Pupil Accommodation Reviews

Winter 2018

Consultation on draft revisions to the Pupil Accommodation Review Guideline (PARG):

Summary of Feedback

Introduction

After engaging with school boards, municipalities and community partners in spring 2017, Ontario launched its Plan to Strengthen Rural and Northern Education in June 2017. A central element of this plan includes strengthening the Pupil Accommodation Review Guideline (PARG). Feedback received during the province's spring 2017 engagements suggested that there is a need to strengthen the PARG for all school boards across the province.

First phase of consultation: From October to December 2017, the Ministry of Education gathered feedback on a series of proposed revisions to the PARG from the public, municipalities, and education sector partners. For more information on what we heard in fall 2017, please refer to the consultation feedback summary.

Second phase of consultation: In February 2018, a draft of the revised PARG was released allowing public feedback on proposed revisions to the PARG during February and March 2018.

Consultation Overview

This document provides a summary of feedback received during the second phase of the ministry's consultation, which involved:

  • An online posting of a draft amended PARG on the ministry's website from February 9 to March 23, 2018, for public input. The ministry received a total of 37 responses (25 from the education sector, five from members of the general public, five from advocacy organizations and two from the municipal sector).
  • A Minister's Reference Group meeting in February 2018, which included representatives from the education sector, municipal sector, advocacy groups and students. The group's mandate is to advise the Minister of Education on effective ways to improve co-ordination of community infrastructure planning from a public education perspective.
  • A Technical Working Group meeting in March 2018, which included staff-level representatives from the education and municipal sectors. The group's mandate is to advise ministry's policy staff on effective ways to improve co-ordination of community infrastructure planning from a public education perspective.

Summary of Feedback on Draft Amendments

General Overview:

Overall, feedback showed that there was a high level of support for the draft revised PARG. Responses indicated that the revised PARG is now more inclusive due to proposals for community and economic impact assessments, inclusion of secondary students and Indigenous communities, and a new requirement to notify both municipal elected officials and municipal staff.

1) Draft Amendment: Extended timeframes due to a third public meeting.

Feedback:

  • Longer timelines and more meetings are beneficial as they allow the public more time to learn about the process and understand it.
  • However, longer timelines can also prolong tension in the community for what is already a challenging process at times.
  • Longer timelines may extend the pupil accommodation review (PAR) process over one school year, which complicates  operational planning for boards, strains staffing resources, increases staff workloads and increases the cost of a PAR.
  • There should be more time between the period when the PAR is started and the first public meeting so boards and municipalities have more time to meet and the public has more time to learn about the process.
  • A third public meeting is viable if boards have flexibility to determine the amount of time between meetings. There may not always be enough content for three meetings. In these cases, boards can repeat the content from previous meetings in the third meeting for people who couldn't attend the first two.

2) Draft Amendment: Rural and Northern Education Fund (RNEF) eligible schools are excluded from modified PARs.

Feedback:

  • Modified PARs are beneficial as they can be completed within a school year and allow certainty and continuity for the board and for the community.
  • Modified PARs allow boards to respond to demographic changes quickly and address local needs effectively.

3) Draft Amendment: Add one more public meeting if a new proposed school closure is included in any of the accommodation options presented in the final staff report.

Feedback:

  • New options should not be introduced in the final staff report.
  • The introduction of a new option should not generate an additional meeting, if this option was already introduced earlier on in the process.
  • Extended timeframes make it difficult to complete a PAR within one school year.
  • If a new option surfaces, the Accommodation Review Committee (ARC) should determine the appropriate amount of time needed to consider it. An extra meeting should not be mandated in the PARG.

4) Draft Amendment: Initial Staff Report must include a minimum of three accommodation options (status quo option, recommended option and an alternative)

Feedback:

  • Presenting three options in the initial staff report can help mitigate the perception of PARs having a predetermined result.
  • However, it may not be possible to generate three options for all PARs, especially in smaller boards. The PARG should allow boards to pass a motion to undertake a PAR, even if there are not three options.
  • Status quo should not be considered an option as the need for a PAR indicates that the status quo is not working.
  • Boards should have discretion to decide if an initial report has a recommended option or not for each PAR.
  • Boards should be able to justify why a recommended option is the best one and can use the PAR process to inform the public of the data and rationale that supports it.
  • Instead of presenting a recommended option, boards could present multiple options that they have considered.
  • Board staff may not be fully aware of local issues and the three initial options may not reflect local circumstances. Alternative options could be generated through the PAR process.

