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Grossi characterized the methodology used by Southland to conclude the charter high school would not

adversely impact District 227 as "intellectually lazy." The flaw in Southland's proposal, according to
Grossi, was that it assumed that all expenses in a school district were variable. Grossi gave an example
of the District's fixed expenses: "[O]ver $2.6 million or $700 of the operating expense per pupil is due to
interest on the district's debt. Under the formula proposed by Southland, if Southland took 1,000
students from District 227, Southland would receive more than $700,000 annually from District 227
solely due to the interest component." Southland incorrectly assumed District 227 would save the
$700,000 in interest expense when "the expense won't be reduced one penny." According to Grossi, the
interest expense alone "would cost Rich High School $7 million over the ten years of their initial
proposal." ¶ 45 Grossi also disputed Southland's claim that District 227 would experience a reduction in
operating costs from educating fewer students. "For example, let's assume that Rich High School - - the
district lost 120 16 No. 1-11-0182 students but they represented 40 students in each of [the district's]
three buildings. And within those 40 students there are 10 freshmen, 10 sophomore, 10 junior, 10 senior
students. The district would likely not be able to reduce staff much, but they would lose over $1.7
million a year to Southland. Other expenses also can't be reduced proportionally with student
reductions. There may be some savings with transportation, but it'll still cost the same whether a bus is
100-percent full or 80-percent full. The district will still need a superintendent, a business manager,
utility expenses will remain unchanged, the cost of cleaning will not be reduced proportionally."

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