December 15, 2015

Barry Nocks, Ph.D., FAICPPAB ChairProfessor EmeritusDepartment of Planning, Development, and PreservationClemson University 2-213 Lee Hall, Box 340511 Clemson, SC 29634-0511

Dear Barry:

The APA Board, AICP Commission and the APA Diversity Task Force of Membership thank you for the opportunity to review and comment on the proposed PAB Amendment to Preconditions to Accreditation and Accreditation Standards. Over the past few months each group has met to develop our feedback.

We support your efforts to address legal issues that have been raised and to ensure that the Preconditions to Accreditation and Accreditation Standards are legally sound. Our principal concern is that the proposed changes seem to go further than necessary to address the legal issue the attorney raised regarding diversity. We talked about how the PAB can monitor and evaluate the success of the program’s policies to encourage diversity. While the proposed changes are intended to avoid the problem of measuring outcomes with respect to diversity, we suggest that what should be measured is the effort to seek diversity in those areas, not the diversity itself. A related consideration is if we measure the effort to seek diversity, such an approach might unfairly penalize a program whose outreach in those areas is conducted at the school level, not department level.

This letter reflects our collective input to date organized by the five categories in the Preconditions. More specific suggestions on language are included in the attached version of the Preconditions with track changes.

1. Strategic Planning & Progress How often should the process of assessment, reflection and correction of

each program or department occur? This process should not only happen before accreditation review but more continually. (1. First paragraph)

When programs document participation in their plan development to include faculty, students, alumni and practitioners, it’s suggested that there is a broad “spectrum of the professions”, but what does that include? It should be more than just the various disciplines of planning to include demographic diversity in terms of age, race and gender.(1.B.)

Feedback from members is that the Programs do not engage the practitioners and employers in the development of the strategic plan and they are often contacted only in the immediate face of a reaccreditation site visit. Thus, we recommend that practitioners be included in the following sentence: “Programs must document participation in plan development by faculty, students, alumni, and practitioners.”. (1.B.)

“Goals shall reflect the Program’s intent to achieve and maintain diversity…” – “Intent” is not a strong enough word. Programs can intend to do things and not do it. We suggest that the goal shall reflect the Program’s COMMITMENT to achieve and maintain diversity. (1.B.2.)

When discussing goals and measurable objectives, programs need to incorporate into their curriculum the following (1.B.2.):

o A clear understanding of the social, economic and environmental forces that keeps aspiring planning students from entering a program or succeeding after completing the program.

o The knowledge and skills needed to serve a diverse society.

o “The objectives should ordinarily be measurable and framed…”: what is “ordinarily”? This language could be less vague. We recommend deleting the word "ordinarily" as superfluous when the word "should" is used, rather than "shall." The "should" allows for some flexibility, without undermining the intent of the statement. (Final paragraph in 1.B.)

Under Program Assessment, the section called “Graduate employment” could be phrased more appropriately to address current issues, especially in the Midwest. This section implies that all graduates will be looking for a job when in reality, many will currently hold jobs. There are students who are currently employed as planners in the surrounding communities but have degrees in Geography or Public Administration. They return for their masters to be better equipped to continue in their position. At this time, that level or type of assessment is not captured. This issue is faced by several of the urban based programs that offer evening classes. We ask you to consider how to accurately assess a program that has this component. One way to clarify what is being measured would be to document the percentage of graduates previously not employed who secure employment. (1.C.1.b.)

While “Graduate employment” seems like a logical indicator, it is reliant on the plentiful and regular availability of planning employment opportunities. Unfortunately, there many variables that affect supply and demand for planning jobs, i.e. geography, economic recession, planners staying on the job passed retirement age, etc.  We encourage the development of this indicator to take these realities into account so that certain planning programs are not put at a disadvantage over others.  (1.C.1.b.)

Under “Graduate Certification”, a qualitative piece is missing beyond AICP exam pass rates. Smaller programs, or programs that have people who don’t take the exam, is of concern. If no one takes the exam that year, then the rate is 0% which reads that no one from that university has successfully taken the exam. That could be misleading, so we suggest that the pass rate also indicate the number taking the text so that there is a ‘context’ to interpret the pass rate. (1.C.1.c.)

Under “Graduate Certification”, should we consider extending these periods to a more meaningful 5 and 7 years? In many/most cases, graduates are not eligible to sit for the exam until their 3rd year after graduation, and undergrads their 5th year after graduation. (1.C.1.c.)

