Liz and Bob Low, Richmond, Vermont
The following is a more detailed response to the Analysis done by Richard Heaps of Northern Vermont Consulting (NEC) and commissioned by the Home Builders and Remodelers Association of Vermont, the Northwestern Board of Realtors and The Vermont Association of Realtors. Liz Low was a member either of the Richmond Elementary or the Mount Mansfield Union School Boards as well as the Chittenden East Executive Committee for many years. Bob Low currently is a member of the Mount Mansfield Board. Thus, we both have direct experience with school budgets. We make these comments as individual taxpayers: our views must not be construed as those of any of the Chittenden East School Boards.
In this document, the “Analysis of the Proposed Richmond School Impact Fee”, prepared by Richard Heaps” will be referred to as the “Analysis”.
SUMMARY
The “Analysis” contains valuable information for assessing the value of proposed school impact fees for the Town of Richmond, as well as assessing future trends in enrollments and their impact on school taxes. However, the information used is incomplete and in some aspects interpreted incorrectly. Contrary to what is put forth in the “Analysis”, additional students will increase the financial burden of Richmond taxpayers.
There may be other reasons to be against Impact Fees. Impact Fees do, however, ease but do not eliminate the increased financial burden that accompanies new students.
MAIN ARGUMENTS
1. Contrary to the conclusions in the “Analysis”, new students are accompanied by new expenses. This becomes clear when one considers all of the expenses related to the student. This was not done in the “Analysis”. Impact fees do reduce the financial burden due to new students, but an increased burden nonetheless occurs.
2. If the Town has (generated) the capacity through borrowing for fire trucks and schools, a one-time impact fee is entirely appropriate source of support and serves as the basis for State statute accordingly (T.24 Chapter 131, § 5200). It is entirely appropriate for owners of new homes to share the burden of debt service.
MAIN ISSUES WITH THE “ANALYSIS”
Summary
The following general issues cast doubt on the validity of the interpretation provided by the consultant.
1. The nature of education has changed substantially from that on which the current interpretation in the “Analysis” is based (early 1990s). New mandates alone have and will require new or reconfigured space. New programs have and will be instated. Full-day kindergarten is under consideration, the pre-school program is being changed, IEPs require more / different space, technology requires special space, and there always are other expectations of the community for our school system. The “Analysis” does not account for this.
2. Debt Service continues for our schools. These are legitimate expenses for which impact fees can be levied. Indeed, Impact fees may be levied for other than new constriction (see State Statute).
3. No projection for new housing over the interval studied is provided from which to assess the impact of new students. The recent increase in housing in Richmond is not noted (77 new houses since 2000 according to the Richmond 411 Forms reporting housing); nor is the number of new houses under review by the Richmond Development Review Board (DRB).
4. No assessment is made for the stability of the current education funding model (Act 68).
5. No evidence is provided that the assumptions and calculations in the “Analysis” have been reviewed by the CESU Office, our school Principals and our School Boards.
6. No numerical evaluation is provided of the inexactness of the estimation procedures used, i.e. the margin of error. How precise are the estimates and projections for population in general and student population in particular?
7. The conclusion that adding students would reduce the financial burden of Richmond taxpayers is incorrect. Experience dictates otherwise, even when Act 68 is taken into consideration. The reason for the inappropriate conclusion is the lack of consideration of variables that contribute significantly, several of which are enumerated above. The conclusion also indicates a substantial lack of understanding of school budgeting, and the fact that large portions of the budget are calculated based on student number. Put more simply, the record shows, as the “Analysis” reports, that cost per student to Richmond residents is greater than that for which the Town is reimbursed from State and other sources. The same will be true for each new student in the foreseeable future.
8. Recent experience amply has demonstrated that the changes in school population are not evenly distributed across grades K-12. This and its impact on Richmond taxes are not considered.
Our public school system has come about through a system of checks and balances that include annual votes on the budget and regular election of School Board members. The quality of our schools has been found to be excellent, and this must not be jeopardized. Education is critical to our future. We have good schools. We must assure that will continue to be so and that we can support them adequately.
Detailed Analysis
Page 1, Finding #1. Enrollment is declining, but will level off an then increase (see page 15). The words rapidly and dramatically over inflate the size of the change.
Page 1, Finding #2. The statement is inconsistent with data provided in the “Analysis”. Data provided indicate that enrollment in Chittenden County will NOT continue to decline for the next 20 years (e.g. see pages 16 and 17; page 2, Section III).
