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Charter Schools — Request by Pioneer Valley Chinese Immersion Charter School for Review of Commissioner's Decision

Members of the Board of Elementary and Secondary Education
Mitchell D. Chester, Ed.D., Commissioner
June 17, 2016


Pioneer Valley Chinese Immersion Charter School (PVCICS) is a Commonwealth charter school located in Hadley and serving a large number of districts in Franklin, Hampshire, and Hampden counties. The school's mission is to produce "academically strong students highly proficient in Chinese and English." PVCICS received a charter in February 2007 to establish a K-8 school with a maximum enrollment of 300 students. The school opened in September 2007, and its charter was renewed in 2012. PVCICS received approval from the Board of Elementary and Secondary Education (Board) to increase its grades range to K-9 in 2012 and received approval in 2013 to increase its maximum enrollment to 584 students and serve grades K-12.

On June 19, 2014, two years ago, PVCICS submitted an amendment request to the Department of Elementary and Secondary Education (Department) to increase its maximum enrollment by 384 students to serve a total of 968 students in grades K-12. Because the school had not fully implemented its earlier expansion and had only limited evidence of demand, which is further explained below, I did not bring the school's amendment request to the Board for consideration. In January 2015, I encouraged the school to seek an enrollment increase in connection with its next application for renewal, which is due this summer. On April 11, 2016, almost two years after its request and fifteen months after my response, the board of trustees of PVCICS requested a review of my January 2015 decision pursuant to 603 CMR 1.10(8) of the charter school regulations. This regulation states that "should the Commissioner deny an amendment request, the charter school's board of trustees may seek review of the Commissioner's decision by the Board." The school's request for review comes before you this month.

This memorandum details the process for review, outlines the school's request from 2014 and the review performed by the Department, and provides context for my decision almost a year-and-a-half ago to not bring this school's request to the Board for approval. I continue to believe that rather than pursuing its 2014 request, the school should submit an updated request with its renewal application, which is due by August 1, 2016. Representatives of the school will be present at the June meeting and will make some brief remarks. Staff from the Department's Office of Charter Schools and School Redesign will also be available to answer your questions.

Requests for Charter Amendment Approval and Reviews of Denial

Under the charter school regulations, the Board approves amendments to a charter with respect to grade span, maximum enrollment, districts served, and contract with education management organizations. 603 CMR 1.10(1). The Department performs a comprehensive review of each amendment request based upon the criteria found in section 1.10 of the charter school regulations and the Department's Amendment Guidelines. In evaluating a school's request to amend its charter, the Department and the Board consider affirmative, credible evidence that the request meets the Department's criteria and additional evidence of a school's success in each of the three accountability areas: academic program success, organizational viability, and faithfulness to the terms of its charter.

When an amendment request is brought to the Board for consideration, I have determined that the request has substantially met the criteria for approval. In cases where a charter school's amendment request is not brought to the Board for consideration, the board of trustees may appeal directly to the Board to review my decision regarding their request. The Board's options during its review are to:

  • Vote to approve the school's amendment request, notwithstanding my objections;
  • Vote to deny the amendment request; or
  • Take no formal action, in which case the denial stands.

Pioneer Valley Chinese Immersion Charter School — 2014 Amendment Request and Review

On June 19, 2014, PVCICS submitted a request to increase the school's maximum enrollment by 384 students. After a thorough review by the Department, including an interview with board officers and the school's executive director and principal in December 2014, I decided to not bring the request to the Board for approval based upon the evidence provided by the school. I communicated my decision to school and board leadership by letter in January 2015. The Department communicated with board leadership regarding my decision and explained how the amendment request had not sufficiently met the review criteria. Specifically, the school had not provided adequate evidence of demand for enrollment and had not yet completed implementation of the high school grades awarded in February 2013. Below is a summary of the school's request and the Department's review during the 2014-2015 amendment cycle.

Pioneer Valley Chinese Immersion Charter School
Type of CharterCommonwealth LocationHadley
Regional or Non-Regional?Regional Districts in Region
(if applicable)
39 districts in Franklin, Hampshire, and Hampden1
Year Opened2007 Year(s) Renewed2012
Chartered Maximum Enrollment584 Current Enrollment439 [389 at time of decision]
Chartered Grade SpanK-12 Current Grade SpanK-11 [K-10 at time of decision]
Students on Waitlist103 [51 at time of decision] Current Age of School9 years [7 years at time of decision]
2014 Amendment Request:
Increase maximum enrollment by 384 students, from 584 to 968;
Implementation to occur during 2017-2018 school year;
Proven Provider Status Required [Holyoke, Springfield].
Mission Statement
"The Pioneer Valley Chinese Immersion Charter School is a K-12th grade educational program that produces academically strong students highly proficient in Chinese and English. The program goals are: to develop proficiency in Mandarin Chinese; to maintain and extend students' proficiency in English; to develop high levels of academic attainment, meeting or exceeding national and state standards, through rigorous study and instruction aligned with the Massachusetts Curriculum Frameworks; to develop students' understanding of other cultures and the ability to interact successfully with others whose language and/or culture differs from their own. PVCICS serves the Pioneer Valley region and offers a diverse group of students an innovative educational opportunity unavailable in Massachusetts. PVCICS will work to disseminate the school's experiences and serve as a resource for schools trying to develop similar programs."