5) Draft Amendment: Initial Staff Report must consider impact on student programming

Feedback:

  • The current School Information Profiles (SIP) already requires boards to review impacts on programming options.
  • The PARG should state that student achievement is not defined by comparing EQAO scores and that EQAO scores are not a deciding factor in a PAR.

6) Draft Amendment: Initial Staff Report must consider impact on student well-being

Feedback:

  • There isn't a universal definition of well-being that applies to all boards, as each board has different circumstances.
  • The community could view student well-being differently than the board, even though the board may outline what factors it takes into consideration. This factor is very subjective.
  • Instead of having a prescriptive definition, seek open-ended feedback (i.e. ask students for their responses on well-being and let them voice their concerns).

7) Draft Amendment: Initial Staff Report must consider impact on school board resources

Feedback:

  • An initial staff report template should identify which costs should be included in the analysis (i.e. consider operational savings such as busing/transportation costs).
  • Boards should be able to measure the economic impact of their underutilized space.

8) Draft Amendment: Initial Staff Report must consider impact on the local community

Feedback:

  • Community impact should be analyzed in both the areas that are losing and gaining students due to closures/consolidations.
  • The PARG should define the geographic component, such as which area the community entails and its boundaries.
  • Community impact should only be analyzed for PARs with RNEF eligible schools.
  • Requiring boards to sustain the local economy deviates from their mandate.
  • Community impact should be reviewed at an area-wide level, not at an individual school level. This avoids pitting school communities against each other.

9) Draft Amendment: Initial Staff Report must consider the impact on the local economy if at least one RNEF eligible school is in a PAR

Feedback:

  • Economic impact should be analyzed in both the areas that are losing and gaining students due to closures/consolidations.
  • The Economic Impact Assessment (EIA) should not be used to influence PAR decisions nor should it be the deciding factor in a PAR.
  • The EIA and community impact can both be planning tools to help municipalities and boards see where population is growing/declining, where infrastructure is being built, etc.
  • EIA could also be considered for urban/downtown areas; some urban areas are growing and municipalities are building parks/infrastructure in the core as families are moving there, but boards are closing schools in some urban areas.
  • EIA can be a transition planning tool for other parties as it can enable local actors to plan together for the future.
  • The area for the EIA should extend beyond the school catchment area. For example, if a school closes, how will the whole municipality be affected?
  • A board's key function is to serve the educational community. Requiring them to assess and mitigate the effects the school has on the local economy is outside their mandate.
  • There is concern around how the EIA will be weighed against the other critical factors such as program viability, aging infrastructure and declining enrolment.
  • The EIA requirement could be onerous for smaller or rural boards as many of their schools are RNEF eligible.
  • The EIA should be part of the Community Planning and Partnerships Guideline (CPPG) as a tool that is co-developed by boards and municipalities. The CPPG could define what information needs to be shared before a PAR. There was support for reciprocity in information sharing requirements to improve communication before a PAR and the initial staff report.

10) Draft Amendment: Ministry to develop template for Initial Staff Report

Feedback:

  • There was a strong desire to have the revised PARG, ministry templates and supports be released at the same time as boards, however, trustees cannot draft and approve local PAR policies without seeing the whole package.
  • A standardized template can be useful, but boards must have flexibility to address local needs and circumstances.
  • Draft templates should be released for input before they are implemented as a requirement. Many boards expressed a desire to comment on draft templates before the final versions are released.
  • The template can be used as an executive summary. There could be a section called the "PAR Executive Summary" if its purpose is to guide readers through various sections of an initial staff report.
  • A five-year window is the most accurate for most types of data (economic data, enrolment projections, Facility Condition Index, etc.).
  • Template should include consideration of impact to joint-use schools and Grade 7-12 facilities.

