Archives for category: Philadelphia

Greg Windle, a journalist at The Notebook, has drawn together the many strands of the tangled web of Reformer groups in Philadelphia, as seen through the lens of a contract awarded to The New Teacher Project for principal training. TNTP, Michelle Rhee’s creation, was designed to hire new teachers. When did it develop an expertise in training principals? Were there no veteran educators, no one in the Philadelphia School System, capable of training new principals? Or were they recruiting principals who had been a teacher for a year or two?

As Windle gets deeper into the story of a contract dispute about hiring TNTP to train principals, a familiar cast of money-hungry Reform groups washes up on the beach.

“Marjorie Neff, a former School Reform Commission chair who voted against the TNTP contract to recruit and screen teachers, said that in her experience such national education vendors use an approach that is “formulaic” and doesn’t tailor well to the needs of an individual teacher or the “context” of teaching in Philadelphia, where a teacher’s needs are different than in the suburbs. Neff is a former principal at Samuel Powel Elementary and J.R. Masterman who earned a master’s degree in education from Temple University.

“They’re selling a product. From that perspective, their formula is their vested interest,” Neff said. “Their bottom line is profitability, and we need to take that into account. Is it the most effective way to do this, or is it the most profitable? I don’t think those necessarily have to be in conflict, but sometimes they are.”

“In 2017, TNTP reported that its expenses were $20 million higher than revenue. In 2016, its revenue was nearly $21 million higher than expenses, but this was entirely due to the $41 million it brought in from “all other contributions, gifts, grants” (excluding government grants). That pot includes grants from outside philanthropies, such as foundations, but also investments from venture capital firms. In 2015, the nonprofit lost $6.1 million, despite millions in outside funding.

“Shifting funding, but consistent ideology

“Bain Capital’s consulting firm has two members on the board of TNTP. Since 2009, Bain’s consulting arm has partnered with Teach for America to develop “high-impact leaders in education” by placing TFA alumni in “leadership” positions in public education. Together, TFA and Bain designed “a series of programs to inspire, prepare, match and support Teach for America alums on the path to leadership.” Bain aimed to bring leadership development practices from the private sector into public education.

“In 2012, the two organizations got together to “expand the scope of work” of their partnership — the same year that Teach for America founded School Systems Leaders to train TFA alumni to “serve at the highest levels of leadership in public school systems.”

“Matt Glickman, an employee of the Bain consulting firm and board member of TNTP, has also served on the board of the NewSchools Venture Fund. That fund has invested in free-market education reforms since 1998. The Sackler family – whose fortune is based on profits from Purdue Pharma, developer of OxyContin – decided to invest heavily in the fund.”

When will education be returned to educators?

Anyone advocating for edupreneurs should be fired. As Neff said quite well, these national vendors are in it for the money.

You know the story about zombies. They are the walking dead. They can’t be killed.

Crack reporter Greg Windle has discovered a zombie charter school in Philadelphia.

It has been warned and warned and threatened with death, but it fails and appeals and fails and never dies.

I remember the early days of the charter movement, the late 1980s, early 1990s. Charter enthusiasts said that the great thing about charters was that they would always be accountable for results. If they didn’t keep their promise, they would promptly be closed.

How did that work out?

This zombie charter plans to fail forever and live forever. No accountability!

We now know that the charter lobbyists have made it extremely difficult to close a failing charter school. Zombies!

It takes a long time to close a charter school, and the process includes many opportunities to delay closure for years. Khepera Charter School has exhausted all but its final chance and is now appealing to the state’s Charter Appeals Board to overturn the School Reform Commission’s decision to close the school.

Khepera is a K-8 school with 450 students located in Hunting Park. It was awarded its first charter in 2004, which was renewed in 2009. After academic results declined, the charter was renewed in 2014 with explicit conditions, along with the proviso that failure to meet these conditions would lead to the closure of the school.

Many of the conditions were never met; beyond that, the school continued to violate the state charter law. Since signing the 2014 charter, the school failed to hire enough certified teachers. Growth on the PSSAs largely reversed as scores began to plummet. The school promised to revise its discipline policy and reduce student suspensions, but instead, suspensions increased, even among kindergarten students. Board members didn’t file the required conflict of interest forms. Nor did the school submit the required financial reports and independent audits.