Overview of Factors Relevant to Decision

In February 2013, I recommended, and the Board approved, a charter amendment for PVCICS to increase the school's maximum enrollment by 284 students and to add grades 9-12 to become a K-12 school. At the same meeting, the Board removed conditions related to governance that had been imposed at the school's renewal in February 2012. I recommended the removal of conditions because the board of trustees had substantially addressed the imposed conditions, including revisions to the process for evaluating the executive director and principal, and board self-evaluation and governance training. I also recommended the increase of the school's maximum enrollment and the addition of a high school in 2013 due to the school's academic success, organizational viability, and compliance with applicable state, federal, and local laws. The school's academic performance was strong, qualifying it for proven provider status as required by serving Holyoke and Springfield within its charter region, both districts performing in the lowest 10 percent of districts based on state assessment data. I recommended granting an increase of 284 seats rather than the 384 seats requested by the school to support implementation of the growth plan described in its amendment request (see Figure 1 below) and the full implementation of the proposed high school grades.

In my memorandum to the Board recommending the increase and in the Department's communications with board and school leadership, I indicated that I would consider any future requests to increase maximum enrollment at the school's next renewal in 2017, once the grade span expansion had been successfully completed and the demand for the size proposed could be supported by evidence.

Table 1:

PVCICS Projected K-12 Enrollment with 684-Student Cap
9th 42020406060
10th  420204060
11th   4202060
12th    42060
Provided in 2014 PVCICS amendment request.

On June 19, 2014, PVCICS submitted a request to amend the school's charter to add 384 additional seats for a total maximum enrollment of 968 students. The school reported that submission of the request was prompted by the realization that the proposed enrollment in grades 6-12 was not sufficient to establish the high school program envisioned, which includes an International Baccalaureate (IB) program. The request presented a modified vision for the school, including growing the middle school and high school by 284 students and establishing significant entry points for new students at 6th (50 percent of the total seats in 6th grade) and 9th grades (20 percent of the total seats in 9th grade). During an interview with Department staff, members of the board of trustees and school leadership noted the desire to increase enrollment in order to implement a K-12 school that provided a full range of offerings to address the needs and interests of students and parents. The school reported that approval of the request would support student recruitment, and the school's ability to secure resources and meet future facility needs for a separate high school facility.

At the time of the Department's review, PVCICS did not provide adequate evidence to revisit an increase in maximum enrollment prior to the school's next renewal decision in 2016-2017. The concerns are highlighted in the bullets and tables that follow.

  • As of the 2014-15 school year, PVCICS had not yet fully implemented the expansion awarded in 2013. The school was serving 389 students in grades K-10 at the time of the Department's review. Approximately 30 students were enrolled in the high school during the 2014-2015 school year. (See Table 2.)

    Table 2:

    Student Enrollment by School YearGradeTotal

  • PVCICS provided limited evidence of student demand to support increased student enrollment for the proposed educational program. The school's enrollment was lower than projected in the growth plan from its 2012 amendment request (Table 1 on page 4 and Table 2 above). Waitlist reports from 2013 and 2014 indicated limited enrollment demand for middle school or high school grades with the vast majority of applications received by the school for the kindergarten entry point. (See Table 3.)

    Table 3:

    Waitlisted Students
    Reported by PVCICS
    May 2013 waitlist49136212121 77
    January 2014 waitlist3718984254312 93
    March 2014 waitlist37156722057000081
    November 2014 waitlist1765504058001051

On January 21, 2015, I notified the school that I decided to not bring their request to the Board for approval. I strongly encouraged the school to submit an updated expansion request with its renewal application in summer 2016. The application is due no later than August 1.

I am enclosing copies of the school's amendment request, dated June 19, 2014; my denial letter, dated January 21, 2015; and the school's request, dated April 11, 2016, for a review by the Board of my decision. In accordance with our standard procedures, the superintendents and school committees in the school's region were provided an opportunity to comment on the 2014 amendment request. We received comment prior to my decision on the school's request from the superintendent of Gill-Montague Regional School District in opposition to the school's enrollment increase and that letter is enclosed. No other comment was received.

After PVCICS submitted its review request in April, my staff spoke to Charles Bagley, the current board chair, and Richard Alcorn, the school leader, to ensure the school's board of trustees is fully aware of the scope of this review of my decision. I requested this additional consultation with school and board leadership for two reasons. First, significant time has passed since the Department reviewed the 2014 amendment request and the evidence has undoubtedly changed. Second, the composition of the board of trustees of PVCICS has changed substantially since the time of my decision, and only one of the current 11 trustees was an active member in 2014-2015. Through these conversations, the board chair and school leader have confirmed the school's intent to bring this review to your attention now as opposed to bringing forward a new request in a few weeks when they seek renewal of the school's charter.

As noted above, the Board's options in this matter are to:

  • Vote to approve the school's amendment request, notwithstanding my objections;
  • Vote to deny the amendment request; or
  • Take no formal action, in which case the denial stands.


If you have any questions regarding the school's request for review or require additional information, please contact me, Cliff Chuang, Senior Associate Commissioner, or Alison Bagg, Director of Charter Schools and School Redesign.


Download PDF Document  Download Word Document
Correspondence from Pioneer Valley Chinese Immersion Charter School: Appeal Request
Download PDF Document  Download Word Document
Correspondence from Pioneer Valley Chinese Immersion Charter School: Amendment Request
Download PDF Document  Download Excel Document
Appendix E — PVCICS Cash Flow
Download PDF Document  Download Word Document
Amendment Review Analysis for Pioneer Valley Chinese Immersion Charter School
Notification Letter of Amendment Request Denial Decision
Correspondence from Gill-Montague Regional School District



Last Updated: June 21, 2016
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