June 5, 2012
Steven Lawrence, Ph.D., Superintendent
Mt. Diablo Unified School District
1936 Carlotta Drive
Concord, CA 94519
Dear Superintendent Lawrence:
The purpose of this letter is to confirm the principal initial findings and preliminary recommendations
identified by the Fiscal Crisis and Management Assistance Team (FCMAT) at the exit conference held at
your office on May 23, 2012. FCMAT’s study agreement with the Mt. Diablo Unified School District
specifies that FCMAT will perform the following:
Provide a comprehensive evaluation of the district’s pupil transportation program to include
both home-to-school and special education student transportation services, vehicle mainte-
nance and safety and training practices. Specific areas to be reviewed include:
1. Analysis of the district’s state transportation revenue and contributions (encroachment) from
the unrestricted general fund for the transportation program for home-to-school and special
2. Evaluate the Transportation Department’s staffing and provide recommendations to improve
the efficiency, if needed.
3. Review routing methodology and relative routing efficiency for both home-to-school and
special education transportation services.
4. Review the district’s scheduling of extracurricular field trips/athletic trips.
5. Provide an evaluation of the Transportation Department’s operational efficiency and make
recommendations for potential savings.
6. Review the department’s driver training and safety, and compliance with driver training laws
7. Review the department’s compliance with all laws and regulations which shall include Vehicle
Code, Education Code, CAC Title 5, 8 &13.
8. Evaluate the department’s vehicle maintenance program, vehicle safety, compliance with
vehicle maintenance laws and regulations. This component will also include a review of the
bus and vehicle replacement schedule and provide recommendations.
9. Review the department’s board policy, administrative regulations and purchasing procedures
for parts and equipment.
Joel D. Montero, Chief Executive O cer
1300 17th Street - CITY CENTRE, Bakers eld, CA 93301-4533 Telephone 661-636-4611 Fax 661-636-4647 .
422 Petaluma Blvd North, Suite. C, Petaluma, CA 94952 Telephone: 707-775-2850 Fax: 707-775-2854 www.fcmat.org .
Administrative Agent: Christine L. Frazier - O ce of Kern County Superintendent of Schools
10. Evaluate the department’s transportation operations facility to include compliance with
industrial waste and hazardous materials rules and storm water run-off regulations.
11. Review of the district’s fuel storage facility and management systems.
12. Review use of technology within the transportation program in the areas of routing,
scheduling of extracurricular/athletic trips, vehicle maintenance and other areas for efficiency.
The FCMAT study team visited the district on May 21, 22, and 23, 2012 to observe transportation
programs, conduct interviews and review documentation. Although the team continues to collect and
analyze data for the full report, the following information comprises FCMAT’s initial findings and pre-
Transportation Finance and Purchasing
School transportation in California was fully funded until 1977. At that time, school districts reported
their operational costs, and the state fully reimbursed the costs in the subsequent year. Between 1977
and the 1982-83 school years, California reduced the percentage of reimbursement, and in the 1982-83
school year, the state capped each district’s revenue at 80% of the reported costs.
Over the intervening years, the state has occasionally granted a cost-of-living adjustment (COLA), but
not enough to keep pace with increasing costs. The Mt. Diablo Unified School District has an approved
apportionment of $1,392,370 for home-to-school (HTS) transportation and $1,426,090 for severely
disabled/orthopedically impaired (SD/OI) transportation.
Over the past three fiscal years, that amount has been deficited by approximately 20%. State funding for
pupil transportation covers approximately 35% of total costs statewide, and for the 2011-12 fiscal year,
Mt. Diablo Unified has a deficited apportionment of $1,116,191 for HTS, and $1,143,222 for SD/OI.
Approved costs are not yet available for the 2011-12 fiscal year, but for 2010-11, revenue was $1,119,620
for HTS and $1,146,735 for SD/OI. The approved transportation costs for 2010-11 were $1,688,174
for HTS and $7,122,107 for SD/OI. For the 2010-11 fiscal year, the overall district unrestricted general
fund contribution for school transportation was $6,543,926 or approximately 74% of the overall cost.
On average for the 2010-11 fiscal year, California supported 35% of pupil transportation costs with
districts supporting approximately 65% of these costs from their unrestricted general funds. Mt. Diablo
Unified School district receives slightly less revenue than the average school district.
The district does not appropriately separate costs between resources 7230 (HTS) and 7240 (SD/OI).
The district should begin working immediately to identify which costs should be coded to each resource
so that the data on the state transportation report (Form TRAN) are accurately stated. As the district
reduces HTS transportation, it should be careful to maintain HTS costs at no less than the approved
apportionment of $1,392,370. If HTS decreases to less than this amount, the state will reduce the
approved apportionment to the lower level of costs.
The district parts technician that was laid off entered vehicle work orders into the electronic vehicle
maintenance system. Work orders for repairs to the district maintenance and operations, food service and
warehouse vehicles (white fleet) were then invoiced to the appropriate department. Since that position
was eliminated during the 2011-12 fiscal year, no work orders were entered into the system and all repair
costs for white fleet vehicles were consequently absorbed by the transportation budget. White fleet work
orders should be calculated and the amounts should be invoiced to each appropriate department.
