Inside the EIA

Every page of the EIA carries a large "DRAFT" watermark — including the version attached to the official Notice of Public Hearing filed for the May 28, 2026 hearing. A document filed to satisfy a legal requirement under AB 1912 was never finalized before being used as the basis for a vote on permanent school closures.

The public notice PDF is named NOTICE_OF_PUBLIC_HEARING_-_EQUITTY_IMPACT_ANALYSIS.pdf — with a double-T in "EQUITTY." The cover page of that same notice misspells "DISTRICT" as "DISTRCIT." These are not minor issues in a legal filing.

Section 3.3.6 is titled "Marhsall Secondary School" — a transposition error in the name of the school whose closure is being analyzed.

The document's author metadata lists Joseph Pandolfo of Total School Solutions. TSS is the same firm named in the Brown Act Cure and Correct demand letter for pre-contract coordination with Board President Fredericks. TSS's principal advised Fredericks in November 2025 to route communications through an attorney to avoid public records exposure — two months before TSS was formally hired. The firm tasked with producing an independent equity analysis is the same one whose independence has been formally challenged.

Appendix E — listed in the table of contents as supporting source material — consists of a single hyperlink with the text "Click Here." There is no label identifying what the link leads to, no archived copy, and no way to verify the document is still available or that it matched the version used in the analysis. A legal filing that relies on external links instead of attached source documents provides no stable evidentiary record.

The EIA's own conclusion (p. 83) characterizes the SCAC's rejection this way: "The committee ultimately voted not to recommend closure at this time, citing process concerns as well as substantive questions about timing and community trust."

The SCAC did not cite "timing." They cited data inconsistencies and a compromised process. Characterizing those findings as "timing and community trust concerns" materially understates what the committee actually said — in the same document that records what they said.

The EIA presents three closure scenarios for Blair High School. For Option 2C, the document states directly: "a detailed financial analysis was not created for this scenario." Option 2C is included in the recommendation without the financial analysis that the other scenarios received. A school closure scenario with no financial analysis is not analysis — it is a placeholder.

Don Benito and Webster's savings tables show refuse service reduced by 50%. When a school closes, refuse service does not decrease by half — it approaches zero. A 50% reduction assumes the school continues operating at half scale. For a closure, refuse savings should be near 100% of current cost, not 50%. This understatement, applied uniformly, reduces the apparent accuracy of every savings total.

Don Benito's "Other Classified Salaries" line is labeled: "Est. for Food Service, Child Dev., Gardening." Three distinct employee categories — food service workers, child development staff, and groundskeepers — are combined into a single estimated line item with no breakdown. Each category has different FTE counts, different seniority rules, different placement options at receiving schools, and different union agreements. Treating them as one number obscures whether any of those savings are achievable at all.

The savings tables produce totals stated to the dollar: Norma Coombs $708,456; Blair High $1,753,244. These figures are derived from inputs including: round-number utility estimates ("$30,000, partial, estimated"), unsourced percentage assumptions (40%, 50%), single flat numbers covering multiple job categories, and in Norma Coombs' case, a missing row. Presenting results to the dollar implies a precision the underlying methodology cannot support.

TSS writes: "reductions in FTEs do not necessarily mean employment will be terminated." Under California seniority rules, laid-off employees often bump into positions at other schools. The projected salary savings assume staff elimination, but the actual outcome may be redistribution — with costs following staff to receiving schools. TSS acknowledges this but proceeds to present salary savings as if the distinction doesn't affect the bottom line.

Section 8 acknowledges that closing schools will increase transportation costs. The district's annual transportation budget is listed as "$6.7 million to $7.2 million annually" — a $500,000 range, not a precise figure. Every school's savings table excludes transportation entirely. The savings numbers are gross, not net. No scenario models the financial impact after transportation increases are factored in.

The EIA mentions one-time costs in one place: Don Benito's International Baccalaureate program transition, estimated at "$20,000 to $40,000" for teacher training. There is no analysis of one-time moving costs, IT infrastructure reconfiguration, legal costs, communications costs, enrollment processing costs, or staff transition costs for any other school. The absence of one-time cost analysis means the document cannot answer the basic question: how many years until the district recoups the cost of closing a school?

When a school closes, families leave the district. Average Daily Attendance drives state funding. If even a fraction of displaced students transfer to private schools, charter schools, or neighboring districts, the district loses the per-pupil ADA funding associated with those students. No closure scenario includes a projection of ADA funding loss. Net savings could be substantially lower than projected — or negative.

The EIA uses current-year figures as the baseline and explicitly states on pp. 21 and 29 that numbers "will be updated when the FY 27 staffing and budget numbers are available." FY27 numbers were not available at filing. They were never incorporated. No sensitivity analysis accompanies the figures. TSS filed preliminary estimates labeled as such and the district proceeded to schedule a public hearing around them.

If McKinley 6–8 students are redirected to Eliot Middle School, the table lists Eliot's capacity as "NA." Eliot was damaged in the Eaton Fire and has not been rebuilt. The scenario is presented as viable with a receiving school that does not currently exist as a functional facility.

Section 4's capacity calculations apply a 20% reduction to the number of usable classrooms at receiving schools to account for specialty rooms, offices, and non-instructional space. This assumption materially reduces calculated capacity. The 20% figure is not sourced to a state standard, a facilities assessment, or a district policy. It is a methodological assumption that quietly reduces every receiving school's available capacity without explanation.

