Pupil Accommodation Review Guidelines Analysis

by Jeremy Hsuing

The Pupil Accommodation Review Guidelines (PARG) are the Ontario Ministry of Education’s framework for the School Boards detailing how to proceed with school closures.  The PARG were previously called the school closure guidelines.  The updated PARG is an attempt to remove the financial incentives to closing schools.
Each school board establishes their own accommodation review policies, under the Ministry framework.  The Ministry states that there must be

• 60 days prior notice to the first of a minimum four public meetings after the intention to conduct an accommodation review has been announced.
• 90 days minimum public consultation period
• 60 days minimum prior to the public meeting where trustees will vote on the accommodation review and recommendations

School holidays such as summer vacation, Christmas break, and Spring break are not considered part of the consultation period days.
The PARG is designed to ensure that the school board's decision regarding the future of a school involves the local community and considers a breadth of criteria concerning the quality of education for students.  School boards develop a generic School Valuation Framework to evaluate schools.  The framework evaluates schools are on four criteria.  These are value to the

• Student (quality of learning environment, student outcomes, range of course/program offerings, range of extracurricular activities and extent of student participation)
• Community (facility use by community, range of programs offered for both students and community, recreational/green space, a partner for government community initiatives, value of school in terms of need in the community)
• School board (student outcomes, range of course/program offerings, availability of specialized teaching spaces, condition/location of school, value of school in terms of need in the community, fiscal and operation factors (cost to operate, cost of transportation, availability of surplus space in adjacent schools, cost to upgrade the facility so that it can meet student learning objectives)
• Local economy (local employer, cooperative education, training opportunities and partnerships with business, attraction/retention of families in community, value of school in terms of need in the community)

The public review of school/group of schools is led by a local Accommodation Review Committee (ARC) appointed by the board.  Schools should only be under review once every five-year period.  Each ARC must have members from the school community and the broader community.  ARC plans must include as part of the review: where students would be accommodated, what changes to existing facilities are required, programming available to students, and transportation.  The ARC is responsible for

• School Valuation Framework
• Public information and access (on school board website or available in print upon request.  All relevant information must be made available, and technical information should be explained in plain language)
• Community consultation and public meetings (include school councils, parents, guardians, students, teachers, local community, and other interested parties.  Consultations based on School Valuation Framework, and must seek input and community feedback on options for accommodating students who would be affected by school closure.  Information relevant to consultation meetings is to be made available in advance.  Minutes reflecting a full range of opinions is to be kept and made publicly available.  A process for questions that cannot be answered at the meetings must be in place.
• School Valuation Report and Recommendations.  In the Report, the needs of all students within the board's particular planning area are to be considered.  The ARC shares the report with community, and may make changes to the report based on feedback at the meeting.  The report is submitted to the Board administration and made accessible to trustees and the public.  The Board reviews and analyses the report, and then presents its findings, proposals, and recommendations to trustees, who make the final decision on the future of the school(s).  The Board must make clear timelines regarding when schools will close.

Guidelines apply only to schools offering elementary/secondary regular day-school programs.  No ARC is needed if

• School is being rebuilt on existing site or existing attendance boundary
• Lease is terminated
• Relocation of grades where enrolment is less than half of the school's enrolment
• Temporary relocation due to repair/renovation
• Holding schools

