in all areas of the science curriculum. However, there was a heavy emphasis on life science. Social studies appeared to be limited to the study of community without historical thinking, political, or economic concepts addressed. It appeared that there was no realistic plan to integrate the many curricular concepts and objectives required by the state of Maryland into a

coherent curriculum. This concern was addressed briefly in our written comments, but as the deficiency was not expressed in detail, we will now address it more fully you only have to look at the 3rd grade curriculum for examples of history, politics and economic concepts: learn international laws about migratory birds; economics; cost of raising cows vs. other foods; investigate how Maryland's natural resources have affected our economy; research historical figures prominent in the advancement of sounds. In 4th grade, American history and Native American history are detailed and covered. In 5th grade, the Constitution, French/Indian war, etc. One has only to look through the extensive curriculum materials we provided to find the social studies sections, vs. the life sciences sections. We have affirmed in the application many times that all the curricular objectives of the state of Maryland will be incorporated. We will have extensive support throughout the EIC certification process. This is a stated goal of SEER to have all of the standards covered we quote Grace Lieberman on this point in the application and in our written responses. 12. The concerns raised by the review panel about the operational capacity of the applicant to create and maintain a safe, functional educational environment were extensive. Throughout the application and presentation, the review panel was concerned about an overall lack of specificity, leadership experience, and organizational capacity. For example, given the location of the site, the transportation plan along with the budget for transportation were inadequate. This question was answered in writing, but not orally. These budget numbers came directly from several e-mail and phone discussions with the Director of Transportation. He confirmed in writing, before application submission, that these numbers were correct. We actually passed on this information to Crossways, so our transportation budget numbers should be similar. 13. The lack of understanding of what is required of a food service plan (i.e., adequate refrigeration), or a maintenance plan was disconcerting. Refrigeration was an issue that came up during the review meeting, and we responded that we would have 5 refrigerators in the main cabin, and one in each cabin. As we were not allowed to ask if this was adequate, we hope to have a real dialog about this detail during the planning year. Kathy Lazor said in writing that, "If the charter school application is approved, the charter school administration will have conversations with DFNS to talk about the meal program." We took this to mean that we would work out small details like this during the planning year. We have answered the rest of the food service plan questions in writing, but did not have time to go into them orally. 14. Having 35 to 50 students housed in residential cabins that are approximately 30 to 40 years old would require a level of upkeep and maintenance that the applicant had not planned for appropriately. Maintenance was never discussed at the review panel meeting, as the facilities representative was absent. We would only have 36 students maximum at one time in each cabin. We have budgeted for what was required of us, and have provided a detailed list of maintenance tasks that we believe we are responsible for, and some that the landlord indicated they would be responsible for. We have shown in a revised budget, submitted to the finance reviewers, that we are flexible enough to put in additional expenditures that MCPS feels it is necessary to show in our budget. We are not sure why MCPS can't trust the maintenance figures from the landlord though. 15. Putting aside the question of whether deploying parent volunteers in such a manner is appropriate, reliance on parents for functions such as crossing guard and teaching is a tenuous proposition without a backup plan if parental volunteerism does not reach anticipated levels. See written answers that we were not able to present orally we have indicated that we would find an alternative crossing guard solution if necessary, but we do not anticipate having a problem with parent volunteerism. This is usually high at charter schools, and is expected, but not required. Teaching is never mentioned as an essential parent function a misquote again.