The state standard for calculating school capacity is 27 students per classroom. TSS uses the PUSD local standard of 29.75 students per classroom for John Muir's capacity calculation. Using the higher PUSD figure increases John Muir's apparent capacity. Applied to 60+ classrooms, this choice adds 150+ students to John Muir's listed capacity compared to the state standard. This is not disclosed as a methodology choice — it is embedded in the table.

The EIA's facility analysis is based on the 2023 FMP. TSS acknowledges (Section 2.7) that a new FMP is planned for completion in 2027. The document being used as the facility data foundation will be superseded before most of the proposed closures would take effect. The EIA does not flag this as a data reliability concern.

Section 2.7 of the EIA acknowledges: the FMP's probable project costs "may partially reflect staff advocacy" — meaning the cost estimates in the document TSS is using for financial analysis may be inflated by the preferences of the people who compiled them. This admission appears in a subordinate clause and is not carried forward into any of the financial projections that rely on FMP data.

The EIA explicitly acknowledges that closures will increase transportation costs. The district's annual transportation budget is "$6.7 million to $7.2 million annually" — a $500,000 range. No closure scenario includes a projected transportation cost increase. The net financial impact after transportation is unknown from this document.

Figures 8.1 through 8.7 show scatter plots of current student addresses against walk-distance rings (15 and 20 minutes) around receiving schools. Across all scenarios, the majority of dots — representing displaced students — fall outside the walk-distance zones. The maps make the transportation burden visually apparent. The savings tables ignore it numerically.

Section 8 repeatedly notes that PUSD is a "district of choice" — meaning parents voluntarily select schools — as a reason the transportation burden is manageable. This framing does not apply to families whose school is being closed. A parent who chose their neighborhood school did not choose to commute to a receiving school three miles away. The distinction between voluntary choice and forced reassignment is not addressed.

The EIA states directly: "students who currently reside near McKinley School (6-8) would have a much longer distance to attend school." This acknowledgment appears in the transportation section with no corresponding cost estimate in the financial section.

Section 5 uses "may," "could," "might," "would likely," and "is anticipated" throughout. These are not plans. Families of students in specialized programs — IB, Armenian Language, special education, GATE — cannot plan around "may continue." AB 1912 requires an analysis, not a list of possibilities.

Section 5.9, which is supposed to analyze a specific program category, consists of two sentences that direct readers to "see Section 5.8 and 5.7.3." No original analysis is present. This section is incomplete.

TSS's finding regarding the McKinley demographic concentration: "PUSD will need to work with these families to select an alternate school and discuss transportation options to ensure a successful transition." No transportation funding commitment. No enrollment guarantee. No specific mitigation plan. The Attorney General guidance calls for "funded busing, transportation reimbursement, and/or bus passes" — none of those appear as commitments anywhere in the document.

Section 8.4 concludes closures "would not be discriminatory." This conclusion is reached while (a) acknowledging McKinley has the district's highest African American student concentration, (b) acknowledging those students would face longer travel distances, (c) providing no funded transportation plan, and (d) citing open enrollment as sufficient mitigation. The Attorney General's guidance specifically warns against this reasoning.

Section 6 uses a 2014 Beacon Economics report as its primary source for environmental and neighborhood impact analysis. This report predates the 2017 and 2020 enrollment declines, the COVID-19 pandemic, the Eaton Fire, and the significant demographic shifts that have reshaped the Pasadena area since 2014. A 12-year-old economic report does not accurately represent the current community context for a school closure decision in 2026.

The EIA's conclusion cites "bond program savings across multiple scenarios could reach tens of millions of additional dollars." Bond funds approved by voters for specific schools are not discretionary savings. Redirecting them requires analysis of bond covenants, legal constraints, and potentially voter approval. None of this is discussed in the EIA.

Item 10 of the Fiscal Stabilization Plan projects $24,000,000 in personnel reductions through 120 FTE eliminations, beginning in FY26–27. The EIA's savings tables project salary savings from closing schools in the same fiscal years. If the district is already planning 120 FTE reductions regardless of school closures — as the FSP requires — then the school closure savings from those same salary lines may not be additive. The EIA does not reference the FSP personnel reduction plan anywhere in its financial analysis.

The Budget Adoption presentation (June 26, 2025) includes Multi-Year Projection charts showing the General Fund unassigned/undesignated balance. Even with the full Fiscal Stabilization Plan implemented and nearly $100 million in Eaton Fire insurance revenue included, the 2025-26 Adopted Budget projects the unassigned reserve to be approximately +$2 million above required levels in FY26–27 — a nearly zero margin — and negative $63 million below required levels in FY27–28. The district's own slide states: "As it stands, substantial additional reductions will be necessary." The EIA's projected school closure savings — roughly $4–6 million per year across all scenarios — would address less than 10% of the projected FY27–28 reserve shortfall. The closures cannot solve the structural problem the district's own documents describe.

This conclusion is stated despite: (1) McKinley's documented concentration of African American students with no funded transportation mitigation; (2) capacity overflows at receiving schools with no mitigation plans; (3) an Eliot Middle School receiving school that doesn't exist post-Eaton Fire; (4) transportation costs explicitly excluded from all financial projections; and (5) the SCAC's unanimous rejection citing data inconsistencies and a compromised process.