Analysis
The second sentence of the Pupil Accommodation Review Guidelines documents states that the financial incentives for closing schools has been removed but it is not clear how.  The PARG are merely guidelines, not a set of strict laws.  This fact is made apparent by the ability of each School Board to create their own guidelines based on the framework.  While the Ministry framework specifies which criteria School Boards must consider when closing a school, the Ministry framework does not specify any order of importance for the guidelines, nor the actions required if community resistance is fierce.  Part of School Board’s review criteria includes the cost to upgrade the facility so that it can meet student learning objectives, which seems to be a partial admission by the Ministry that it is not providing enough funding for the current schooling infrastructure, and expects schools be closed because of it.
The framework specifies that there is to be a public consultation period, with no legal recourse available to the public should consultations not work in their favour.  A simple example would be a referendum given within a certain area around the school under-consultation; a 50% No vote would effectively scuttle the school closure procedure.  Without any mention of recourse in the PARG, School Boards only need to consult the public after they have made their recommendations and allow for public feedback for a minimum of 90 days.  The Ministry does allow for an Administrative Review of the Accommodation Review to determine if a School Board circumvented its own accommodation review policy, but this review may be circumvented by a well-made, ambiguous document.  In addition, if the review does find the School Board at fault, the Ministry of Education merely appoints a facilitator to address the community’s concerns, and the “Ministry expects that boards will work cooperatively with the facilitator”.   
The public review of school/group of schools is led by a local Accommodation Review Committee (ARC) appointed by the board.  The fact that the ARC is appointed by the Board instead of the community leaves room for scepticism regarding the commitment of the ARC to the public’s welfare, despite the fact that the Ministry framework specifies community members must be appointed.  A self-serving Board may appoint members who support the Board’s actions.  The ARC must seek input and community feedback on options for accommodating students who would be affected by school closure.  Alternatives to closing the school do not need to addressed.  Information relevant to consultation meetings is to be made available in advance although no timeline is given.  The ARC is responsible for creating the School Valuation Report and Recommendations and sharing the report with community.  However, in sharing its findings the Ministry does not force the ARC to make changes based on the community’s suggestions.   Instead, the Ministry opts for the ambiguous statement that the ARC may make changes to the report based on feedback at the meeting. 
The PARG appears to be a toothless Ministry document in that it gives the Ministry and the affected communities essentially no powers in the school closing process.  It gives the school boards a great deal of flexibility in the guidelines in terms of creating their own frameworks and how to deal with community responses to school closings.  The document and review process appear to have been created to give communities the illusion of self-determination, and are a self-serving Ministry of Education document to allow school boards to close more schools to reduce the financial burden on the Ministry.

The PARC Process:  Examples
Avon Maitland District School Board
The Avon Maitland District School Board (AMDSB)’s PAR has seen relatively little controversy compared to other PARs across Ontario.  PARC members have indicated that many community members felt that they did have opportunity to speak and participate in the pupil accommodation process.  These comments come despite concerns about whether school closings and pupil relocations to larger “super-schools” would prove to be detrimental to students.  Community members are concerned about the loss of a sense of school community as a result of combining grades seven and eight with the high school, and are also doubtful about the purported increase in resources with behavioural issues, since the student-to-teacher ratio would remain the same.
Halton District School Board - Oakville
The Pupil Accommodation Review (PAR) in Oakville has been very contentious and has caused two communities to come in conflict.  The communities in conflict are the Clearview community, which aims to have a school built, and the southeast Oakville community, which will have schools closed in order to fund the new Clearview school.  In addition to the inherent conflict in the school closing situation, the Halton District School Board (HDSB) fuelled further conflict through the ARC:  The HDSB created an ARC with a larger Clearview community component than from other school communities.  These actions support the argument that a self-serving school board can create an ARC that is biased towards the board’s own agenda.  The results of the PAR were contested by the southeast Oakville community, resulting in a review of the PAR by a Ministry facilitator.  Despite the fact that the board was found not to be fully compliant with the review process, most of the PARC’s recommendations were upheld by the facilitator. 
Ontario North East School Board - Timmins
The information from the Timmins PARC meetings has been very factual although some points have been raised about the committee’s composition.  While the PARG states that the PARC must include members of the school community, it does not specifically state that a teacher must be involved.  This omission raises questions about how accurately the school’s value to the student and to the community can be assessed considering that teachers are a vital component of the school and school community.
Ottawa Catholic District School Board
The response of some members disillusioned with the process supports the idea that the PAR and PARCs are powerless instruments to give communities the facade that they have power in the school closing process:
          “One public meeting is not adequate to meet the objectives of informing and consulting with the community. […] we already seem to be inadvertently planning to evade our responsibilities to engage the public. The minutes of our first meeting imply that “we will tolerate a few members of the public participating, if they are civil, but if the community does become fully engaged, and our working meetings are disrupted, we will have to change our plans.” […] we are hoping that the community does not become too engaged, rather than planning ways to engage them. […] And what if the public somehow does become involved? […] Will we restrict public input to a 15-minute session at the end of two-hour long meetings? Will we rush forward with our recommendations to avoid the heat? That, to me, will represent a total failure to meet our mandate.” – Charles Yellen
In addition, the ability of the ARC to affect change is minimal at best:
 “If we think that the purpose of the ARC is to give sound planning advice to School Boards, we are fooling ourselves. Instead, the primary role of the ARC is to ensure parents and community members feel that they have been involved in school closure decisions.” – Charles Yellen
Rainy River
Rainy River is another success story for the PAR process with near-unanimous agreement amongst parents, teachers, community representatives, and board officials that a school closure and the opening of a new school would be beneficial for the community.  Although there is not a great deal of parental involvement in this PAR, those that are involved seem to be happy with the outcome.  Judging from the notes it seems that the board is genuinely concerned about improving students’ learning environments and informing the community about various aspects of the school closure process.