Page 1, Finding #3. The conclusions regarding excess capacity are faulty (see page 21). School capacity must be evaluated given current and future educational programs, not those of the present and past. Examples of what might alter the conclusions are Kindergarten, technology possibilities, small group and team learning, new approaches and mandates related to special needs, etc. Thus, conclusion 1 is not appropriate.
Page 1, Finding #4. The statement is NOT a certainty. Critically, Bolton and Huntington students were not factored into the CHMS student population. A 20 year forecast also is very inexact, as would become apparent if numerical estimates of the margin of error were included, together with missing key variables. These errors also are apparent when one examines the range of population growth estimates that have been put before the public (see below). Therefore, conclusion #2 is misleading.
Page 1, Conclusion #2. It is inappropriate to suggest there is “no basis” for including past expansion (and its debt service) in an impact fee. The appropriateness of including debt service is a matter of State Law. Assuredly, the new facilities undertaken in the 1990s have been and will continue to be utilized by existing and future students. Those in doubt simply should visit our schools and see.
Page 1, Finding #5 and Conclusion #3. The statement that a new home would lead to a reduction in taxpayer financial burden throughout the foreseeable future has no basis in reality. There are a number of expense categories that are calculated based on number of students and that were not included in the “Analysis”. For example, when new students require an additional teacher or any other support (music, art, Special Education, Technical Education, etc), and the charge for central CESU services are included there are increased expenses.
Page 2, Section II (also table, page 4). Recent growth in Williston indicates the instability of regional estimates. One must be wary, therefore, of statements that “Richmond’s demographic trends are similar to those of its neighbors…”.
An analogy may be helpful. Consider a room full of jars (Towns). There is a hose attached to an open faucet in the room. The hose is not being held, so the water (population / students) sprays randomly throughout the room. All the jars will fill approximately equally, if time is allowed for this to occur (sample size). But suppose someone holds on to the hose directing water to a subgroup of jars (e.g. a new interchange is made on the interstate or a large employer moves in). Even if the total water sprayed remains the same (the spigot might even be opened further) the water will now be distributed unevenly. We know these non-random events take place. The hose recently has been held over Williston. Who might be next?
Page 4, Section II. What is the numerical margin of error here?
Page 5. Population growth in Williston in the 1990s is given as 4.6% annually. This is a large figure which could occur elsewhere at some future date, including in Richmond. There are situations when a community must prepare for a maximal response, not an average one. School capacity is one of those.
It would be most helpful to include data over time rather than examining one instant in time. The data are available. What are the trends within age groups?
Page 6. It is indicated that a 1 percentage point difference in Richmond age distribution would amount to 9 students, half an elementary school classroom. This is not a small number and is not a small additional financial burden. Again, data over time would be helpful. The final conclusion must be put in the context of what has happened to Williston and what might happen should a Renbel-like project, as proposed in Richmond a number of years ago, become reality.
Page 7. How were recent population growth estimates made and what is their margin of error? Using the figures for the State as a whole creates a number of sampling issues. What evidence is there that regional growth is uniform throughout the State? Why is not disproportionate growth likely based on experience to date? Knowledgeable individuals (e.g. at the Chittenden County Regional Planning Commission - CCRPC) indicate that Chittenden County presents unusual sampling problems and that data for the State as a whole can be dangerously misleading. The Economic and Demographic Forecast prepared for the CCRPC, dated September, 2000 presents a very different demographics assessment, which may well turn out to have been inaccurate but certainly does demonstrate the wide range of extended forecast numbers that can be made depending on the data used and assumptions made. Making the analysis more difficult, there is a substantial sample size issue when units are as small as Richmond.
Page 9. How are population projections made, and what is the numerical margin of error? For footnote #3, what is the basis for the belief?
Page 10, table. How were the population by age forecasts made? They do not appear entirely to be internally consistent. For example in 2000 there are 10,012 students in 5-9 age group. Why, then, are there 13,441 ten years later in the 15-19 age group? Is this due to an influx of students? To the nature of the statistical anaalysis applied? To something else? The MISER numbers at the top of the page are of concern. Is there a sample size problem here? What is the numerical margin of error? Finally, under C, who is going to purchase the houses given the population forecast? Or are current ones to be abandoned? Related to this issue are data specific to Richmond: 77 new houses have been added in Richmond since 2000, amounting to approximately 54 additional students using the figure of 0.7 students per household recommended in the “Analysis”.
Page 11, bottom. Who is concerned? What are the concerns?
