An Open Letter to the South Kingstown Town Council and Community

Dear Council Members,

This letter outlines grave concerns surrounding the procedural and ethical conduct of several South Kingstown School Committee members leading up to the March 16, 2018 facilities vote. Actions surrounding the vote call into question the public trust, transparency in decision-making, the legitimacy of the decision, and are incompatible with the South Kingstown School Committee Code of Ethics and School Committee By-laws.  I write publicly as it appears that rapid implementation of the Committee decision is under way. This is despite public assurances by the Committee of extended planning and discussion, facilitated by a formal Planning Committee that is to be vetted and convened to oversee this process. This rapid implementation has also begun before pending RI Access to Public Records Act (APRA) requests have been fulfilled, limiting the opportunity for oversight and accountability of the process and decision.

As you are likely aware, the week of the facilities vote, School Committee Chair Roland Benjamin sent a graph and accompanying text to Superintendent Stringfellow, requesting that she forward the information to other school committee members. The document included enrollment and facilities utilization information coupled with demographic projections.  The graph was not publicly available or posted on Boarddocs.  During Roland Benjamin’s explanation of his graph and argument, which occurred only after public comment was closed, the Superintendent inaccurately claimed that the graph had been publicly posted.  The graph was displayed to the side of the public seating.  It quickly became the frame of discussion only following the closure of the public comments and the decision-making process was under way.  There was no reasonable opportunity for the public to prepare, question, or engage the content of the materials presented that constituted the argument presented in the graph as it had not been made publicly available.

Several aspects of this process contrast with the South Kingstown School Committee Code of Ethics and By-Laws. These are detailed below:

The graph and accompanying text included new information and arguments.

1) Roland Benjamin estimated a new demographic trend (the dotted gray line on his graph) that is his individual forecast and constitutes a new work product.  The specific data sources, indicators, and assumptions are not explained or included in the accompanying text. His own discussion during the meeting indicated that he conducted his own estimation of this demographic trend.  This trend offers a significantly more dramatic depiction than the other demographic trends identified by the experts (McKibbens, NESDEC Annual Forecast).  In addition, Roland Benjamin chose the most extreme option in the graphical representation of his trend line, focusing on the lower bound of his forecast. The text accompanying the graph references NESDEC p. 91, 2010, implying that this trend line comes from a published source, however, the reference page in question only includes a statistical estimation technique.  In other words, the dotted grey line represents his own application of statistical methodology to a set of data rather than the presentation of already publicly available information.  This projection is new, diverges substantively from demographic expert estimates provided in the legacy study and supporting documents, and is constructed, even after considering his own text, in an opaque and non-replicable manner. 
2) A deliberate choice was made to use the most extreme and least reliable indicator of facilities capacity.  RIDE2 (p. iv, 2017) defines three capacity metrics: a) LEA (used by Roland Benjamin in his graph), b) functional capacity, and c) aspirational capacity.  The RIDE (2017 p. 2) further argues that at a minimum, all available capacity calculations should be considered as part of the master planning process. The RIDE report further indicates that each of these indicators provide different information and are not alternative measures to be substituted.  Of particular note, however, the abovementioned report consistently identifies aspirational capacity as the most equitable metric constituting best practices.  In contrast, LEA capacity is referred to in the report as “rigid” and the least reflective of current needs for educational programming and practice  (RIDE 2017, p.10).  Rather than present each of the capacity options in this graphic or provide three alternate graphics reflecting the various metrics, Roland Benjamin chose only to use the least-recommended LEA benchmark, depicting only the most extreme skewed picture of utilization of existing capacity.  The figure generated by Roland Benjamin included an artificially skewed scale required to capture the higher LEA numbers, and was not properly calibrated to include values that would have allowed for the overlay of the functional and aspirational capacity benchmarks due to the reality that these two metrics are so much lower than the LEA metric, numerically. The result is a severe misrepresentation of utilization in relation to both the enrollment and utilization data, creating the picture of a school district in an enrollment crisis. 

