1 before the united states department of education office for civil ...

Race to the Top application. 8The Commissioner is, in effect, New York State’s superintendentof schools and reports to the Board of Regents -- effectively the State’s Board of Education.NYSED is New York State’s education agency. NYSED holds itself out to be one of the mostcomplete, interconnected systems of educational services in the United States. 9Its statedmission is to raise the knowledge, skill, and opportunity of all the people in New York. NYSED,the Board of Regents and Commissioner direct where educational funds are distributed inaccordance with education aid formulas established and approved by the New York StateLegislature and Governor.At all times relevant to this Complaint, New York State and NYSED have beensubstantial recipients of federal financial assistance. During the 2012 and 2013 fiscal years, NewYork State received 1089 federal grants totaling $5.67 billion. 10During the 2012 and 2013 fiscalyears, NYSED received 5 federal grants totaling approximately $49.94 million. 11Notably, NewYork State and NYSED were recipients of American Recovery and Reinvestment Act funds in2009, and NYSED, as New York’s education agency, was responsible for distributing thesefunds to school districts in New York.III.NEW YORK’S DISCRIMINATORY STATE FUNDINGSTRUCTURESupport for public education in New York comes from three sources: (1) thefederal government (approximately 5 percent); (2) state formula aids and grants (approximately40 percent); and (3) revenues raised locally (approximately 55 percent). State aid for public8 http://usny.nysed.gov/about/commissioner_king.html9 http://usny.nysed.gov/about/10 U.S. Dep’t of Education, Grant Award Pick-List (Search Report), accessed October 2013.11 Id.8