Good morning, Chairman Bedwick and Honorable Commissioners.

My name is Jennifer Arevalo and I am the CEO at the Souderton Charter School Collaborative. On behalf of the Pennsylvania Coalition of Public Charter Schools, as well as the close to 170,000 public charter students across the Commonwealth of Pennsylvania, thank you for the opportunity to speak today and provide a few brief remarks on the Pennsylvania Department of Education’s Final-Form Charter School Regulation.  

We oppose this regulation and ask the Independent Regulatory Review Commission to disapprove based upon the criterion that you utilize to review proposed regulations: (1) Statutory Authority and Legislative Intent; (2) Economic Impact; (3) Public Welfare; and (4) Public Health and Safety. 

This final-form regulation circumvents the legislative process. The regulation goes beyond clarifying the Charter School Law’s legislative intent and beyond PDE’s statutory authority. 

The regulation will have a detrimental economic impact on the charter school community, including but not limited to the redirection payment process.  PDE has calculated that they will save approximately $60,000 annually; however, the regulation does not solve the redirection disputes (hundreds of thousands of dollars in tuition payments) that have plagued our state for years.  The egregious school district behavior will continue to threaten the closure of charter schools and jeopardize charters’ ability to pay their bills.

When it comes to Public Welfare, Pennsylvania public charter schools kept teaching during the pandemic, including my school, and our students’ welfare was kept at the forefront of our work. The result of our collective efforts is seen in our growing enrollment numbers, almost 23,000 in 2020 – 2021 alone, and more parents choosing charter schools. 

This regulation may lead to additional closures of schools, many of which are small, single site, minority operated and attended charter schools.  

This regulation will also make it harder, and possibly impossible, for new public charter schools to open in our Commonwealth.

This will reduce not increase school choice options for families. Public charter schools serve a majority of minority students as well as economically disadvantaged students. 

The overall response from the charter school community is negative towards this regulation.  The concerns and suggestions of the community were largely left unaddressed and ignored by PDE.

There was no collaboration or consensus reached with the charter school community on this broad-sweeping and significant regulation.    

When it comes to the health and safety of our students, some of the top issues why parents choose charter schools for their children, this regulation could place students back into bad situations.

This final-form regulation would harm Pennsylvania’s 170,000 public charter school students and the tens of thousands of students who are on waitlists to attend one of these schools.  I’m very worried about the future of my own school, one that has successfully operated for over 20 years.

There are not enough calculations or analyses by PDE to conclude that “The Department does not anticipate any greater cost or adverse effect to the charter school entity community as a whole…”.  

Therefore, the Pennsylvania Coalition of Public Charter Schools respectfully requests the Commission to exercise your independence to disapprove of the PDE’s Final-Form Charter School Regulation.  

Thank you!