3) The text accompanying the copy of the graph sent to Superintendent Stringfellow and then circulated to the School Committee includes two written arguments: 1) addresses the argument that DLI has increased Kindergarten enrollments by downplaying the opportunity for future growth based on the speculation that other districts will adopt the program and 2) makes an argument for comparison between the NESDEC forecast line on the graph and his own estimate:  “The dotted grey line is a closer representation to a “reversion to norm” where we follow a cohort survival dynamic using 95% of births as the starting predictor of future enrollment.  This was common in the 10 years leading up to introduction of DLI programming (p. 91 NESDEC, 2010).  Since DLI was introduced, Kindergarten enrollment has been well above that baseline, but if other districts adapt to offer other programming , we might see enrollment retreat to the lower bound .  It is lower than the NESDEC line, but not unreasonably as it represents an error within acceptable bounds and resembles the low side delta their projection from 2009 exhibited..” (notes from Roland Benjamin graph appended to this letter)

Roland Benjamin’s arguments were intended to validate the claims made by the graphical argument, discount possible discussion, and dismiss the possibility of town policy or educational programmatic intervention as an alternative to resolving the constructed crisis. 
4) The graph excludes data that should be included for an accurate enrollment/utilization figure by ignoring the SKIP population, which under any plan requires elementary school facilities space. This exclusion of SKIP results in a depression of enrollment numbers or an overestimation of capacity numbers.  In sum, every aspect of the graph constructs a visual argument utilizing the most extreme measures available and excluding relevant data to depict a demographic crisis for the district. These include an unverified demographic non-expert forecast when other available options were derived from experts, identified as more credible, and reflect best practices of the Rhode Island Department of Education.

The School Kingstown Code of Ethics item 2 indicates that school committee members are tasked with policy decisions only after full discussion at publicly held School Committee meetings. 

1) There was no full discussion of the new information contained above or of the argument presented in the graph. This discussion should have included the range of information including the best-practice based utilization metric, and the ability to engage the argument presented in the graph.  Public comment was not facilitated.   
2) Scott Mueller featured the argument presented in the graph as a large component in his decision based on the “trend line” in his comments (in the video he is seen gesturing to the graph) and indicating that he should have “listened to Roland last time.”  
3) In fact, one school committee member, Raissa Mosher, read a prepared decision off of a printed page, reflecting on enrollments as a key deciding factor. This behavior suggests that Ms. Mosher had formulated her vote, considering the data depicted in this figure, prior to full public discussion in the School Committee meeting and prior to convening the School Committee meeting itself. 
4) Alycia Collins indicated during the closed session that the focus on “dismal enrollment numbers” as a deciding factor in the decision-making process had only arisen in the past week following the distribution of “Roland’s graph”.  This alone demonstrates that the committee had not adequately taken time to address the information.  The committee had not been presented with alternate information, and that the graph itself was incomplete, missing labeling for the y axis.    Indeed, the timing of the graph’s distribution right before the vote and the lack of public distribution precluded a full discussion on this issue.  An example of the difference in argument that would have occurred given a full discussion is presented in the accompanying comparison graph that includes additional aspirational facilities metrics and SKIP population (appended to this document). 

The South Kingstown School Committee Code of Ethics (3) obligates school committee members to make decisions on available facts and independent judgments.  This process and argument presented in the graphical argument without public discussion or comment prohibited this from occurring through the presentation of an inaccurate (exclusion of SKIP) and biased (capacity, utilization, and demographic trends) argument. Open discussion among the school committee members or one on one discussion of the argument presented in the graph among committee members in a non-public setting is prohibited by Rhode Island State General Law (Open Meetings Act), and the South Kingstown School Committee By-Laws (5.3 10).  The committee appears to have failed to meet its ethical obligations for full and fact-based discussion or the committee may be in violation of the RI Open Meetings Act. The committee also may have failed to meet its fundamental charge under the South Kingstown School Committee By-Laws and Code of Ethics: the first and foremost concern must be the educational welfare of the students (Bylaws 5.4 11; Ethics 10).  

