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Local planning commissioners in California may deny residential construction proposals that require a zoning change if the developments would overburden public schools, a state appellate court has ruled.

The decision by the Second District Court of Appeals, issued last month, also said that municipal authorities are entitled to ask developers to donate land or money to school districts as a condition for the approval of construction projects.

Two crowded Santa Clarita Valley school districts had filed suit against Los Angeles County in 1989 after a regional planning commission refused to block a 2,500-unit housing development that, the districts contended, would inundate them with new students.

County lawyers had maintained that a 1986 state law imposing a school-related fee of $1.58 per square foot on developers prevented them from blocking projects that affect schools.

School officials argued, however, that the revenues generated by the fees covered only about one-third of the educational costs associated with the new developments.

The number of Wisconsin students receiving high-school equivalency diplomas decreased 66.8 percent between 1986 and 1989, more than seven times the national average, according to a state report.

The state's Legislative Audit Bureau found that only 2,660 equivalency diplomas were issued in 1989, a sharp drop from the 8,011 certificates distributed in 1986. The national decline in equivalency degrees issued during that period was 9 percent, the study said.

The report cited several factors for the decline, including the introduction of a more rigorous form of the General Educational Development examination in 1987. At the same time, Wisconsin raised its ged passing requirements, while many states lowered standards. Wisconsin maintains the highest passing requirement for the ged nationwide.

In 1988, the state also raised the minimum age for taking the ged to 18 years, citing fears that many students might drop out of high school early and take the ged rather than graduate.

A majority of Wisconsin vocational-education schools, which offer ged preparation courses, support a lower score requirement, claiming that the higher passing score dissuades potential ged graduates from taking the test.

Vol. 10, Issue 21

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