In 2015, the SRC’s Charter Schools Office first warned Khepera that it was failing to meet the conditions. Yet the school has been operating ever since and, by all indications, plans to open for the 2018-19 school year.

Khepera’s appeal to the state essentially seeks to dismiss all charges for a variety of reasons. Its lawyers argue, for instance, that a lack of certification paperwork for a given teacher doesn’t prove that the teacher isn’t certified.

The school ignored the first “notice of deficiency” from the Charter Schools Office, sent in October 2015. The charter office sent another notice in May 2016, another in August 2016, and yet another in May 2017.

Khepera did not respond to these notices. So in June 2017, the SRC voted to begin conducting public hearings to determine whether it should revoke the school’s charter — fully two years after the school failed to meet multiple terms of its signed contract. Hearings began Aug. 10, 2017, and ended Sept. 12, for a total of seven sessions.

Then in December 2017, the School Reform Commission voted to close the charter. Case ended? No! The charter appealed to the state Charter Appeals Board, which could keep the charter open for years.

Zombie!

But that’s not all:

After the SRC voted to revoke the charter of Walter Palmer Leadership Learning Partners Charter School in the spring of 2014, the school filed an appeal to the state so that it could open its doors in September for the next school year.

But when it could not pay employees, Palmer abruptly shut its doors in December 2014, stranding students mid-year and forcing the District to scramble to find places for them.

This cut short the hearings before the state Charter Appeals Board, at which administrators for the charter school had invoked their Fifth Amendment right against self-incrimination 77 times.

After closing the charter, Palmer, a longtime civil rights leader in Philadelphia who founded and ran his namesake school, became a consultant to Khepera, where he initially helped with recruitment. At the end of 2016, he was hired to be CEO.

Khepera’s website gives every indication that it intends to operate throughout the 2018-19 school year and is continuing to recruit and enroll new students.

Zombie walks, talks, and enrolls students even though it is a failing school.

Every failing charter in Pennsylvania can find inspiration in the story of this failing charter:

The longest charter revocation process in state history was for Pocono Mountain Charter School. It lasted six years from the initial revocation hearings to the date the school finally closed. The charter revocation hearings ran for two years, starting in 2008, and appealing to the state’s Charter Appeals Board allowed the school to remain open for three more years. Then the school appealed the state board’s decision twice to higher courts, and only closed in 2014 after it declined to file a third appeal.

Toward the end of the process, Pocono Mountain’s CEO was convicted of using the school to funnel more than $1.5 million in tax dollars to himself, his family, and his businesses. He was sentenced to 10 months in prison.

But taxpayers can take solace knowing that the charter revocation process ended after six years and the CEO was convicted. Justice is slow but sometimes happens.

Franklin Towne Charter High School in Philadelphia has been accused of discrimination against a student with disabilities, reports Greg Windle in The Notebook.

Pamela James was thrilled when her granddaughter was accepted at Franklin Towne Charter High School. Her granddaughter raced off to tell friends the good news, and James gave the school a copy of her granddaughter’s Individual Education Plan (IEP), which included the need for emotional support — a common but relatively expensive requirement among students in Philly schools.

Hours later they were both shaken when James got a call from the Northeast Philadelphia school, informing her that her granddaughter could not attend as a result of her emotional disturbance diagnosis, that the class she needed was “full” and that the school would not accommodate her.

“After I took her IEP to the school, that’s when they shot me down,” James said. “That was really ugly discrimination.”

James was furious. No one at the school would return her calls, though she eventually received a brief letter restating that her daughter could not attend.

“I don’t understand how they’re able to do this,” James said. “They decided to change their mind because she needed emotional support.”

At that point, James did not know it is illegal to deny a student attendance at a public school based on their special education status. But she would soon find out. The Education Law Center of Philadelphia has since taken up her cause, sending an open complaint letter to the schools’ lawyer.

The article includes a graph created by the Education Law Center that shows the stark disparity between Philadelphia’s public schools and its charter schools in enrolling students with disabilities.

The only type of disability where charters accept the same proportion of students as public schools is “speech or language impairment.”

On every other type of disability, the contrast is dramatic. The public schools enroll more than 90% of students who are blind and nearly 90% of those who are deaf. The proportions accepted by charter schools are tiny. Eighty percent of students with autism are in public schools, 20% in charters.

Let us all be grateful to organizations like the Education Law Center. Without them, many students would have rights that are not enforced.

