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This week: Policy 9130 complaint routing (LEAD) • Administrative capture explainer • The 39‑policy power shift (highlights) • Surveillance/tech stack gaps • Facilities & asset guardrails • Concrete fixes the Board can adopt now • Receipts you can print for public comment
LEAD — THE TEXTBOOK CASE (AND WORST OFFENDER): POLICY 9130
As we’ve covered in prior Ledgers at www.tosa2030.com, Policy 9130 channels complaints and public input through the Superintendent, insulating the administration from direct Board accountability. The effect is simple: if the Superintendent is the gatekeeper of the very complaints about the Superintendent, accountability fails by design. This is the model other changes now mirror.
Quote of the week
“They didn’t just tighten a few screws—they rewired the whole house so the superintendent controls the switches, the meters, and who gets to read them.”
Opinion: ‘Autocrat in Chief?” Critics say the draft policies overly centralize power.
Context — Administrative Capture: What Just happened?
If you felt the Board just surrendered authority, you’re not wrong. Last week’s package (September 8 Board Meeting) rewires rules so decision‑making, data, and discipline flow to the Superintendent—while guardrails become “optional.” That’s administrative capture—and it’s the engine of Wauwatosa’s governance crisis.
What “administrative capture” means
It’s when the people hired to run the district slowly rewrite the rules so decisions, information, and accountability flow to them—not to the elected board or the public. It’s not partisan and it’s not politics; it’s governance. When administrators can define their own powers and limit scrutiny, oversight collapses and crises compound.
The big reveal: from outrageous to upsetting
Below are the standouts from the 39‑policy package (see below WSD email dated 9/5/2025), ranked by power shift (editorial rating). The pattern is the point: redefine “operations” as admin‑only turf, curb member independence/speech, and convert safeguards into options.
0144.5 — Board Member Behavior & Code of Conduct (2nd reading/action)
What changed (plain English): Reframes who runs the district (“operations” = administration), forces member replies on “operational/managerial” topics through administration (with compulsory CC to the Superintendent), and adds sanction levers—censure, committee removal, even restricting a member’s ability to request agenda items. Blanket ban on member phone use during meetings (beyond agenda materials).
Ledger angle: Classic capture sequence: define turf as “operations,” route speech through admin, and reserve tools to police dissent.
Control Shift Index: 5/5
Pull‑quotes to print: “The operation of the District is the responsibility of the administration.”
Sanctions include censure, removal from committees, and restricting agenda‑request rights.
2262 — Child/Youth Care Programs (2nd reading/action)
What changed: The prior criminal background‑check requirement was removed from policy language. In the draft, the checkbox indicating adoption of a background‑check clause is left unchecked, and the policy no longer requires checks for District employees in child/youth programs. Contractor coverage leans on state licensing, without an explicit parallel District mandate.
Ledger angle: Access to kids cannot hinge on a blank checkbox or external licensing alone. The mandate must be restored in policy for employees and contractors—full stop.
Control Shift Index: 5/5 (child safety risk)
Pull‑quote: “( ) staff members … have completed a successful criminal history records check …” (unchecked = not adopted; language removed from District policy requirement).
2431 — Interscholastic Athletics (2nd reading/action)
What changed: Normative guardrails—good sportsmanship, “maximum student participation,” WIAA eligibility, concussion/return‑to‑play safeguards, and “no PEDs” language—are presented as options and left unchecked, while Superintendent disciplinary authority remains intact.
Ledger angle: Values and safety become optional; control remains centralized.
Control Shift Index: 4/5
2460 — Programs for Students with Disabilities (2nd reading/action)
What changed: Swaps “adopt DPI model forms/policies annually” for a district‑authored, counsel‑customized manual (DPI adoption box left unchecked).
Ledger angle: Moves authority inward; raises due‑process/consistency risks if the local manual drifts from DPI standards.
Control Shift Index: 4/5
6231 — Budget Implementation (2nd reading/action)
What changed: Authorizes Superintendent/designee to execute commitments/purchases within budget; Board gets after‑the‑fact monthly listings and high‑level reports; amendments kick in at ±1%.
Ledger angle: Real control depends on the granularity and timing of monthly reporting—not pre‑approval of major commitments.
Control Shift Index: 4/5
What to watch: Are check registers (incl. ACH/wires) detailed and public? Are large contracts/change orders pre‑approved—or only visible later in roll‑ups?
