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OAL DKT.
NOS. EDU 03246-01S, EDU 04029-99S, EDU 04030-99S, EDU 04113-99S,
EDU 04436-99S, EDU 05356-99N, EDU 05358-99N, EDU 05799-99N, EDU
05804-99N, EDU 05873-99N, EDU 07157-99N, EDU 07158-99N, EDU 07456-99N,
EDU 07914-00N, EDU 09462-00N
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districts
doing the same regarding their programs and students, as well
as the community providers with
whom they propose to work. As one example of the arbitrary
action of the Department undertaken without the benefit of apparent
study, analysis and assessment,
the petitioners claim that rather than doing as the Court instructed,
the DOE has instead insisted
upon imposing a pre-established cost per student of $4,500, a
figure used in such dealings
as the DOE's contract negotiations over Head Start. It
points to the form issued for the "Abbott Preschool Educational
Program Contract,"14in
which the "Compensation" section
contains the $4,500 figure as the amount the district
"shall pay the Provider . . . per child based on an average daily
attendance of no less than 80%."In
the Newark Plan submitted in January 2000, the Board proposed
to serve 90 eligible three-year-olds,
at a cost of $4,500 per student per school year in
cooperation with providers, the tuition covering educational services,
materials and supplies.
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In
addition, petitioners claim that the DOE has failed to insist
that districts detail their
plans for achieving certification of teachers within the time
frames established or to provide
funds for such purposes. It has also insisted upon limiting funding
to districts to pre-determined
ECPA levels, without assurance that such funding will be adequate
for districts to provide well-planned,
high-quality preschool education.
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The
petitioners also complain that the DOE has failed to provide safe
and adequate preschool facilities.
In part, they urge that the Department has failed to
require the districts to assess their temporary and permanent
facility needs in light of the
restriction to fifteen students per classroom and the goal of
increased enrollment. Elizabeth
especially argues that it has encountered serious difficulties
in its planning process due
to the failure of the State to provide funding, and assurances
of funding, for what the district
believes to be its facility requirements. It contends that the
DOE's failure to at least commit
to the funding of the facilities prevented it from realistic
planning for the 2000-2001 school year and forthcoming school
years and, in particular, has
deleteriously impacted on its ability to realistically recruit
its preschool population
14Miller
Cert., Exhibit D.
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