Greg Windle wrote an exemplary report on the record of Philadelphia Superintendent William Hite, who took Office in 2012.

He makes clear that there are many metrics, not only test scores, and many actors, including the governor and the legislature.

Education writers, take note. This is a treasure trove of information that the people of the city need to know.

Lisa Haver and Deborah Grill, leaders of the activist group Alliance for Philadelphia Public Schools, wrote a commentary calling out the school board for its deference to charters, which are now asking to be held to lowered standards.

Forget about transparency or accountability if you are in the charter industry. Even the school board asks permission from the charters to regulate them and holds closed-door meetings to negotiate what they are willing to do.

They begin:

Philadelphia charter school operators and advocates have long maintained that if they were freed from the bureaucracy and regulations imposed on public schools, charters would be able to quickly and consistently raise student achievement. The School Reform Commission bought into that argument, approving new charters in almost every year of its 17-year reign.

The SRC also turned over control of more than 20 neighborhood schools to charter operators through its Renaissance initiative, whose provisions include “stringent academic requirements” that would be used “as a basis for a decision to renew, not renew or revoke a Renaissance school at the end of its [five-year] term.”

But when the data show many of those schools failing to achieve anything close to the “dramatic gains” promised, the SRC did not hold those charters accountable.

Recently, charter operators have actually lobbied the District to lower the standards by which their schools are evaluated. A June 11 Philadelphia Public School Notebook/WHYY story, “Philadelphia School District nearing new accountability rules for charters,” revealed that secret negotiations had taken place between District and charter officials about changes in the rating system, which “was developed with substantial input from the charter operators themselves.” This is not the first time charter operators and District officials have met in secret: They conducted closed-door meetings from fall 2016 through spring 2017 to formulate public policy about charters.

Belmont Charter CEO Jennifer Faustman argued that it’s not fair to compare charters who took over poor-performing District schools, saying, “You’re basically being challenged to exceed the District.”

But hasn’t that been the justification for creating and expanding charters — that they would always do better than public schools? Belmont Charter would not sign its 2017 renewal agreement, citing unfairness of conditions, even though Belmont failed to meet standards in all three categories—academic, financial, and organizational.

District officials contend that the new rubric is “fair” to charter operators, but do not explain how it is fair to the students or their parents. Theoretically, a charter school could earn a 45 percent academic grade even with near-zero proficiency rates. That is, a charter could be renewed as long as it showed improved attendance and growth — if not actual academic achievement. Incredibly, the charter coalition finds that expectation too high. They are holding out for a 40 percent passing grade.

Then-SRC Chair Estelle Richman told reporters that the charter “performance framework” has undergone “more than 60 negotiated changes” in the last year and that the “charter agreements incorporate a revised performance framework which provides charter schools with transparent and predictable accountability and ensures charter schools are quality options for students and families.”

Transparency, apparently, should be extended to charter operators but not to the public. If charters are truly public schools, as charter operators contend, then all policy discussions, including changes in the rating system, must be open to the public. Nor did Richman explain why the SRC felt the need to consult those being regulated on how they wished to be regulated.

Last month, in one of its final actions, the SRC approved 10 charter renewals. Four others, including two Mastery charters, were not on the agenda, reportedly because they rejected conditions suggested by the District.

Who is in charge? Why no accountability? Why are standards higher for public schools than for charters? What about all those promises?

Greg Windle, writing for The Notebook in Philadelphia, writes here about polite corruption in bidding for public contracts on the Philadelphia School System, which is run by a Broadie, William Hite.

“In a dispute over a lucrative contract for principal coaching, a bidder [Joseph Merlino] has accused the District of ignoring its procurement procedures, as well as state and local bidding requirements.

“The company has filed a complaint in the Pennsylvania Court of Common Pleas demanding the District and school board agree to follow their own contracting procedure in the future to avoid undermining public confidence in the integrity of the process…the District is preparing to argue that it has no obligation to follow state law or enter into competitive bidding when it awards contracts for professional services, despite promising to do so in its procedures sent to bidders.”

The contract was for training principals. The bidder who lost co,planned that his organization had a more experienced team and a lower bid than the bidder who won, which was The New Teacher Project. The decision was made by someone with informal ties to The New Teacher Project.

