Proposed changes to charter school regs in Massachusetts

At their March meeting, the state Board of Ed is considering  proposed changes to the charter school regulations here in Massachusetts
You can find the current regs with proposed changes here. The Commissioner's summary of them for the Board of Ed is here. While I somehow got the deadline wrong on this--it closed on the 24 of January--(why is it TWO MONTHS before the meeting!?), comments can be directed to charterschools@doe.mass.edu, and it's good to cc the Board itself at  boe@doe.mass.edu.
I also plan to go to the Board of Ed meeting in March to testify before this vote.
So what's proposed?
Let's first be blunt: a number of these changes are in direct response to the closure of Spirit of Knowledge in Worcester this past fall, most particularly everything in 1.12 having to do with what happens when a charter school is placed on probation. Any such school now "may be required" to establish an escrow account to pay for closing costs; it also provides for appointment of an outside party to oversee closure, should it be deemed necessary. Further, it adds that a charter school may be placed on probation for "lack of evidence of academic success," which, believe it or not, is not currently among the reasons. The state may also withhold payments to any such charter and is now changing the bit about what happens to the property of any closed charter school: it ALL goes to the Commonwealth in the changed regs, without any language around purchase by other entities.
Things that are missing here: there should be a clear bit about reconsidering the foundation budget and the student population of sending districts when a charter school closes. Worcester managed this, but, from what I can tell, it was largely through sheer determination on the part of our finance office. It shouldn't be up to them; it should be part of the regs. If a district gets 150 kids in late October, they should count on that year, and they should be funded as the school closes, deadlines be what they may.
And the "may"s around escrow and outside parties should be "shall." There were a number of panicked phone calls that went back and forth to Malden in the weeks after SoKA closed (and not all from WPS!); there needs to be a clear authority who picks up the pieces.
What else is going on here?
Along with some languages changes that are more tweaks, the state is proposing change the "shall" to "may" on the two step application process (see the beginning of 1.04); I can imagine someone coming back with a "streamlined" process which probably isn't good. There's a bit more clarity of notification of district superintendents on applications for charters (and such) throughout the changes. They've also broadened--and I see SoKA in this one, too--what is required in the application for a charter.
But goodness gracious, look at what is going on in section 6 of 1.04!

(d) Should the Board elect to award fewer than the number of charters specified under M.G.L. c. 71,  § 89 in any given cycle, the Board may grant those charters not awarded in subsequent  application cycles in addition to the number of charters scheduled to be awarded and  notwithstanding any limitations on the number of new charters authorized in such year.  

(e) The Board may award any charter revoked or returned to the Board in subsequent application  cycles in addition to the number of charters scheduled to be awarded

So, they could not grant any this year, but "save" those charters to be granted next year. This sounds to be like a face-saving move; if they have only applications they don't want to grant, they don't have to go the route they did with Gloucester Arts and SoKA and give them to the "least worse" of the applicants, but just save those charters until the next year, without--heaven forbid!--looking somehow anti-charter school.
Likewise, it looks to me as though (g) in that same section is to give clear guidance around applications like the one from Lynn the same year as SoKA that smells a lot like a private school conversion.

Here's the bit we REALLY need to pay attention to:
Section (9) of 1.04 deals with the very important question of where new charters go. They're proposing a switch from a straight math/ELA MCAS calculation to one that uses MCAS CPI for math/ELA/science, percentage advanced, percentage failing, and student growth.
Yes, it is all MCAS scores. And one assumes we're going to be scrambling like mad if we make a switch to PARCC.
Good news, first: it isn't a silly "who does best on MCAS" ranking, which is, and will always be, a great reflector of "who has the highest income," thus telling you little about the school system. They're actually including student growth!
But--bad news--only as a quarter of the measure, with the rest of it remaining plain ol' MCAS lists.
Thus, in the interest of not making the perfect the enemy of the good, here's a good place to praise the inclusion of student growth--which still reflects family income, but not as exactly--but push the Board to make it more than a quarter of what is considered. It would, from calculations I've seen, substantially change what communities are targeted.

Also, new requirement for charter schools:

 A charter school must develop a plan that includes deliberate, specific strategies the school will use to attract, to enroll, and to retain a student population that is demographically comparable to similar grades in schools from which the charter school enrolls students. Charter schools shall submit recruitment and retention plans for approval by the Department that meet the requirements of M.G.L. c. 71, § 89; 603 CMR 1.05; and any guidelines issued by the Department.

I'd be interested in how they're going to enforce those.
There's also a long section on the responsibilities of the Board of Trustees (1.06) and staff. Also  a proposed change in funding to monthly rather than quarterly payments, and those will be in line with monthly enrollment reports from the charter school (only the initial payment will be based on projected enrollment).  They're also pushing hard on solid numbers on enrollment, which is overdue.
Regardless of dates, you can always write to the Board, and, should there be anything you hope I'd include, please let me know!