STANDARDS FOR ADEQUACY
The policies used to determine the size or adequacy of playground space are not codified in one place but are found in several different NYC Department of Education documents. With the recent restructuring of the New York City Department of Education by Mayor Michael Bloomberg, several offices and divisions have been merged. Since the reorganization, the School Construction Authority has the primary responsibility for school facilities and construction. The Office of School Facilities, NYC Department of Education was formerly the primary office to monitor school facilities. In 1994 the Division of School Facilities, Office of Capital Administration issued a document, “Standard Space Requirements – Primary and Intermediate Schools” which included guidelines for space regulations for outdoor playgrounds in NYC public school facilities. Though the document incorrectly states, contrary to state law, that playgrounds are not required in New York City, the document does set a “preferred minimum” for size and space recommendations for playground size. The document does not define “adequate” playground space, but sets the preferred minimum for size of outdoor playgrounds.
“Playgrounds are not mandated requirements. However, they are highly desirable for health and educational purposes. The BOE preferred minimum square footage is:
- A fenced 3,000 square feet early-childhood playground for schools with LYFE centers, pre-kindergarten, and/or kindergarten classrooms.
- A playground with an area of 30 square feet per pupil to a maximum of 30,000 square feet for primary and intermediate schools.
- The area assigned to playgrounds (e.g. 30,000 square feet) includes the 3,000 square feet of the early -childhood playground, if any. For instance, an 850 pupil school will be programmed for a playground of 22,500 square feet (850×30=25,500 minus 3,000 = 22,500)”16 [Emphasis added.]
Similarly, the Division of School Buildings of the New York City Board of Education, a predecessor of the Office of School Facilities, issued two other documents in 194717 and 197518 each entitled “Manual of School Planning” suggesting the same guideline for space size for outdoor playgrounds. In both documents the same formula for square footage per pupil was reiterated.
When designing new schools with outdoor play areas in New York City, architects are provided with requirements for new buildings indicating the same standard noted earlier: 3,000 square feet for Early Childhood playgrounds, and 30 square feet per pupil with a maximum 30,000 square feet for primary schools.19
NO CITY PROCESS FOR TRACKING ADEQUACY STANDARDS
While fairly specific NYC Department of Education standards define outdoor space requirements, the Department is unable to calculate whether each school meets the standard. Unfortunately, school officials do not have verified or up-to-date data on the square footage for each school playground. The Department does have verified and up-to-date data on enrollment. Thus, calculating the number of pupils in each school is possible. However, the only data available within the Department of Education indicating the square footage of buildings, the square footage of playgrounds along with the square footage of total site areas and building square footage is 15 year old and unverified.
Staff at the School Facilities division of the Department expressed caution about the reliability and use of the 15 year-old data. In light of that, Committee staff visited targeted school sites to “test” the data. Our experience confirmed the concerns raised by DOE staff that the 15 year-old data is inaccurate. As a result, Department of Education data cannot be used to assess compliance with its own standards for outdoor space because only half of the formula, the pupil enrollment, is available.
In recent weeks the Department of Education has made attempts to collect data by issuing a survey to regional plant managers about the availability of physical education facilities in schools throughout the system. The survey was a minimal attempt at answering questions of whether schools have playground space, operational physical education equipment, pools, athletic fields, etc. The survey required only a ‘Yes’ or ‘No’ response. Staff from our Committee, again attempted to “test” the data. The Committee found several schools responding affirmatively to having playground space available for recreational activities when our on-site visits told a different story. Though NYC Department of Education officials made this attempt to collect data on physical education facilities, the survey instrument was very limited and superficial in scope and apparently not verified. The City should continue in its efforts to pursue collection of accurate and verifiable information.
Most recent contact with School Construction Authority staff requesting data on specific schools was also met with the same inability to provide accurate information on square footage of school properties and facilities. Though requests were made, SCA officials did not provide the requested information of outdoor playground space size and dimensions.