“Underlying this dispute is a concern over long-term outsourcing of this type of work, as well as a clash of philosophies over the best way to train teachers and principals in leadership. This clash pits those favoring more traditional means against others promoting a more “disruptive” approach that has been advocated by major national education players, including the Gates and Walton foundations, and the groups they fund, such as the New Teacher Project, which was awarded the contract….

“In a complaint sent to the District as a prelude to his court action, Merlino noted that the District’s deputy in the department that selected the New Teacher Project, out of nine who submitted bids, was on a two-year fellowship with School Systems Leaders, part of an informal network of organizations that grew out of Teach for America and includes the New Teacher Project. School Systems Leaders seeks to place Teach for America alumni in high-level administrative positions within public school districts….

“In his complaint, Merlino noted that the contract was awarded when Katie Schlesinger was a deputy in the office of Leadership Development & Evaluation, which managed the bidding process. At the time, she also had a fellowship through School Systems Leaders.

“School Systems Leaders and the New Teachers Project are both spinoffs of TFA, and both function by staffing rank-and-file positions with TFA corps members or alumni. And they both receive funding from the same venture capitalist firm – the NewSchools Venture Fund.”

One hand scratches the other.

This deal stinks.

Tom Ultican, recently retired teacher of physics, has embarked on a mission to cover the Destroy Public Education movement. His posts have taken him to several cities, where the school choice movement has destroyed public education without putting anything better in its place. In fact, the “new” schools are usually worse than the public schools.

In his latest foray, he studies the destruction wrought by the Destroy Public Education movement on the public schools of Philadelphia.

The trouble started when Republican Governor Tom Ridge hired the Edison Project to conduct a study of the Philadelphia public schools and come up with solutions (such as, taking charge of the entire district themselves, nothing like conflict of interest to stir the commercial juices.)

Ultican relies heavily on Samuel Abrams’ excellent book Education and the Commercial Mindset, which began life as a study of Chris Whittle’s Edison Project.

Things went downhill from there. The whole point of “reform” was not to make the schools better, but to save money.

“Edison’s report was not impartial. Both the Philadelphia Inquirer and the Philadelphia Daily News called it a charade. (Abrams 116) The report was overly critical of the school district and recommended that the Edison Project be put in charge of running it. Edison also called for reforming “failing” schools by turning them into charter schools.

“Helen Gym (now on the Philadelphia city council) speaking for Asian Americans United, asked, “If this [privatization] is so innovative why aren’t they doing it in Lower Merion.” (Abrams 114) This turns out to have been a perceptive question. Lower Merion is 85% white and rich. Still today, there appear to be no charter schools in Lower Merion Township. Charter schools mostly exist in poor communities without the political capital to protect their schools.”

Broadies, Broadies everywhere! Closing public schools. Starving them. Opening charters. Destroying the district. The great Charade of “Reform.”

Ah, remember the old days of saving poor black kids from failing schools?

Here is a charter school in Philadelphia that won a renewal on the condition that it attempt to achieve greater racial diversity and get rid of financial conflicts of interest. The charter school is opposing the conditions on its renewal. Too onerous! So what if its schools are majority white in a district that is 14% white? So what if its owners and directors have conflicts of interest? Why should that matter?

The SRC approved the new charter on April 26 after originally denying it on Feb. 22. The conditions were significant – reducing the enrollment total by a third, requiring the school to give preference to students from nearby zip codes with high non-white populations, and changing policies to conform with various state laws.

Franklin Towne’s existing two schools, which enroll 2,100 students in grades K-12, are 70 and 83 percent white, although they are located in a diverse section of the city. In the School District overall, only 14 percent of students are white.

The SRC also imposed conditions on Franklin Towne’s operational structure, which the District’s Charter Schools Office, in evaluating the application, found rife with conflicts of interest among its schools, its boards, its management organization, and its landlord.

Why not just copy the Minneapolis-St. Paul model and have charter schools that are all white, and others that are all-black? Do you have a problem with that?

Charters are more segregated than public schools. We know that. Who will have the nerve to oppose it when the Founding Fathers of charters in Minneapolis-St. Paul think that segregation and non-union charters are just fine, even, well, “progressive.”

Apparently, if you are part of the charter movement, separate but equal is a swell doctrine.

This article by Amadou Diallo in The Hechinger Report describes schools in Philadelphia that rely on project based learning rather than standardized testing. Unlike many such articles, it acknowledges the differences between schools with selective admissions and those that accept all applicants.