Digital Domain: Surveillance + Tech Stack (Powerful + Under‑Specified)
7440.01 — Video Surveillance & Electronic Monitoring (2nd reading/action): System‑wide video (and potentially audio) with blank retention windows, investigatory no‑notice authority, and pathways to use footage in student/employee discipline. Ledger angle: Broad powers; few hard limits. 5/5
7440.02 — Smart Sensors (2nd reading/action): Sensors authorized in restrooms/locker rooms/classrooms; data can be used as evidence; no retention/access‑log requirements. 5/5
7540 — Technology (1st reading): District Tech Plan centralized with Superintendent; Board approval cadence optional; “no expectation of privacy” locked in; social‑media posture unresolved (choose‑one options unpicked). 4/5
7540.01 — Technology Privacy (1st reading): Staff have no privacy on District systems; who reviews (Board vs District), notice, and password registration are left open. 4/5
7540.03 — Student AUP (1st reading): No privacy; strong filtering/monitoring authority; student email + social media access left as options. 4/5
7544 — Social Media (1st reading): Superintendent designates platforms; forum rules and employee‑use limits not yet chosen. 4/5
7540.08 — Artificial Intelligence (1st reading): On by default under Superintendent; no guardrails on PII/bias/impact reporting. 3/5
Facilities, Safety, and Asset Control (The Quiet Softening)
7410 — Maintenance (1st reading): Five core program elements (summer program, spares plan, replacement cadence, modernization, energy/safety plan) are all optional and unchecked. 3/5
7410.01 — Principals’ Building Responsibility (Rescind): Removes site‑level accountability for inspections/custodial oversight/playground safety checks. 4/5
7420 — Hygienic Management; 7430 — Safety Standards; 7440 — Facility Security (1st readings): Centralize responsibility with reactive Board visibility; audit/reporting cadences not set. 2–4/5
7100 — Facilities Planning (1st reading): Annual “review” headline remains, but data‑feed requirements(enrollment/projections/condition) are struck. 3/5
7240 — Site Acquisition; 7300 — Disposition; 7450 — Property Inventory; 7530 — Lending (1st readings):Processes and guardrails largely left optional/blank (appraisals, offer presentation, inventory cadence/thresholds, lending limits). 3/5
6830 — Audit; 8305 — Information Security; 7460 — Conservation: Baselines present, but oversight hooks (Board selection/reporting/metrics) are thin. 2–3/5
What to Watch This Week — Concrete Fixes the Board Can Adopt Now
Fix 9130: Restore a direct, Board‑accessible pathway for complaints and public input not routed through the Superintendent, with published timelines and public reporting.
Restore a mandatory criminal‑background‑check clause in 2262 for employees and contractors (clear “shall” language), with documented verification and annual reporting.
Set retention & access‑log rules in 7440.01/.02 (e.g., 30–45 days default; access logs; annual public report).
Restore Board approval + annual review for the District Tech Plan (7540) and name the approver for reviews/searches (7540.01).
Adopt DPI manual by default (2460)—or justify every divergence publicly.
Pre‑approval triggers for major contracts/change orders in 6231 before monthly roll‑ups.
Reinstate site‑level accountability (if 7410.01 is rescinded, replace with explicit responsibilities and inspection cadence).
Put the metrics back into Facilities Planning (7100) and set inventory cadence/thresholds (7450).
Fix 0144.5 so “operations” can’t be weaponized to gag member speech or block agenda requests.
Receipts (Short, Printable Sidebar)
“The operation of the District is the responsibility of the administration.” — 0144.5 (draft)
Member replies on “operational/managerial” topics must be brief, factual, and CC the Superintendent. — 0144.5
Sanctions up to restricting agenda‑request rights. — 0144.5
Background‑check mandate REMOVED for child/youth programs; checkbox left unchecked; no policy requirement now in force for District staff; no explicit District mandate for contractors. — 2262
Sportsmanship/participation/WIAA/safety shown as ( ) (unchecked) — 2431
DPI manual replaced by district‑custom manual; annual DPI adoption box unchecked — 2460
Surveillance retention left blank; no‑notice investigatory use authorized — 7440.01
Sensors OK in restrooms/locker rooms/classrooms; no retention/access‑log rules — 7440.02
Policy 9130 routes complaints/public input through the Superintendent, insulating the administration from direct Board accountability. — 9130
Policy pull‑quotes reflect the Sept. 8, 2025 board packet drafts (1st/2nd readings). For context on why administrative capture matters, see prior Ledger coverage; 9130 is the template many changes now mirror.
The Pattern to Print
Redefine “operations” as admin‑only → curb member independence and public voice → loosen safeguards exactly where families expect the opposite (child safety, surveillance, facilities, finances). That’s how the balance of power gets rewired.
Call to Action
Email the Board today: “Fix 9130 to restore direct accountability; restore mandatory checks in 2262; set surveillance retention/logs; restore Board approval/annual review for the Tech Plan; reinstate site accountability; and fix 0144.5 to protect member speech and agenda access.”
Bring a one‑page Receipts to public comment—quote the boxes left unchecked and the language removed.
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Disclaimer
All views reflect testimony, public records, and editorial opinion. Allegations are supported with source documentation where noted. No conclusions are asserted here; all parties are invited to provide corrections or context. Right of reply: send corrections or context via the contact form at tosa2030.com/contact and we’ll review promptly for inclusion in the next issue. Freedom of speech is protected by the First Amendment.