NYC DEPARTMENT OF EDUCATION INSTALLS TEMPORARY CLASSROOM UNITS ON OUTDOOR PLAYGROUND SPACE
For schools suffering severe overcrowding in specific school grades, Temporary Classroom Units are installed on or near the school grounds to ease the overcrowding in the classroom. See photo of P.S. 276 in Brooklyn on the prior page. TCUs are approximately 1,200 square feet with adequate space for two classrooms housing 26 students in each. The agency responsible for overseeing the installation of these structures is the School Construction Authority. SCA officials concede that placement of these units is primarily on available playground space since often that is the only space available to schools within New York City. SCA officials further concede that even though available playground space is inevitably lost in the decision, overcrowding of academic classroom space takes precedence as the criteria for placing these TCUs. It appears that the primary concern when evaluating the feasibility of TCU placements by City Education officials is to address the need for more classroom space for academic learning, rather than the resulting loss of space for physical education curriculum and programs. SCA does seek to ensure that installation of the units complies with New York City building, fire and safety codes and regulations.
As of November 2002 there were 249 TCU units in 103 elementary schools in New York City. School data reveals that some “temporary” classroom units remain for as long as eight years. For example, P.S. 19 in Queens has had a TCU since 1995. TCUs are removed when overcrowding ceases or are relieved by construction of an addition or renovation of a school building providing the needed classroom space. Committee research uncovered no discernable process in writing or practice at DOE where loss of outdoor playground space is considered, let alone overrides a decision to place TCUs in overcrowded schools. School Construction Authority officials informed us that 40 TCU units were removed in recent years, however, those removed were just transferred onto other school playgrounds to relieve overcrowding in those schools.
As noted earlier, Committee staff visited elementary schools in each of the five Boroughs. A total of 36 schools were visited over a four month period of time. The primary purpose of these visits was to “test” the City data concerning playground space. The visits also provided anecdotal information about TCUs and their placement on school playgrounds. The pictures included in this report were another product of these on-site inspections.
The visits revealed numerous examples of schools where the playground space was lost to TCUs and sometimes also parked cars. Virtually the entire playground area was filled with TCUs at PS 276 in Brooklyn. A school official at the school subsequently confirmed that there were “no useable outdoor facilities” for the older children (1st through 5th grades). Thankfully, there was space set aside and available for the Pre-kindergarten and kindergarten population. Other schools in Brooklyn had TCUs in the school yard but also, fortunately, had play areas of significant size, such as PS 32.
PS 96 in the Bronx showed a large portion of the schoolyard filled with TCUs. According to SCA and DOE documentation, there are 11 TCU units on that site. While there is remaining “open” space in between and in front of the TCUs at this location, a school official advised that “there is very little room” for recreation and no equipment available for the kindergarten population. The following is a picture of two of the TCUs on that site.
Manhattan has two schools with TCUs. Each of the schools contains two TCU units. One of these school playgrounds also contained parked vehicles, further eliminating playground space. In PS 5, TCUs took up an entire area that was once available for outdoor recreation. An area remains, however, which provides a rubberized floor and some minimal equipment. Another area of the school provides playground space for the kindergarten population. PS 163’s entire school yard is taken up with TCUs. Right next to the school, however, is “The Happy Warrior”, an adjacent alternative playground. This type of Jointly Operated Playground is more fully discussed in the next section. The following photos illustrate the TCUs on the site and the signs showing the adjacent park space available to students during school hours.
Sites visited in Queens provided yet other examples of TCU filled playground space with varying amounts of remaining playground space still available. At P.S. 19, mentioned earlier as housing one of the oldest TCU units on a playground site, faces such severe overcrowding, a school staff person told us bathrooms and hallways are used for storage in some places of the school building. The following shows images of TCU units in the school playground used for classroom space. It should be noted that while there are TCUs at PS 19, there is still other playground space available.
