funding and the effective use of education dollars.” One obvious problem for districts in the Big 5 is that during a fiscal crisis, local appropriations for schools may fall dramatically, affecting their ability to provide the opportunity for a sound education. The same is not necessarily the case in fiscally independent districts since property values tend to be stable, and in fact, may rise during difficult economic times. In the words of Dr. Berne, “Compared to the resources say in New York City where it is a combination of all of the general resources, the property tax is less, economically less sensitive and more predictable tax.” Another problem is that in addition to having limits in the amount that they can borrow, there are also State-imposed limits in the amount of taxes cities may levy.[26] The State uses a system comprised of about 54 formulas to distribute about 13 billion dollars of State aid. Historically, New York City has received close to 34 percent of the total of State aid. For 1999, the New York City's Board of Education had a budget of 9.8 billion dollars. The average per- pupil expenditure for that year was $8,957. The roughly 1.1 million public school students in New York City make up 37 percent of the total State student population. About 80 percent of New York City students qualify for the federal government's free and reduced lunch program that is targeted to poor students. About 72 percent are African-American or Hispanic. About 80 percent of all State students with limited English proficiency attend New York City public schools. A substantial number of New York City students are said to be at-risk of doing poorly in school because of socioeconomic disadvantages, including poverty, race and limited English proficiency. The record establishes that these students need more help than others in order to meet educational goals, such as extended school programs, remedial instruction, and support services. The most important category of formulas is termed basic operating aid, which distributes 5 to 6 billion dollars of State aid based on weighted attendance and wealth of school districts. Although we held in Board of Educ., Levittown Union Free Dist. Nyquist (57 2 27 [1982]) that the Education Article does not require equality of educational resources, operating aid seeks to have a wealth equalizing effect by giving more to low-value property districts and less to high-value property districts. Operating aid also distributes flat grants to each district regardless of the level of wealth. New York City receives about 36 percent of operating aid. Mr. Kadamus testified that operating aid treats New York City as an average wealth district, overlooking the high concentration of