11) Draft Amendment: Include secondary students in the PAR process and include their feedback in the Final Staff Report

Feedback:

  • High level of support for including secondary students in the process and their feedback in the final report. However, boards should have flexibility to determine how to involve students in each case.
  • Feedback from elementary students should also be in the final report.
  • The PARG should mandate an invitation to secondary students to join an Accommodation Review Committee (ARC), but their participation on the ARC is voluntary and optional.

12) Draft Amendment: Ministry to develop a template for community partners to provide feedback and proposals

Feedback:

  • Proposed alternatives to school closures and proposals for community use of schools should be submitted to the board prior to the PAR process. It is too late to consider these ideas during a PAR.
  • This template could be a part of the Community Planning and Partnerships Guideline (CPPG) instead.
  • Student programming must be viable, and will be the first priority, even if there is space for community partners to use. The revised PARG should clearly reiterate boards' primary responsibility as such.
  • The template should require community partners to demonstrate sustainable financial viability when submitting an alternative proposal to school closure; that they offer programs that are complementary to a school setting; that the proposed community use aligns with the organization's mandate and core service offerings.
  • If there is a template, boards should have flexibility for local circumstances.
  • Boards should be consulted on the development of these templates.

13) Draft Amendment: Integrate the administrative review procedure into the PARG document

Feedback:

  • The language in the administrative review section should clearly state that an administrative review cannot overturn a board's decision.
  • The administrative review process and the petition template should not be included in a board's own local PARG document, as this is a tool for the public, not for school boards. The administrative review process is not required as a part of a PAR, so it is not appropriate for a board's own policy/procedure to provide the steps for an administrative review.
  • All petition requests should be sent to the board, as well as the ministry.

14) Draft Amendment: Ministry to allow e-signatures for the administrative review petition and develop guidelines on e-signatures

Feedback:

  • Only one parent or guardian should be allowed to sign the petition per affected student.
  • Only e-signatures of parents or guardians who participated in the PAR process may be used to sign the petition.
  • The term "affected" school needs to be clearly defined as the school that is being closed in the context of an administrative review request.

15) Other Suggestions

Municipal Involvement:

  • The Ministry of Municipal Affairs should mandate local school advisory committees for each municipality.
  • PARG should specify that "municipalities" includes, single, upper, AND lower-tier, not just the first two. Ensure that consultation happens at all three levels.

Municipal Meeting:

  • Meeting with municipality should occur within 30 business days of the trustees' decision to undertake a PAR, before the formation of the ARC and before the first public meeting.
  • There was a lack of support for the statement that the municipality or partners must provide their response to the options. This could be perceived as allowing municipalities to stop the PAR process if they do not provide their response before the final staff report. PARG should be revised to remove the word "must" in terms of a response being required.

Role of the Accommodation Review Committee (ARC):

  • Respondents were divided on whether the ARC should be responsible for developing new accommodation options.
  • Some respondents believed that new options should not be developed by the ARC during a PAR, as it may not produce the best option.
  • Other respondents said that best practice should be to speak to the ARC and the ARC will put forward ideas. The public can submit options and the ARC can decide if they want to move forward with these. The community should understand that the ARC is the conduit for the community.
  • ARC members can develop options but they must be based on a rationale/information (for example, the board will provide the ARC with data). Then the ARC can develop their own options and submit these to the community for discussion.
  • Since the ARC members are the conduit of information, PARG could give guidance as to how information should be shared.
  • PARG should specify that ARC orientation meeting is not a working ARC meeting.
  • ARC chair/vice chair should chair the ARC and public meetings.
  • All ARC members should be required to attend the ARC orientation.
  • PARG should be more prescriptive of what is to be discussed and shared at an ARC meeting.
  • Respondents were divided on whether the ARC orientation should be public or private to avoid public criticism.
  • The PARG should clarify if a municipal councillor can be part of ARC membership.

Trustee Role:

  • It should be emphasized that trustees are ad-hoc members of the ARC and participate passively.
  • Alternatively, trustees should be removed from the ARC to prevent divisiveness and perceived favouritism.

Initial staff report:

  • Initial Staff Reports should include a description of the actions taken on the four solutions outlined in the preamble section of the PARG, including analysis of both positives and negatives.
  • PARG Section III: should include "school board financial viability/sustainability", so that school boards can address their financial pressures.
  • Initial Staff Report should provide a "summary of accommodation issue(s) for the school or school area under review" to prevent individual school communities from arguing over which school has greater needs.
  • Boards should have the flexibility to include a School Information Profile (SIP) in the initial staff report.