16. The Wellspring facility itself raised a variety of challenging issues. The primary facilities proposed to house the students classrooms are three cabins. A conference center building also is part of the proposed facility, apparently to function as a multipurpose room. The review panel was concerned because the cabins themselves comprise a number of small rooms, the largest of which is a common room of 240 square feet. This common room is about a quarter of the size of a standard MCPS classroom and would not be able to accommodate a class larger than 12 students at desks. This concern was not raised specifically in the written questions, or in the meeting, as the facilities representative was absent. Our planned expansion of this room to connect it with the kitchen, well detailed in the application, was not taken into account. We will of course be in compliance with all county codes. 17. The remaining rooms are identified as sleeping rooms in the floor plan submitted with the application. These rooms are 120 square feet and 108 square feet and could accommodate only four or five students each. It would be assumed that these small sleeping rooms would be used for small group instruction with certified staff, and if that is the case, the budget would not support the number of teachers required to adequately staff each of these rooms. The facility simply does not provide a sufficient number of classroom-sized rooms for the anticipated enrollment. These rooms are close together, and would function as "centers would in a normal classroom. There would be 2 staff members floating between 4-5 centers. If this is not adequate, there are other solutions that could be explored. Again, this is a new concern, and was not raised due to the absence of the facilities representative. Our plans will comply with county codes. 18. In addition, there was no evidence of planning for facility upgrades converting the cabins from a temporary residential use to full time instructional use. The facilities reviewer must not have read the application or the budget section on upgrading the facility. We have $128,000 budgeted for these upgrades. Again, he was not at the meeting to ask this easily-clarified question. 19. The secluded nature of the site raised concerns about the safety of students during the extensive outdoor instruction time. This is a new concern. As mentioned in the application, at least 2 staff members would be with a group of children during outdoor excursions. 20. The review panel was not comforted by the planned assignment of the groundskeeper as security staff. There is no such plan. We never mentioned this in our application or in the dialog - see our written answers to security questions. 21. In addition, the road leading to the site is a gravel road and access and egress for student transportation purposes is questionable. This is a conference center with access that has been certified by the fire department. The gravel road is straight and wide. If necessary, we would have the money from the state start up grant for any fire/safety road improvements. Again, the facilities reviewer was absent and unable to hear this concern raised and addressed. Facilities are not definite. As we say in the application, we will make the best choice available to us upon approval. Recently, we were approached by the Izaak Walton League, which is actively seeking tenants such as us. We expect to be in a much better position to negotiate real estate agreements upon approval.

The panel expressed a general lack of confidence in the applicants financial and executive management experience or skills and capacity to implement the concept. To question our qualifications and capabilities is not only insulting, after putting together such a detailed and comprehensive plan, but is not consistent with the truth. Carrie Bagwill is the Director of a preschool. Krisna Becker has worked on the Board of this preschool, and has prepared the budget and fiscal policies. She even received a written "job offer" from Marshall Spatz, as a compliment for her work on the Seneca Creek budget. There are experienced managers and educators on our Board, a Senior Human Resource Professional, also the former Vice President of a bank, the Director of Wildlife Diversity for the U.S. Fish and Wildlife, former Director of Project Learning Tree in Nebraska, two small business owners, IT management professionals, LEED certified architecture professionals - please read our resumes. Our qualifications, and our application gave the state no concern when they rigorously reviewed our application and granted us $550,000. All this aside, we are not going to be working at the school. In fact, we were expressly prohibited from applying for jobs with the school, as Board members. We will be employing qualified MCPS staff members, as we mention time and again in the application. The only reason MCPS administrators are not already founding members of this Board is because they were illegally prohibited from being involved, even as advisors. 22. For example, the applicant indicated that the administrative secretary would be accountable for maintaining and developing the financial records and reports as well as providing nursing services. We never indicated this in our application, or in the discussion. 23. The critical function of financial management should not be designated to an administrative secretary. This is a new expectation/concern. We were given the MCPS financial manual (and all operations, governance, and finance training) a mere 3 days before we were required to submit our application (which took over a year to develop) for technical review. If the title of administrative secretary should be promoted to "business manager," we believe we have allocated enough of a salary for this primary financial agent's job. 24. Additionally, having the administrative secretary maintain and develop the financial records does not provide adequate separation of duties, as this person will likely handle cash collected by teachers (for field trips, lost materials, etc.). We address questions on this separation of duties and functions in the application, as well as in our written responses, which we did not get to present orally. As they were finance questions, we were allowed to submit those answers in writing. We have affirmed our commitment to comply with all MCPS Fiscal Responsibility and Control policies. As we state, and as is MCPS policy, the principal is ultimately responsible for overseeing the financial management system. Please recommend an alternative to our plan, and we will be happy to make a change. 25. ...secretary would be expected to maintain the account books and act as school nurse. We make no such claim. There would be a separate position for school nurse, as described in the staffing plan, under contract with MCPS. The Administrative Secretary, as well as the Office Assistant would merely have training as a Health Aide, as an extra person with this training, available during the school day during emergencies. This is a realistic plan for this size school, and has been implemented at my child's current school of a similar size. The contracted nurse would do the official record-keeping, and other medical duties. Again, this is something that could have been clarified, if we had been allowed to dialog or submit answers in writing. It is also detailed in the application. 26. This demonstrated a poor understanding of the many functions the administrative secretary is responsible for, and creates an unrealistic expectation as to the capacity of this one role. The applicant also proposed using a groundskeeper employed by Dayspring Ministry for security and maintenance. This individual, who would not be employed by the charter school, would be expected to provide security on a huge secluded campus, where by design, much of the