Adoption of best practice based evidence is fundamental to execution of the educational welfare of students.  Best practices have not been observed in several ways:

1) Disregard for the wealth of nuanced and qualified data obtained from demographic experts commissioned as part of the Legacy Study and from other qualified sources, in favor of a non-expert, non-vetted estimate in decision-making, constitute a failure to fulfill this mission.  The town invested in procuring expert study to execute detailed and transparent data and processes.  The use of alternate and non-public information wastes the town’s substantial monetary investment and is clearly not reflecting best practices in guiding decision making.   
2) The failure to use the preferred and most equitable metric from the Rhode Island Department of Education to reflect school capacity reflects decision making that does not foreground educational welfare of students.  In fact, the LEA metric chosen does not accommodate a range of contemporary programs (RIDE 2017, p.10), and the School Committee has not demonstrated utilization based even on a range of capacity measures as indicated should be included above. 
3) Multiple committee members indicated that best practices include small class sizes and potentially smaller school sizes.  Consolidation will increase class sizes in direct contrast to the largely agreed upon best educational practice and environment for the youngest children in the district. Democratic accountability only works when the decision-making process and inputs are transparent.  This School Committee was tasked with making the most important decision the district has faced in the last decade.  There is a particular obligation, given that the majority of the body is appointed and that a recent Open Meetings Violation was found by the RI Attorney General, to ensure that appropriate procedures and process have occurred, community input is robust, and that all evidence is fully vetted and considered.  Instead, the committee has made a decision utilizing non-public information, excluded the public from comment on key components, and disregarded best practices in decision-making and presented biased evidence.  

The town invested well over $150,000 in the Legacy Plan and school planning. This investment has not been well used.  I urge the Town Council to evaluate the veracity of the evidence utilized to make the decision and reflect on the legitimacy of the process utilized by the School Committee.  Prior to assuming structural debt obligations and closing a well-functioning school, consider the implications of the lowest capacity line on the comparison graph derived from the RIDE report (2017, p.46).  This reflects the equally likely possibility that South Kingstown Elementary Schools could find themselves in the same over-utilized position as Newport Elementary based on RIDE metrics.   The choices and information surrounding the Legacy Planning process for the school district are some of the most important issues facing our community.  South Kingstown residents deserve evidence based and transparent decision-making throughout the process.  The inclusion of a last minute biased argument and failure to appropriately allow response and discussion represents an abdication of the ethical and educational responsibility vested in this body.  

Thank you for your consideration and prompt attention.

Kristin Johnson

South Kingstown resident and parent


See also:  State of Rhode Island Schoolhouses Report.  September 2017, Rhode Island Department of Education.  


Compilation of Demographics Models and Utilization Zones  

                                 Roland Benjamin     March 2018


 Solid orange and blue lines are two externally provided forecasts of total k‐5 enrollment,  McKibbon (p.9 McKibbon, 2017) and NESDEC (p.3  NESDEC, 2017).    

 The dotted blue and yellow show modifications of McKibbon’s forecast.  These are extreme  upper bounds, one doubling the stated error when asked prior to commissioning the forecast of  1%/yr.  The other represents the first year error over actuals in 2017 K and 1 enrollment  repeating every year for the succeeding 9 years of the forecast.  Jerome McKibbon responded  that those are the best that we could hope for and would require serious and sustained  economically disruptive shifts that as of now are not visible.  

 The dotted grey line is a closer representation to a “reversion to norm” where we follow a  cohort survival dynamic using 95% of births as the starting predictor of future enrollment.  This  was common in the 10 years leading up to introduction of DLI programming (p. 91 NESDEC,  2010).  Since DLI was introduced, Kindergarten enrollment has been well above that baseline,  but if other districts adapt to offer other programming, we might see enrollment retreat to the  lower bound.  It is lower than the NESDEC line, but not unreasonably as it represents an error  within acceptable bounds and resembles the low side delta their projection from 2009  exhibited. 

 The dashed horizontal lines represent the stated capacity for either 3 or 4 schools (p. 14, 18, 25,  29 NESDEC, 2010). 