A snippet:

An unqualified success for these new schools would be results like those at Science Leadership Academy, a magnet school that is home to the district’s longest-running project-based learning program, which opened in 2006. The school combines rigorous research with student-driven projects that have impact beyond the school building. One student project involved putting on a city-wide Ultimate Frisbee tournament. In the 2016-17 school year, 99 percent of its seniors graduated, and 84 percent attended college immediately afterward. Algebra, Biology and English literature proficiency scores at the school are more than double the district high school average.

“Projects are really hard, collaboration is really hard.”

“As a magnet school,” said Science Leadership Academy principal Chris Lehmann, “we need to be able to prove that the learning we engage in here shows up on the test … without falling into a teach-for-the-test problem. It’s a balancing act. It always has been.”

It may prove difficult for other schools to replicate Science Leadership Academy’s performance, however. As a magnet school, it has selective admissions and attracts students from a wider range of socioeconomic backgrounds (fewer than half its students receive free or reduced-price lunch, for example) than the city’s other project-based learning schools.

Lehmann acknowledges the inherent advantages at a school that’s able to choose its students — applicants must meet minimum grade requirements and sit for an interview — but, like his counterparts at Philadelphia’s nonselective project-based learning schools, he argues that we need to be taking a more holistic view of school performance. “How you judge a school is an incredibly nuanced thing,” he said. “The way that we take care of each other and the way that we learn are intertwined.” There may not be a quantitative metric to assess whether students are being provided with meaningful work in an environment that lets them know they are cared for, but Lehmann believes that without those components, grades and test scores become an end unto themselves.

“There’s no [statewide] assessment for being able to look people in the eye and speak clearly.”
Vaux Big Picture High School principal Gabriel Kuriloff

Tamir Harper is an 18-year-old senior at Science Leadership Academy whose passion is education reform: In 2017 he founded a nonprofit that advocates for quality urban education. He says that when he arrived at the school he was obsessed with grades. “I just wanted to know ‘How can I get an A?’ I didn’t care if I was learning, or comprehending,” he said. “Now I’m a student that wants to learn, and I don’t worry about the end result [grade]. I’m into the process.” He says a big part of that shift was the relationships he forged at school. “We’re not just project-based, we’re a community-driven school,” he said.

Fellow senior Madison Militello, 18, says her middle school was very strict, with no room for individual connections. “Here I don’t feel like the teachers are above me. I feel like we’re on the same level,” she said, noting that she’s still close with some teachers even though she doesn’t have their classes anymore. “You can’t teach a group of students you don’t have a connection with.”

That sentiment was a common refrain at Vaux, LINC and Workshop, each of which offer slightly different approaches to project-based learning in underserved communities. Educators at each are confident that the skills their students are acquiring — collaboration, critical thinking and problem-solving — will eventually manifest themselves in improved results on more traditional metrics like math and reading tests. More importantly, however, they believe that students will be much more prepared for the real world when they leave school. Whether project-based learning done on a larger scale can turn the tide in Philadelphia is another question.

“You can create the perfect school model and it’s still not going to solve American poverty,” Hauger said. “We’re moving the needle for every child who comes through the door and sometimes that doesn’t feel like enough.”

The lame-duck School Reform Commission in Philadelphia, which ceases to exist on June 30, voted to award a third charter to Franklin Towne Charter school, which currently has two charters serving majority-white populations. The SRC called on the charter operator to make a greater effort to achieve diversity. The current K-8 charter is 75% white; the high school charter is 83% white. They are located in diverse neighborhoods and do not reflect the neighborhood.

What makes this decision peculiar is that the owner of the Franklin Towne charter chain has engaged in ethically dubious real estate deals. As The Notebook reported, the CEO of Franklin Towne is involved in one of those real estate deals where the charter company is both landlord and tenant.

The debt of Franklin Towne Charter network is long-standing, incurred through a series of circular real estate arrangements that were used to purchase and construct school buildings and rent the buildings from companies that its CEO created.

A 2010 report from the city controller found these arrangements at nine different charter school operators around the city and described it as a way of “transferring taxpayer-funded assets to non-profits that are not accountable to the School District.” 

The report found Franklin Towne’s high school to be among those nine. CEO Joseph Venditti leased the school’s already-purchased property to a for-profit entity he created, Franklin Towne Holdings LLC, and then subleased it back to the school. He also doubled his own compensation over the course of three years. 

