A year after using low enrollment to justify school closures, the Denver Public Schools Board of Education is expected to consider a policy that would prohibit district officials from using enrollment numbers for future recommendations.

The proposed policy suggests — as DPS officials have warned for years — more closures are coming, but new guidelines will be used to decide which schools will close.

“The Board of Education believes it is necessary to consolidate and unify schools to maintain the financial viability of the district and to maximize the resources, staff, and programs offered to students,” district officials said in a draft of the proposed consolidation policy.

“With respect to unifying and consolidating schools, the Superintendent shall not fail to take reasonable steps to ensure maximum use of resources, staff, and programs offered to students while continuing to support schools where viable and consider consolidation when necessary and closure as the remaining viable option.”

The policy appears to represent a shift away from using low enrollment to rationalize closing a school.

If approved Thursday, the policy would create “guardrails” around why the superintendent recommends schools for closure. Among others, these include:

• Not creating a “bright line criteria” that relies on enrollment minimums.

• Not using standardized test scores as a condition for consolidation or unification.

• Should not identify a disproportionate number of schools with greater percentages of students qualifying for free or reduced lunch, multilingual learners or students with disabilities or that which will “exacerbate segregation based on student race, economic class and language.” (Eligibility for free and reduced-price meals is widely used as a poverty indicator.)

The proposed policy would require that the superintendent ensure the board understands the financial and program implications of declining enrollment before making closure recommendations.

The superintendent should also present recommendations to the board before Oct. 31 for the following school year, the policy states.

The new guidelines are clear about what the superintendent shouldn’t do when closing a school, but not as clear about the criteria that should be used to decide which schools to close. The new policy only says that the superintendent should engage with other school districts to learn from their successes and failures.

The district’s enrollment has been falling since hitting a peak of 93,815 in 2019. In the October count last fall, the district had 88,235 students enrolled — a 6% decline over the past five academic years.

But enrollment in elementary schools — which can be an indicator of future trends — has been dropping for the past decade. DPS had 43,851 students enrolled in primary school in 2014, a 2022 district report shows.

Last school year, district officials defined campuses with a “concerning enrollment” as those with fewer than 215 students. And those with “critically low enrollment” as having fewer than 120 students.

Last March, board members tearfully voted to close three schools, each with an enrollment of less than 150 students. Those schools were: Denver Discovery, Mathematics and Science Leadership Academy and Fairview Elementary.

In November, the board decided against closing a fourth school, Academy 360, a low-performing elementary charter school.

District officials had identified 15 elementary and middle school campuses most affected by student declines. Seven of the 15 schools required instruction in English and Spanish, an indicator students have greater needs that require additional resources.

At the time, the district had 38 schools with fewer than 215 students, the threshold indicating a concerning enrollment level.

An advisory committee report on declining enrollment two years ago suggested the criteria for closing schools include schools with critically low enrollment that are unable to provide programming without budget assistance and those that are not financially solvent.

The district expects its K-12 enrollment to continue to slip. This, despite the influx of new immigrant students — many who crossed the U.S. border illegally with their family — who have, temporarily buoyed enrollment.

Nearly 10% of schools this school year, or 20 campuses, have fewer than 215 students and nine with less than 120, district data shows.

Enrollment is a critical issue for school districts because it’s tied to state funding. Schools get a certain amount of funding per student. Lower birth rates, skyrocketing home costs and gentrification are the biggest factors driving enrollment declines as the city’s demographics shift.

The unparalleled growth in the number of schools under former Superintendent Tom Boasberg also may be to blame.

In 2008, a year before Boasberg took the helm, DPS had roughly 75,000 students and operated 146 schools. A decade later, DPS had added nearly 17,000 more students and 61 schools.

“Boasberg was like Oprah Winfrey, handing out schools left and right,” Andrew Lefkowits, co-chair of the Park Hills Neighbors for Equity in Education, has said. 

“We have too many schools.”

Formed in 2017, the group’s mission is to raise community awareness about school inequities.

Because of something called “smoothing,” the district hasn’t really begun to feel the economic pinch. For districts with declining enrollment, smoothing involves averaging the student population from the five previous school years to determine the funding allocation. Higher enrollment numbers in previous years means DPS has received more funding than the actual students would dictate.

Consider this school year: DPS had 83,222 students for the count in October, but Colorado funded DPS for 84,848 students, which is a five-year average. This “smoothing” resulted in the district receiving about $20 million more for students not actually enrolled in DPS, said Chuck Carpenter, the district’s chief financial officer.

“As our enrollment goes down and levels outs, we will be in a situation where we have the same number of kids, but our revenue is going to start dropping,” Carpenter has said.