Garden State Coalition of Schools/GSCS      West State Street, Trenton, NJ 08608

Chris Cerf, Acting Commissioner

100 River View Plaza, Trenton, NJ 08625

Dear Commissioner Cerf,

The Board of Trustees of the Garden State Coalition of Schools has a number of concerns about virtual charter schools - how they will actually work, how they may impact New Jersey students, how they may affect traditional public schools, as well as the expedited path currently being pursued to establish them this coming school year in our state. In addition, virtual schools require thoughtful discussion on how to be funded, especially since they are known to be less expensive to run than regular charter schools. Another funding complication is that the regulations – not yet approved - call for open borders for these online schools. 

A  main concern of GSCS regarding charter school policies in general continues to be the clear lack of synchronization between the unrevised and not updated Charter School Law of 1995 to regulations still being revised that must be framed by such an old law. To proceed in establishing virtual charter schools for this coming year with no relevant regulations in place, with no open analysis on per pupil costs in said schools, and with no updated and supporting charter school legislation in place appears to be a clear case of putting the cart before the horse.  Just a few of GSCS’ concerns and questions are:

·          Funding – 1) actual costs per ‘virtual pupil’  need to be determined before proceeding with implementation, 2) per pupil amounts v. profit percentages, and 3) yet another drain on local taxes (especially a burden in hundreds of currently that currently must support the overwhelming majority of their school budgets via property taxes)

·          Home-schooled students – a brand new group that has not been supported by public education funds before may emerge with the implementation of virtual charters. Has this possibility been analyzed and/or reported out?

·          Has this approach to teaching and learning been effectively vetted, relevant to New Jersey, to ensure that it will bring added value to student achievement?

·          How to account for dropouts

·          What, if any, legislative footing secures virtual charter schools?

·          How to deal with the franchise effect v local community input: once a charter is granted in one locale it may expand into other localities with no process required for local review and input in those additional communities

·          What legal obligations does a for-profit virtual company avoid, if any, if it is not located in NJ?

GSCS recommends strongly that time be taken to address these issues now, and not put them on the side instead, as that will only exacerbate a growing volatile situation.  The strong sentiment among the GSCS Board of Trustees is to be very wary of building and flying the plane on the same day. Let’s not ‘go live’ with our children’s future prior to testing and vetting the program first.

Thank you for your time and for the opportunity to present to GSCS’ concerns to you.