Dear Messrs. McConnell and Everett:

Enclosed is the study of the supervisory districts in Steuben, Allegany, Schuyler, Chemung and Tioga counties prepared by Drs. Geoffrey Davis and Lawrence Kiley that fulfills the requirements of Education Law § 2201. In commissioning this study, I requested that the investigators examine a possible reorganization of the Steuben-Allegany BOCES with respect to six areas that are outlined on page six of the report.

In reviewing the findings of the study, I make the following observations:

Educational Benefit: Although both BOCES have a significant array of instructional and support services, future services will be limited by their high costs and declines in enrollment base of both BOCES. These trends will make access to services by smaller districts more and more dependent on the larger districts in the two BOCES, particularly Elmira in the Schuyler-Chemung-Tioga BOCES and Corning in the Steuben-Allegany BOCES. Already there is evidence of such vulnerability in the region with the Schuyler-Chemung-Tioga BOCES eliminating a much needed alternative education program as a result of the withdrawal of Elmira from the service.

Cost-Saving Benefits: The study concludes that a merger of the administrative structures of the two BOCES could save up to $800,000, based on 2001-2002 audited data. Every district in the two BOCES would benefit from this cost reduction. The study also concludes that such savings comes from combining administrative overhead, not from consolidating instructional programs. This is an important finding and an important direction for education in New York State.

Workforce Development Implications: Business and government leaders in three of the counties under study clearly are concerned about the region’s economic future and are working to build a common workforce development system. Even while this study was being conducted, a major employer in the Elmira area announced a plant closing affecting the employment of 800 people. One key to future economic development in the region is a strong, vibrant workforce. BOCES throughout New York State have played a critical role in preparing both youth and adults to meet employer needs. The current organization of the two BOCES serving the region does not result in a large enough entity to be considered a regional workforce development force. A merged BOCES, with proper programs, would have the potential to be a significant asset as business and government leaders seek to rebuild the region’s economy.

Academic Standards: BOCES instructional support, such as staff development and school improvement services, is critical if schools are to meet the State learning standards and close the gaps in student academic performance. The study indicates that such services at the Schuyler-Chemung-Tioga BOCES are "…in a state of transition." It also documents that nearly half of the instructional services at the Steuben-Allegany BOCES are cross-contracted. Although it is recognized that the Steuben-Allegany BOCES has recently taken steps to offer more instructional support services, this area appears to be vulnerable. Given the number of small, low-wealth districts in the region, questions remain about the long-term ability of the two existing BOCES to offer needed instructional support services.

District Superintendent Responsibilities: The study concludes that a single superintendent could manage a merged BOCES and provide needed attention to all 21 districts. Our experience throughout the State supports this conclusion, since 11 BOCES have 21 or more component districts.

Other Factors: There are two critical factors that the study cites: geography and readiness. The geography of a merged BOCES would be 2,144 square miles; six other BOCES would be larger. Therefore, savings from merging the instructional programs or consolidating the three educational centers will not materialize. However, administrative savings would not be affected by the geography. The second factor, readiness in the region for a reorganization, is of greater concern. The investigators give significant weight to this factor. In fact, they suggested postponing reorganization until a greater level of readiness is built.

Given these observations, I conclude that a merger of the Schuyler-Chemung-Tioga and the Steuben-Allegany BOCES would promote the educational interests of the region. Such a merger would save administrative costs in a time of very tight budgets, would serve the workforce development interests of the region and would, in the long-term, create a large enough enrollment base to allow for both program stability and growth. Furthermore, a single District Superintendent could effectively supervise the merged operations and provide support to component districts.

However, there may not be a readiness in the region to make such a merger successful immediately. Readiness must be built from the ground up by local leaders. I am confident that leaders in the two BOCES have the creativity and inventiveness to develop solutions. Therefore, I am taking the following steps:

I want to thank Drs. Davis and Kiley for their work on the study. I also want to thank the Board members, administrators and staff for their assistance in providing information for the study. I believe that the study has identified a challenge that can be met by leaders in the region; that is, to create a strong, powerful regional educational and workforce development entity that will be administratively cost-effective and instructionally rich. I look forward to meeting with local leaders on November 23 to discuss how to meet this challenge.

Please note that the study and my accompanying letter are available on the website of the Department’s Office of Elementary, Middle, Secondary and Continuing Education website, www.emsc.nysed.gov, thereby allowing for the widest possible dissemination to the public of these crucial issues and timeframes.

	Sincerely,
	Richard P. Mills

Enclosure