Why is the cost (tuition and fees) an outcome? If deemed as such by the programs and PAB, would we not want these costs in relation to the cost in the recent past (e.g., 5 years)? Also, if tuition and fees are an outcome, it seems that scholarships and other assistance would need to be included as an outcome as well. (1.C.1.e.)

“Core Knowledge, Skills, and Values of the profession” could include a note that they are listed in the PAB standards under standard 4. Curriculum.(1.C.2.a.)

When discussing graduates servicing the community and the profession, please clarify the meaning of "community." Does this mean the academic/university community or the community in which the graduate works? How will this be defined? (1.C.2.c.)

How can you accurately track contributions to meeting community needs and service to the profession 2 and 5 years after graduation? How do you gather the data? What is the anticipated performance metric here? Hours in pro bono? Grants obtained? Number of plan commission meetings attended? (1.C.2.c.)

Faculty research/scholarly contributions to the profession needs more clarification. We understand that there must be a balance between the need for academic research and applicable research. Not all research is immediately useful in application, but contributes toward the larger body of knowledge that improves the profession’s impact. With that being said, distribution outside of the academic community is necessarily a metric of value. There should be some consideration given to the extent to which faculty research is disseminated outside of the academic community. (1.C.2.d.)

2. Students The last sentence in the introductory paragraph is stricken, but it is not clear

how that sentence would violate legal requirements. Item 2.B. Student Diversity: the entire paragraph B has been replaced. It

would appear that only the last two sentences are a problem with respect to the legal issue that has been raised.

PAB should be very clear on what they want to report on diversity data.

3. Faculty Under “ Faculty Quality Guidelines”: Eliminating the guideline about adjuncts,

lecturers, and guest speakers adding perspective removes opportunities for students to be exposed to diverse, valuable and experienced voices that come outside the academic world. This guideline should not be removed. (3.A.Guidelines)

Under “Faculty Size Guidelines”: There was some concern over stating that a program should have a minimum of 5 full-time faculty members. What if budget concerns dictate that the number be lower than 5? If this is in fact a guideline, then the accreditation team should have flexibility when evaluating the program. (3.C.Guidelines)

Too many programs appear to assemble their 5 FTEs from dozens of adjuncts teaching a single course. (3.C.Guidelines)

When discussing “publication outlets”, JAPA should be specifically cited as a journal through which publications will be disseminated. Also, some portion of the output of the faculty must be accessible to the profession of planning outside of the academic community. (3.E.Guidelines)

When stating that the faculty should “progress toward meeting the needs of the broader community”, define “broader community.” University community? Local community? (3.F.)

We do not encourage academic isolation of the faculty and the changes in 3.F to reduce the inward focus of faculty endeavors are welcomed. We have

suggested changes to 3.G. to reinforce the value of professional practice. (3.F./3.G.)

4. Curriculum and Instruction Equity needs to be mentioned. When discussing that curriculum must

“prepare students to practice planning in communities with diverse populations”, we also need to add “and to develop skills necessary to create equitable and inclusive planning processes”. (4. First paragraph)

Under the “Values and Ethics” section, we need to add “Health and the Built Environment: the vast implications of our profession on individual and community health in the places where we live, work, play and learn.” (4.A.3.)

5. Governance Regarding “Program autonomy”: Programs should invite and encourage the

involvement of adjunct faculty but when the word “shall” is used, it is a requirement, and adding hours into the time adjunct faculty spend may be unreasonable. Most are not paid much to start so requiring additional hours of time could narrow the pool of willing instructors. (5.A.)

General comments In general, we'd like to see more emphasis on community engagement and

recognition of students interested in community development and urban affairs, since we think that is where we can find more diversity. Also, we think the PAB accreditation focuses too much on strategic planning and the concept of urban planning as a term; and not enough on community engagement, outreach, equity and improving the lives of others.

We are concerned that the proposed revisions weaken the commitment to diversity that the current standards exhibit, and we urge the Board to keep a strong commitment, while remaining consistent with applicable law

We would like to see more examples formatted in the language when mentioning racial and ethnic minorities, or cultural differences. For example "Policies shall be in place that pro-actively seek to expand opportunity for under-represented minorities, including racial and ethnic minorities (Ex. black, white, Hispanic, etc.), and that foster a climate of inclusivity that appreciates and celebrates cultural differences (Ex. Sexual Orientation, Religion, etc.)". 

Sincerely,

Carol Rhea, FAICP Valerie J. Hubbard, FAICP Angela D. Brooks, AICPPresident, APA President, AICP Chair, APA Diversity Task Force of Membership