Point-by-Point Contradictions & Omissions of the “Impact Statement” of RCS Closure & Merger of Coalton into TWES, Closure & Merger of Midland into Beverly School

An evidence-driven assessment identifying the procedural, legal, and constitutional noncompliance embedded in Randolph County Schools’ proposed school closures.

Executive Summary

The closure proposal issued by Randolph County Schools for Coalton Elementary and Midland Elementary – drafted under the direction of Superintendent Dr. Dilly – fails to meet the legal standards required under West Virginia Code §18-5-13a and WVBE Policy 6204. The application lacks the critical analyses these laws demand, draws upon incomplete and inconsistent data, and dismisses the foreseeable consequences such actions will have on children’s education, health, and overall well-being.

In doing so, the plan directly contradicts core provisions of the West Virginia Constitution, including Article XII §1, which guarantees a thorough and efficient system of free schools; Article XII §4, which ensures the Irreducible School Fund is used to support those schools; and Article III §1, which protects life, liberty, happiness, and safety. It further violates the Equal Protection principles established under Article III §10 and the Fourteenth Amendment of the United States Constitution.

Rather than providing the transparency required of a public institution on the RCS Closure & Merger of Coalton into TWES, Closure & Merger of Midland into Beverly School, the district’s so-called “Impact Statement” conceals the facts, misleads the community, and leaves the official record both incomplete and unreliable.

Point-by-Point Contradictions & Omissions within the Randolph County Schools “Impact Statement” Regarding the Closure and Merger of Coalton Elementary into Third Ward Elementary, and the Closure and Merger of Midland Elementary into Beverly Elementary

1) Required Alternatives Analysis: Missing or perfunctory

What they put: a generic claim that consolidation “saves money.”

The truth:

• 18-5-13a (b)(3) and Policy 6204 §3.2 require a comparative alternatives study with transparent fiscal tables. No such table exists. There is no accounting for: trimming central-office FTEs (8.5 positions averaging $80 K each (WVDE 2021)), shared-specialist or grade-band models, co-use/community-hub options, or offsetting costs new bus runs, fuel, driver overtime, additional supervision, utilities, or itinerant-service mileage.

Without a net fiscal analysis, the “savings” narrative is speculative. When total transport and staffing costs are included, districts typically recoup less than 10% of projected savings after consolidation (West Virginia Policy Center, 2023).

This is not fiscal necessity it’s discretionary harm –

2) Transportation Time & Safety: Understated and under-analyzed

What they put: Third Ward is “reasonable distance -”

The truth:

Coalton-area children will ride 75–90 minutes each way on narrow, two-lane mountain roads subject to black-ice and fog conditions (WV DOT Planning Fact Sheet 2023). That equals 2.5–3 hours of daily travel for children as young as 5.

Policy 6204 (b)(5) requires evaluation of ride time, terrain, and safety; none appears. Research shows commutes over 60 minutes correlate with higher absenteeism and lower GPA (NCES, 2022). In winter months, these buses will leave before sunrise and return after sunset, increasing accident risk (CDC Traffic Safety Facts, 2023). For small children, this isn’t “reasonable” – it’s hazardous and developmentally inappropriate.

3) Daily Schedule Math they ignore

What they put: “Minimal disruption.”

The truth:

A 75–90 minute bus requires wake-ups around 5:00–5:30 AM; first pickups earlier. Evening arrivals near 5:00–5:30 PM leave narrow windows for homework, meals, hygiene, and rest. Typical homework load for grades 3–5 averages 60–90 minutes nightly (NCES, 2021). Pediatric sleep guidance recommends 9–12 hours/night for ages 6–12 (American Academy of Pediatrics [AAP], 2016). To be rested by 5:15 AM, bedtime must fall around 7:15–8:15 PM – colliding with homework, family time, and any extracurriculars.

Sleep restriction of even 1 hour/night impairs attention and memory comparable to missing an entire day of instruction (CDC Sleep and School Performance, 2022). Chronic loss raises anxiety and depressive symptoms by ~60% (CDC Youth Risk Behavior Survey [YRBS], 2023). This schedule mathematically guarantees cognitive fatigue, emotional dysregulation, and academic decline.

4) Extracurricular Access & Tutoring: Unsupported assurances

What they put: Activities remain available.

The truth:

There are no late-run buses, no parent-transport feasibility study, and no tutoring-time plan.

Tutoring: After-school RTI and Title I programs occur 3:15–4:15 PM. Coalton transfers leaving at that hour cannot attend. Morning help: impossible; first buses arrive just before start bell.

Special education & therapy sessions: travel gaps cut into service minutes, breaching IEP fidelity (WVDE OSEP, 2023).

Research shows that students who lose access to extended-day support experience a 0.25–0.3 GPA drop within one semester (RAND Education, 2020). Thus the closure would systematically strip remedial and enrichment time – a denial of equal educational opportunity under Pauley v. Bailey (1984).

5) Sports Feasibility & Social Development: Functionally eliminated

What they put: “Students can still participate.”

The truth: Practices often run 4:00–5:30 PM, 5:30–8:30 PM, or in fixed evening blocks (e.g., Elkins Little League 5:30/6:30/7:30 PM; basketball 5:30/6:30/7:30 PM; soccer 5:30/6:30 PM). Coalton students arriving home at 5:30–6:00 PM cannot safely attend, eat, do homework, and meet 9–12 hour sleep guidelines (AAP, 2016). It is mathematically impossible –

Physically active youth are 23% less likely to report depression (CDC, 2023). Removing sports access correlates with increased loneliness, bullying exposure, and self-harm risk (NIH Adolescent Health, 2022). Isolation of rural students without after-school contact is a known suicide-risk amplifier (WV DHHR Youth Suicide Prevention Report, 2023). Students who participate in sports average higher GPA and better attendance (Journal of School Health, 2020).

