increasing. * * * Opportunities for less-educated workers are likely to keep declining, while continued increases in the services sector will bring more good jobs to people with computer skills who are literate, can write, and are well-grounded in the science and mathematics.” 26 The State attempted to ensure that the City's contribution to education remains stable despite changes in the economy by enacting a law commonly known as the Stavisky-Goodman Act (Educ. L. § 257[5]). According to Dr. Berne, the law has not been effective at ensuring that contributions from the City remain stable because it applies to all funds in the New York City budget received from local taxes, the State and the Federal government, and because it is not clear who can invoke it. A recent law enacted in 2000 makes clear that it applies only to the City's own budget (chapter 91, section 5; Education Law § 2567 (/nyctapcgi/ez-nylaw?EDN+2567) [5-a]). 27 This view was reiterated by Harold Levy, former member of the Regents and former Chancellor of the New York City Board of Education. 28 A 1996 report by the then State Comptroller H. Carl McCall entitled An Agenda for Equitable and Cost-Effective School Finance Reform, concluded as follows: “The current day complexity and convoluted nature of the aid system is the result of many years of manipulation of the formulas through the budget process. Each year the legislative leadership and the executive agree on some broad parameters for school aid, such as how much the year-to-year increase will be and on how, overall, the aid will be distributed among regions. The formulas and grant programs are then altered by technicians to achieve a desired result. Although the formulas were originally intended to reflect need, each year's manipulation is in truth most heavily driven by a politically determined distribution requirement. The focus is always on a single year's aid distribution rather than conceptual concerns about need and how aid should be provided. The cumulative result of this annual patchwork is therefore quite naturally a jumble.” See, Governor Pataki's press release of January 3, 2001, available at http://www.state.ny.us/governor/press/year01/jan03_2_01.htm. 30 New York is one of fifteeen states whose constitutions' express terms impose an educational obligation to maintain a system of free public schools, but nothing more ( see William E. Thro, Note, To Render Them Safe: The Analysis of State Constitutional Provisions In Public School Finance Reform Litigation, 75 Va L Rev 1639, 1661-70 & n 109 [1989]). By

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