As CEO, Venditti took the building bought by the high school with bonds and leased it to Franklin Towne Holdings. The holding company sub-leases the building back to the school, which pays rent to the holding company. Venditti signed the lease and sublease as both CEO of the school and manager of Franklin Towne Holdings LLC, according to the 2010 city controller’s report. 

Franklin Towne is no longer collecting state reimbursements for rent payments, but a 2014 audit of the high school’s finances found that the same circular leasing arrangement was still in place. According to the audit, this agreement will not expire until January 2033.

Franklin Towne has since expanded to open a K-8 school called Franklin Towne Elementary. Audits of that school found it is in the same sort of relationship with the Richmond Street Development Corp., a nonprofit, which collects rent on the already-purchased school building.

Richmond Street Development Corp. was established by the elementary school in 2009 to acquire land and construct a school building, according to the 2014 audit. And Franklin Towne Charter Elementary is “the sole member of the corporation.” 

The school also “effectively appoints a voting majority of the board” and Richmond Street Development Corp. is “economically dependent on Franklin Towne Charter Elementary School for financial support,” according to the audit. 

The Charter Schools Office’s evaluation of Franklin Towne’s proposed new middle school, which the School Reform Commission will consider on Thursday, would be set up with a similar arrangement. This time, the high school itself would be acting as the landlord by subleasing a portion of the building to the new middle school. 

These kinds of financial shenanigans are not uncommon in the bizarre world of charter school finance.

But the question is, why would the School Reform Commission ignore this report of Franklin Towne’s shady finances?

The SRC can’t say they were not informed.

Lisa Haver, retired teacher and public school activist, suggested some possible reasons for the SRC’s readiness to award a new charter to the Franklin Towne charter chain in her testimony to the School Reform Commission before they voted to approve expansion:

Testimony of Lisa Haver to the School Reform Commission

April 26, 2018

There is no need in the Frankford/Tacony community for another Franklin Towne Charter.  Franklin Towne already gades 6-7-8 in its K-8 school. The only reason that company needs a new school is to secure its own bottom line.

I taught at Harding Middle School in Frankford for over 10 years. It seemed that there were 2 exits for graduating 8th graders: one for the African-American and Latino students to Frankford High, and another for the white students to Franklin Towne Charter, which should be renamed the Lower Northeast Democratic Ward Leaders Apartheid Real Estate Charter Company.  How does a school in ANY neighborhood in this city, in particular that neighborhood, explain an 83% white enrollment rate? That alone is reason to deny.

As I said about Aspira, what we see here is a Real Estate company/bank that happens to run charter schools.

As CEO, Venditti took the building bought by the high school with bonds and leased it to Franklin Towne Holdings. The holding company sub-leases the building back to the school, which pays rent to the holding company. Venditti signed the lease and sublease as both CEO of the school and manager of Franklin Towne Holdings LLC, according to the 2010 city controller’s report. 

 Venditti is the proposed “incorporator” of the middle school. He is also the CEO of the high school. The high school is proposed to be the management organization for the middle school, as well as its landlord.

 The Charter Schools Office’s evaluation of Franklin Towne’s proposed new middle school…would be set up with a similar arrangement. This time, the high school itself would be acting as the landlord by subleasing a portion of the building to the new middle school. 

 Is it the business of the SRC to fund this pyramid scheme—with taxpayer dollars?

 FTC board pays Venditti $226K to manage two schools, which is almost the amount Dr. Hite is paid to mange 200 schools.  What we don’t know, because of the legal firewall charters are allowed to set up, is how much Venditti makes off of the real estate dealings.

Of all of the political connections of the FTC board, this is the crucial one:

Ryan Mulvey, a board member for Franklin Towne’s elementary school, is a legislative aide for State Sen. John Sabatina Jr., a Democrat, and would also be on the board of the middle school if it is approved.

 Sabatina is the ward leader who supported Commissioner Green’s failed run for Congress.  In fact, Mr. Green’s address on his filing form, 7718 Castor Avenue, 2nd floor, is a commercial property whose sign says “Sabatina Associates”.  Ryan Mulvey’s brother, Scott Mulvey, was Mr. Green’s chief of staff when he was a city councilman.  Thus, Mr. Green, who should have recused himself when he voted to approve this application in February, must recuse himself now from any vote on FTC.