School Information Profile (SIP):

  • The PARG section on SIPs should read that "the SIP is expected to include data (to inform) each of the following four considerations about school(s) under review".
  • SIPs should be completed before the initial staff report, not after it has been started.
  • SIPs should include the distance of students to their current school and length of their bus ride. This information should be included for all PAR options.
  • SIPs should not have to reflect proposed changes from new options. SIPs are meant to represent data for a school at a certain time.
  • SIPs should not be the tool to compare two schools and draw conclusions between them.

Final Staff Report:

  • Should include staff-level feedback.
  • Should summarize the proceedings of any meetings with municipalities.
  • The PARG should clarify that there are multiple versions of the Final Staff Report. The PARG should clearly make the distinction between the Final Staff Report and the Final Staff Report with delegations. Final Staff Report should be called "Final Staff Report with Delegation Feedback Addendum" to help distinguish the reports. There might be another version if an additional meeting is added, if there is a new school closure option. This version would have the added commentary from the additional meeting.

Ministry Supports:

  • Ministry staff should attend PARs to observe and offer support if needed. Ministry representative would not be identified to the public. This would also be useful during an administrative review to verify events.
  • Provide flowchart/visual aid for PAR process showing timelines.
  • Ministry should provide an outline of its requirements for final staff report or a template.
  • Boards should hire a facilitator to work with the ARC chair to help run the meetings.
  • Ministry should provide resources to educate the community/stakeholders to develop a shared understanding of the mandate of school boards, issues, funding, etc.

Administrative Reviews:

  • Revise the template for administrative review petition.
  • Boards should send their responses to administrative reviews to both the petitioner and the ministry.
  • In the event of an administrative review request, the requesting party should be required to notify the board, as well as the ministry, of their request. Petitioners need to send their petition letters and signatures to the board.

Public Delegations and Meetings:

  • Clearer policy is needed for speakers/presenters or open public questions or delegations.
  • Boards should have more flexibility to conduct community consultation. Instead of only having public meetings, they can select from a variety of methods (workshops, open houses, online streams, etc.). This will help inform the public, foster a collaborative relationship and allow for a faster process.
  • The PARG should be reworded to reflect that feedback collection can occur outside of public meetings. For example, "include public meetings in conjunction with other methods of public consultation to solicit feedback and input".

Timelines:

  • Boards should be able to make a final decision during the summer holidays, but delegations should not be made at that time.

Clarify PARG Language:

  • Incorporate into PARG: “Local school board should continue to have the flexibility and autonomy to address local needs within the PARG. Local Trustees should be able to determine local policies to address local needs.”
  • Incorporate into PARG: “Board's key function is to deliver quality programming for students, and that schools must remain viable as schools before anything else (i.e. community partners).” Provide consistent messaging throughout the PARG to communicate this.
  • More information is required surrounding the purpose of the second and third public meetings, as well as what specific conditions will trigger an additional meeting. What is considered a “new” option? Is it "new" compared to the initial recommended option, or to any of the options provided in the report? If an option is introduced before the final staff report then will it trigger an additional meeting?
  • “School closure” needs to be clearly defined (i.e. changes in programing, panel, etc.).
  • The ministry should define urban schools as well, if the definition of a rural school is included.
  • PARG should be revised to prevent trustees from modifying the final recommendation or approve a different outcome without redirecting to staff for investigation or community consultation.
  • Boards should be required to consider joint-use options before closing schools.
  • Clarification is needed for PAR exemptions.
  • PARG should clarify that the decision made by the trustees will not result in additional public meetings.
  • PARG needs more clarity as to what a "transition plan" looks like and what information needs to be shared with parents and students.
  • More direction is needed on the requirement that boards provide documentation of their efforts to obtain information from local municipal governments.
  • PARG needs more detail outlining boards showed that they have considered other options prior to the PAR.
  • PARG should provide more clarity that the future of closed schools is not a part of the PAR process, as there are many instances where the local community is more concerned about this issue than the loss of local programming.
  • A pre-PAR public announcement, posted a few months in advance of a PAR, would be helpful for the community.