Page 12. The data show past K-12 enrollments for Richmond. Page 15 shows forecasts of enrollment. Was the RES survey of preschool students considered? If it is assumed the first five lines of the table on page 15 are derived from our school census data for pre-school children and rolls each class forward as the years go by, after that, the forecast becomes quite inexact. The numerical margin of error is not given. No mention is made of the predicted number of new students added due to new housing. What will be the impact if the recently released CCRPC Report on Housing Targets is used to estimate housing growth? Also, no mention is made of any possible changes due to increases in Town population due to other factors such as immigrant family resettlement, such as has occurred in Burlington.
Page 13. What do the disaggregated data look like (by Town)?
Page 14. What do the disaggregated data look like?
Page 15. Finally, margin of error is mentioned. Bt where are the actual error data?
Page 16 and following. Vermont-wide data are shown. These do not give us details for Richmond and thus do not account for our unique situation. Decisions based on the local picture require examination if decisions regarding Richmond are to be based on such an analysis (see above).
As but one example of the importance of the local picture is the aforementioned recent growth in Richmond housing (77 over last 5 years). Also instructive is the number of subdivision proposals under review by the Richmond DRB over the past few months. Just its June 8 Minutes describe proposals that would create a total of some 15 more home sites in Richmond. The MISER statistics quoted on page 9 of the “Analysis” calls for a population increase in Richmond of 172 people from 2000 to 2010, or 17.2 per year. Assuming those 15 sites are approved by the DRB, they alone could be expected to bring in roughly a third of the total population increase projected for the entire decade. They would add approximately 10 new students at 0.7 students per household using the “Analysis” calculation.
Pages 17 and 18.
Where numbers are judged to be significant, by what analytic test was that determined?
Page 18. As revealed in the discussions that led to defeat of the RTA proposal, there were serious concerns about the validity of the numbers the Regional Technical Academy (RTA) provided regarding school enrollments.
Page 21, capacity constraints. It is now anticipated that RES capacity is less than 490, as is indicated in the “Analysis”, page 20, IV.A., paragraph 1. It is not certain that the school can accommodate all the students anticipated over the 20 year study interval, because we do not now know what educational programs will be in place over that time, including what external forces / mandates will be forthcoming. The pre-1994 capacity of 350 students should not be used as a basis for discussing school capacity in 2014, due to the many changes in the education program that already have occurred and unknown ones for the future. In addition, capacity at CHMS needs to include Bolton and Huntington students and does not.
Page 22. Capacity at MMU also may not be sufficient for the same reasons as well as the possibility of new programs, such as technical education.
Page 23. The Richmond school system has been dealing with declining enrollment for a number of years. This process is NOT “beginning”.
Page 24. The table needs further clarification. Does the “direct instructor” column include music, art, etc teachers? What program changes and what decisions about educational methods such as team teaching that have been made in the past five years were considered? What staffing is included in the total FTE column? Were teacher contract requirements in the last five years considered?
Page 24: adding students to smaller enrollment classrooms. All well-and-good. But how does one do this? For example, should Richmond only allow families with certain aged children to build? In any case, this is not a long-term solution.
Page 25. Similar questions can be asked of the table on page 25. As well, the school designation for the table on page 25 should be CHMS not the Elementary school.
Decreasing staff is a step function based on classroom size. A decline of one or two students at each grade level does not allow a staff reduction. Staff reductions do take place as a result of declining enrollment, however, as most recently took place at CHMS and should be anticipated for the future should enrollments continue to fall.
Page 25, last statement. What tax rate is this? Addition of student will increase all of those expenses that are based on student number, such as central office services and transportation. As students are added, at some point, staff also have to be added, adding further to costs. This assumes that the number of staff is reduced as enrollment falls, as took place for CHMS and can be anticipated further. What account has been made of NEA negotiations that will be taking place over the study interval? Impact Fees do reduce the increase in financial burden that accompanies each new student. Nonetheless the financial burden still increases.
Page 26. If one additional student lowers the per pupil spending by $11, and the equalized tax rate by $0.0017, the tax decrease on a $100,000 house would be approximately $1.70. However, adding one student given no changes in other towns in the Supervisory Union will increase the proportion of expenses which Richmond covers for centralized services, such as Transportation and Special Education. The change of one elementary school student would result in the neighborhood of a $1,500 increase for central services. There, alone, goes a major portion of the proposed tax reduction. The change of one middle school or high school student, alone, eliminates the tax reduction proposed in the “Analysis”.
Education is critical to our future. We have good schools. We must assure that will continue to be so.
Respectfully,
Liz and Bob Low
Richmond Vermont