The district has taken responsibility for transporting all special education students that previously were
transported by the Contra Costa County Office of Education. There is no written agreement, but it is the
district’s understanding that the county office will agree to transfer a portion of its state pupil transporta-
tion revenue to the district. Mt. Diablo Unified should get clarity on this amount and use the J-141-T
form to permanently transfer this funding.
Reasonable controls should be implemented regarding parts and supplies purchasing practices. Although
the district has a rather large parts inventory, it is not documented and not often utilized. Most required
parts are purchased as they are needed. Work orders may include the part number, but prices are not
noted, and reasonable levels of approval for purchases are not apparent.
Buses are fueled by a single employee, but maintenance and operations vehicles are fueled by their
drivers. There is no electronic fuel management system, fuel pumps are not locked during the day, and
dispensed fuel is to be recorded on a paper log. As a result, this system is vulnerable to misuse.
The Transportation Department has decreased the number of regular education HTS routes over the
past few years, but increased the number of special education routes. The district has taken responsibility
for transporting all its special education students that previously were transported by the county office.
FCMAT has reviewed staffing and will make recommendations on a conservative, but more effective
staffing model in its full report.
The district has 12 regular education bus routes, and some of these routes also serve students who need to
attend schools other than their home school because of larger class sizes (an overflow of students). Some
regular education routes also serve students who are allowed to attend another district school because
their home school is in Program Improvement status (PI) under the federal No Child Left Behind law
(NCLB). The district has 79 special education bus routes that transport approximately 950 special educa-
tion students for a load factor of approximately 12 students per route, a relatively efficient ratio for a dis-
trict of this size and population density. Approximately 250 special education students are transported by
outside contractors or parents who are paid in lieu of receiving transportation. This is an extremely high
number compared with other school district transportation departments that FCMAT has reviewed.
The district reported that approximately 4,500 students have Individualized Education Programs (IEPs),
and approximately 1,200 of these receive specialized transportation as a related service as dictated by their
IEP. Approximately 26% of the district’s special education student population receives specialized trans-
portation; however, that percentage is approximately 10% in most school districts reviewed by FCMAT.
The district has determined some of the reasons pupil transportation costs are so high. Mt. Diablo
Unified overidentifies students for specialized transportation and does not take advantage of reasonable
methods to support each student’s least restrictive environment (LRE) as required by the Individuals with
Disabilities Education Act (IDEA). The district has routinely assigned transportation service instead of
evaluating each student’s specific need.
The district should revise its IEP and transportation request forms to evaluate the appropriate need
for specialized transportation for each student. Program specialists, teachers and principals should be
trained on the issues and decisions involved in determining whether to provide transportation service.
The Transportation Department designee should be invited to IEP meetings where transportation will be
discussed, and clearly should be consulted on challenging situations or placements. Instead of providing
door-to-door service, the district should make arrangements for students to meet in groups at corner
stops or at their local school of attendance to board a bus that transports them outside their regular atten-
dance area (clustering), if required by their program placement.
In addition, the district should closely evaluate the need for a third-party transportation provider. This type
of transportation is generally provided in a one-on-one fashion and may be less efficient than transportation
on a school bus. A very large number of parents choose to transport their children instead of having them
transported on the school bus. The option of paying parents to drive their own child to school should be
offered only if no district bus is available, and this option should not be offered to everyone.
Compliance with Laws and Regulation
District staff members are knowledgeable about the laws and regulations that govern pupil transporta-
tion. California Education Code Section 39831.3 requires each school to have a transportation safety
plan. However, district staff members could not locate this plan.
The state requires school bus driver training to be performed by a state certified school bus driver instructor.
At Mt. Diablo Unified, one supervisor maintains driver training records and assigns and oversees the work
of three school bus driver instructors. FCMAT’s review of a sample set of driver training records found that
they comply with all laws and regulations, and that drivers receive sufficient training as required by law.
Bus Maintenance and Vehicle Replacement
The California Highway Patrol’s (CHP) Motor Carrier Division annually inspects school buses, mainte-
nance records, driver records and federal drug and alcohol testing program records. The CHP provides
a document known as the terminal inspection report that grades the school district. Mt. Diablo Unified
consistently receives CHP’s highest grade of “satisfactory” indicating overall compliance with laws and
regulations in these areas. Some violations concerning vehicle maintenance and drug and alcohol testing
were noted, but they were not extensive enough to compromise student or operational safety.
The district recently received a grant for 10 coach-type buses from the Bay Area Air Quality Management
District to replace older buses. In addition, the district recently purchased 19 smaller school buses to accom-
modate the projected growth in special education transportation. However, the bus fleet is generally old,
and many buses are in need of replacement. In addition, buses are not regularly washed or cleaned.
FCMAT extends its appreciation to all the staff of the Mt. Diablo Unified School District for the oppor-
tunity to be of service and for the assistance provided during this review.
A draft version of FCMAT’s full report containing detailed findings and recommendations will be
provided for your review in approximately six weeks. Should you need assistance prior to issuance of the
draft report, please contact me at 661-204-0579, or email@example.com.
William Gillaspie, Ed.D.
Deputy Administrative Officer