offered no plan for children in Head Start, despite identifying 875 children as participating in federally funded Head Start. West New York also did not submit a plan that indicated that it intended to assure Head Start children an Abbott-quality program. Following Abbott VI , none of the districts provided any significant revision regarding Head Start.¹²

In support of these contentions, the petitioners offer the certifications of Cecile Dickey, executive director of the Concerned Parents for Head Start in Paterson ("Concerned Citizens"), Trish Morris-Yamba, executive director of the Newark Day Center and a member of the Executive Committee of the Newark Emergency Committee to Save Child Care, Audrey West, executive director of the Newark Preschool Council, and Lorraine Johnson, director of the North Hudson Community Action Head Start Agency. Each of these individuals details the circumstances of her particular organization and addresses concerns regarding allegedly inadequate funding offers, lack of assessment of needs, including for transportation, professional development and certification, disparity of salaries and benefits between their staffs and those of the local districts and the need for comparability in order to secure and retain qualified staff.

Ms. Dickey reports that her organization has operated since 1965 and currently serves 663 disadvantaged three- and four-year-olds, spending an average of $6,500 per student to provide a full-day or six-hour program for 560 children for 185 days a year and an extended day or ten-hour day for 103 children for 245 days a year. During the 1999-2000 school year, the Paterson School District approached the organization about providing Abbott preschool to non-Head Start children and also providing preschool under Abbott standards to some of the federally-funded Head Start children in Paterson. The district offered to pay $3,500 per child, but no contract was ever finalized and Ms. Dickey believes that the DOE rejected the district's offer. No explanation was ever provided as to how that $3,500 figure was determined, and she contends that it

¹² Dr. Holster's certification also complains that the DOE did not require Passaic to include Head Start children or approve funding for Head Start children in the district's preschool plan.

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