instructional time would be spent outdoors. Again, our application does not state that the groundskeeper would perform security duties. See written responses on security issues. 27. The simplicity of the applicants solutions often belied the complexity of the issues presented. Given that much of the instructional time is intended to be spent outdoors, the applicants plan for ensuring access for students with physical limitations and complying with the Americans with Disabilities Act of 1990 requirements was the use of a golf cart. This was a recommendation by MCPS Outdoor Education. We detail many other facilities accommodations that we intend to make to comply with ADA requirements. See facilities appendix H for floor plans. We will of course have to finalize plans with an architect, after a lease is signed. 28. Finally, under the proposal, rent on the site would begin one month prior to the opening of school. This would not be sufficient time to convert a site designed as a residential camp setting into a fully functioning school. We never meant to imply that the renovations would begin only one month before school starts. It clearly states in our timeline that facilities work will be done from September 2011 to July 2012. This is a misunderstanding of our application, and a new concern that was not covered in our meeting due to the facility representative's absence. 29. In addition to the deficiencies and unanswered questions noted above, there were concerns about a wide array of issues including but not limited to: contradictions between employment practices of MCPS and the applicant, capacity to provide professional development, evaluation and supervision in accordance with the professional growth system, These questions were clearly addressed in the meeting, and we have provided our written responses attached. 30. adequately funding transportation for homeless and special education students Again, we used MCPS Transportation Director's figures. He confirmed that these figures were accurate, in writing, prior to application submission. 31. and food handling and sanitation These concerns were addressed in our written responses and in the application, but we did not have time to address them orally during the presentation. Our responses were therefore unseen by the reviewers. We are extremely proud of the application that we have put together, and we are confident that once you read it thoroughly, you will realize (as some of you did in the Global Gardens case) that the superintendent's comments were unjustified, and the result of an extremely unfair and obstructive process. We have many well-documented instances of misdirection, misinformation we received, unwritten expectations and prohibitions placed on us in violation of charter law, and arbitrary hurdles and obstructions to dialog with reviewers. We believe that these reviewers may have given us meaningful technical assistance, if they had the chance. It wasn't until last Friday that we knew who all the reviewers and content experts were, let alone had the opportunity to dialogue with them. Our liaison often did not forward our questions, or answers for review to the right content experts, and we had to end up forwarding them directly at the last minute, adding time pressures to Mr. Spatz that I'm sure he didn't need. It was a monumental undertaking, made practically impossible by the superintendent's process that was adversarial and obstructive from the beginning. The Board now has a chance to correct this process by complying with the State Board's guidelines on a fair charter review process is, allowing for the opportunity for meaningful technical assistance to cure deficiencies. We respectfully request that the Board approve our application on the condition that any concerns still expressed by reviewers, after reading this statement, our written responses, and having a true dialogue with us, would be addressed with recommended changes in the text during contract negotiations.

In our view, it boils down to adding only a few minor details into our contract - perhaps a change in title for our Administrative Secretary, a small revision of the budget and staffing plan to reflect the change in SPED staffing that we had allocated to the wrong SPED category, and some further detail addressing our kitchen and meal facilities. This should have been allowed to happen already, but can certainly happen quickly and within the 30 day contract negotiation period. Do we really need to wait a year, as Crossways has, to reapply with these few changes?