 The colored zones represent target utilizations.  Green represents 80% to 90% utilization in 3  elementary schools with NO expansion needed at any of them.  Yellow represents 80% to 90%  utilization in 3 schools with some of the recommended expansion (~5 classrooms).  Blue  represents 80% to 90% utilization in either the fully expanded Option B recommendation, or no  expansion with Option A.  


South Kingstown Legacy Plan 2017‐2027 Demographic Study (McKibbon, 2017)
NESDEC Long‐Range School Facilities Planning and Staffing and Efficiency Review (NESDEC, 2010)
NESDEC Annual Enrollment Projection for South Kingstown (NESDEC, 2017)


The thick black line represents the 4 SK elementary school 100% capacity using an older measurement approach, which RIDE labels LEA capacity (see RIDE’s 2017 State of Rhode Island School Houses report,

 The LEA capacity measure for the 4 SK elementary schools equals 1662 (page 46). The RIDE report has an extended discussion about three different capacity measures and how they relate to utilization on pages 10-14. This LEA is the only capacity measure utilized in the graph circulated by Roland Benjamin and does not represent RIDE 2017 standards based on 21st Century Learning.

The thick red line represents the 4 SK elementary school 100% capacity using RIDE’s latest approach to measuring capacity, which they call Aspirational Capacity (see pages 10-14 in RIDE’s 2017 State of Rhode Island School Houses report, 

The aspirational capacity measure for the 4 SK elementary schools, after subtracting SKIP capacity needs, equals 1205 (RIDE 2017, page 46). Aspirational capacity relies on a space standards approach (square footage per student based on educational best practices defined in the Educational Program Space Guidelines in the School Construction Regulations, SCRs). “The aspirational capacity is based on the Rhode Island SCRs and is an aspirational goal of space use” (page 2). “For the purposes of this study the SCRs were utilized to calculate an aspirational capacity because the most consistent and equitable way a state can determine school capacities across a variety of districts and educational program offerings is by using square feet per student standards” (page 14).

When the 2017 RIDE report discusses the advantages of the aspirational capacity measure the study notes the “SCRs were adopted in 2007 whereas most schools in Rhode Island were constructed in the 1960s. The space standards defined in the SCRs are robust and reflect current teaching and learning practices. Applying current standards to Rhode Island’s aging school facility portfolio identifies facility shortfalls relative to 21st century learning" (pg. 12). By contrast, Roland Benjamin’s use of the LEA capacity measure in the original graph is described by RIDE's 2017 study as “rigid” and dated (page 10). SKIP enrollments are projected byMcKibben to be 92 students throughout this period

These new SKIP students will reside in the 4 elementary schools and were not considered in Roland Benjamin’s original graph. Because these are half day students, 92 was divided by 2, with a total capacity requirement of space equal to 46 students. In other words, the capacity available for K-5 students is reduced by a total of 46 due to the presence of SKIP in the elementary schools. This capacity correction accounting for SKIP is a very conservative approach in that pre-K students should have smaller class sizes and require about 25% more space per class than standard elementary students (see page 13 in this report.)

The thick green line represents the 3 SK elementary school 100% capacity using RIDE’s latest approach to measuring capacity, which they call aspirational capacity (see above). The aspirational capacity
measure for the remaining 3 SK elementary schools, after subtracting SKIP capacity needs, equals 1016. In other words, this analysis removes the available aspirational capacity of Wakefield Elementary School
as enumerated in the RIDE 2017 report (page 46). This illustrates the capacity of the SK elementary schools available to K-5 students if Wakefield Elementary was closed and SKIP relocated to the elementary schools.

This analysis keeps all of the enrollment projections in their original form (Roland Benjamin’s graph). Roland Benjamin included forecasts from McKibben and NESDEC; he also applied a margin of error to these forecasts. Roland Benjamin also generated his new forecast (dotted grey line) he called the Rough Estimate Cohort Survival Method (RECSM) using a 2010 methodology. Detailed methodology notes, data sources, or the raw data used in the RECSM forecast could not be found on Board Docs and his raw forecast data was not found in any other public place.