No TCUs are located in any elementary school in Staten Island. All of the schools visited had significant outdoor play space (PS 56, 60, 44 and 32), and many had state of the art playground equipment. One of the schools operated with a JOP (PS 6). The picture below on the next page is one example of a Staten Island school.
SED provides no oversight of TCU placements on school grounds in New York City. Arguably installation of TCUs on school grounds could be viewed as an erection, remodeling or construction on a school site as referred to in Education Law §408(3) and, hence, subject to SED oversight.
“(3) The commissioner of education shall approve the plans and specifications, heretofore or hereafter submitted pursuant to this section, for the erection or purchase of any school building or addition thereto or remodeling thereof on the site or sites selected therefore pursuant to this chapter, if such plans conform to the requirements and provisions of this chapter and the regulations of the commissioner adopted pursuant to this chapter in all respects; provided, however, that the commissioner of education shall not approve the plans for the erection or purchase of any school building or addition thereto unless the site has been selected with reasonable consideration of the following factors; its place in a comprehensive, long-term school building program; area required for outdoor recreational activities; educational adaptability, environment, accessibility; soil conditions; initial and ultimate cost.” [Emphasis added]
SED, as stated earlier, precludes its ability to review and approve such plans and specifications for New York City schools by accepting only outlines. This has the secondary effect of precluding review and approval of TCU installations and in turn, considering the further loss of available outdoor recreation space. Once again, the Commissioner’s response:
“Our Office of Facilities Planning reviews the outlines but cannot perform a programmatic review that would determine if the amount of planned outdoor play area is adequate”.20
State regulations and state law bestow authority on SED to oversee that adequate space be provided. The installation of TCUs on outdoor playground space reflects on the loss of outdoor playground space and, therefore, clearly fits within the provisions of the statute requiring State Education Department oversight.
When insufficient space exists for outdoor playground facilities at NYC schools, New York City officials sometimes provide Jointly Operated Playgrounds (JOP). The NYC Department of Parks and the NYC Department of Education jointly operate a shared park space, allowing for outdoor physical education curriculum activities to take place. These joint facilities are also available to schools that may already have playgrounds, but are fortunate to be located nearby to parks or facilities of this type operated by the Department of Parks. These sites are generally shared with the public but are limited to school children, teachers and school personnel during school hours.
As of October, 2002, there were 285 schools that participate in the JOP program, with 385 total acres of parks, athletic fields, gardens and land involved. The JOPs exist in all five boroughs of the City. Though staff of the Department of Education was unable to provide actual contracts or agreements executed between schools and the parks, City Education officials reported that the Parks Department staff maintains these areas with upgrading, cleaning, renovation and upkeep with school custodians having no responsibility for cleanup or maintenance. The JOP facilities may have athletic fields with large areas for teams sports to occur; asphalt areas in playground space for basketball, shuffleboard, volleyball etc; areas with playground equipment, such as slides, climbing apparatus, see-saws; and benches near paved or unpaved areas where recreational activities take place.
These facilities clearly provide excellent opportunities and options for outdoor play areas, especially for those schools that have insufficient outdoor space for recreational programs. For this option to be available, a school must be located in near proximity to a park. Thus, the JOP program is a potential for only some schools; it clearly is not the answer for all schools in need of playground space. The program should be nurtured, expanded and schools presently unconnected to nearby parks should be encouraged to develop these relationships. In other areas, these kinds of shared situations with community organizations or civic groups with available space should also be encouraged.
The collage above shows both TCUs placed in school playgrounds at P.S. 106 (Bronx) and the alternative playground, run jointly by City Parks and City Department of Education that is provided as an alternative for these students.
Though recent reports from DOE indicate an enhanced relationship with DOP on physical education activities for NYC school children and families, none of the recent initiatives speak to furtherance of the JOP program through establishment of more JOP sites. Enhanced physical education programming is good, but the physical infrastructure is a prerequisite for any programming to be possible.
Source: No Room in the Playground – A Report Examining Playground Space in NYC Elementary Schools