In practical terms: this plan trades mental-health protection and community belonging for a theoretical budget line.

6) Fiscal Assertions: One-sided math

What they put: “Annual savings: $X.”

The truth:

Figures mix years and omit offsetting expenses. Using FY 2020–21 salary data inflates “per-pupil cost” when enrollment counts are 2024–25. No allowance for added bus fuel (up ~38% since 2021, EIA, 2024), driver benefits, receiving-school crowding (portable classrooms, HVAC), or increased wear on vehicles from mountain grades.

Peer-reviewed analyses show rural consolidations often raise per-student costs within 3 years due to transport inflation (Appalachian Education Network, 2020). The math is cherry-picked financially misleading and ethically reckless –

7) Educational Outcomes & Equity: No evidence of benefit

What they put: “Improves efficiency.”

The truth:

Efficiency is not achievement. There are no performance projections demonstrating Coalton students will equal or exceed prior outcomes post-closure. Average class size at Third Ward (per WVDE School Report Card, 2023) already exceeds state average by ~4 students. Adding Coalton’s enrollment increases pupil-to-teacher ratio beyond thresholds cited in

Pauley v. Bailey (1984).

Longer commutes correlate with lower attendance and higher chronic-absence risk (CDC School Connectedness, 2023). The plan reduces educational time while increasing fatigue – violating Article XII §1.

8) Public Health & Mental Health: Completely ignored

What they put: “No significant adverse effects.”

The truth:

Every major health authority contradicts that claim.

Sleep deprivation: chronic loss of >1 hour/night raises depression risk by ~58% (CDC YRBS, 2023).

Extended commute isolation: rural youth riding >60 min/day show roughly double the rates of anxiety and somatic complaints (NIH Rural Health Study, 2021).

Bullying exposure: decreased peer contact time at school and on teams correlates with ~35% higher bullying victimization (CDC School Violence Report, 2022).

Suicide data: West Virginia’s youth suicide rate (ages 10–17) is ~11% higher than the national mean (WV DHHR, 2023); risk rises with chronic stress, fatigue, and social disconnection.

By forcing pre-teens into pre-dawn wakeups, multi-hour rides, and no time for recreation, the district is knowingly intensifying conditions linked to youth self-harm – That omission is not only unethical – it may breach the constitutional duty to safeguard “life and safety” under Article III §1.

9) Constitutional and Civil Rights Violations

What they put: “Complies with law.”

The truth:

WV Const. Art. XII §1 – requires a “thorough and efficient system of free schools”: this plan knowingly reduces instructional time, tutoring access, and health conditions necessary for learning.

Art. III §1 – WV Bill of Rights: guarantees “the enjoyment of life and liberty… and of pursuing and obtaining happiness and safety.” The extended-commute regime endangers both.

Art. XII §4 – Irreducible School Fund: funds must support free schools statewide; diverting resources into redundant transport violates that purpose.

Art. III §10 & U.S. Const. Amend. XIV – Equal Protection: this policy creates a two-tier system – students living near receiving schools keep full academic, athletic, and social opportunity; Coalton students lose them.

Pauley v. Bailey (1984) confirmed equal opportunity as a judicially enforceable right. This closure, based on incomplete data and foreseeable inequity, is a constitutional breach, not an administrative option.

10) Community and Economic Impact: Unassessed

What they put: “Neutral community effect.”

The truth:

Coalton Elementary is the town’s only civic anchor. Closure removes local employment, suppresses small-business traffic, and increases childcare burdens. Parents losing two hours daily to new transport schedules face income reduction or job loss (WVCBP, 2022).

Policy 6204 §3.2(f) requires such impacts be evaluated; none appear. Educational consolidation thus becomes economic consolidation hollowing the community it claims to serve.

What Compliance Should Look Like  and Does Not

• Side-by-side, net-of-cost fiscal analysis including all transport and staffing costs.
• Full transportation modeling: 75–90 min rural routes, terrain grade, weather risk, supervision.
• Tutoring & activity access plan with funded late-run buses.
• Educational-benefit demonstration (class sizes, intervention minutes, measurable outcomes).
• Comprehensive health/safety study per CDC/AAP standards.
• Community-economic impact statement.
• Public-comment transcript + district responses as required by §18-5-13a.

Parent Quote

“A plan that forces 5am – alarms, up to 150 minutes of daily bus time, and no real access to tutoring or sports isn’t ‘thorough and efficient’ it’s the slow removal of opportunity and the erosion of bad, no recoverable mental health issues. Our kids deserve equal time to learn, recover, and grow knowing that their school board has their best interests in heart, not the best interests of money.

I’ve personally spoken with over thirty parents intentionally, across different neighborhoods and “not a single one” believes this plan is rational or humane. Every single one said the same things with different verbiage, such as: many on the board do not listen, many on the board do not care, and their kids are already struggling under the current schedule. Children are exhausted now. Add another two hours of travel, and they’ll have nothing left.

Parents are panicking about jobs and childcare. Families are already balancing survival with school as is, and this would push many past the breaking point. It’s not an education plan it’s a forced hardship. No one who truly understands what it means to raise children could call this plausible, let alone fair.”