{
  "code": "GKD",
  "title": "Community Relations: Nonschool Use of School Facilities",
  "description": "Conroe ISD's GKD policy governs how school district facilities may be used by nonschool groups and individuals. It establishes categories of facility users, sets a priority system for scheduling, and outlines fee structures for different types of users. The policy also addresses requirements for facility use and permits religious organizations to use district facilities for worship and related activities under standard terms.",
  "last_action_date": "2026-06-16",
  "last_action_result": "adopted",
  "timeline_local": [
    {
      "date": "2026-06-16",
      "school_year": "2025-2026",
      "action": "adopted",
      "result": "adopted",
      "summary": "This update to GKD (Local) substantially rewrites the Nonschool Use of School Facilities policy by replacing the prior framework with a comprehensive new structure that introduces formal definitions (District Facility, Facility User, Campus-Affiliated Facility User, Employee Facility User, Student Activity User), expanded scheduling priority provisions, detailed facility use requirements (18 numbered items), revised fee and complimentary-use rules, liability and insurance requirements, an appeals process, and an implementation deadline of December 31, 2026. The prior policy language covering approval of use, release of liability, private lessons/clinics/summer athletic leagues, special provisions, usage fees, complimentary/reduced/waived fees, required conduct, and applicability is entirely removed and replaced.",
      "changes_added": [
        "Definitions section header and all definitions: District Facility: Any District or campus facility, building, land, property, parking lot, parking space, or other District resource, or any portion thereof, designated by the Superintendent or designee as available for use by Facility Users under this Board Policy.",
        "Facility User: Any non-District individual or entity approved to use a District Facility that is not part of an official District or campus-sponsored event, including Campus-Affiliated Facility Users, Employee Facility Users, and Student Activity Users.",
        "Campus-Affiliated Facility User: An organization composed of parents, teachers, employees, and/or community members formed to support District or campus programs or activities, including PTA/PTO organizations, booster clubs, Board committees, employee organizations, and any other organization designated by the Board.",
        "Employee Facility User: A full-time exempt District employee, or an entity owned or operated by one or more full-time exempt employees using District Facilities during non-employment hours, and after completing all required District employee commitments and obligations for any activities consistent with a Student Activity User. This term does not include daycare providers, childcare programs, or similar custodial care services.",
        "Student Activity User: A person or entity providing programs, opportunities, or experiences for students residing in the District for purposes of engagement, development, enrichment, or participation. This includes, but is not limited to, extracurricular, co-curricular, and enrichment activities; tutoring; private lessons; academic, fine arts, athletic, and career and technical programs; and related clubs, organizations, camps, teams, performances, and events.",
        "Scheduling Priorities section: Subject to District and campus needs, the District shall give scheduling priority to Campus-Affiliated Facility Users, Employee Facility Users, and Student Activity Users over other Facility Users.",
        "The District will make facilities available for reservation as far in advance as reasonably practicable, consistent with District and campus schedules and operational needs. Reasonable efforts will be made by the District to ensure an event occurs as scheduled or at an appropriate alternate location.",
        "Facility Use section: The District shall permit Facility Users to use District Facilities only for appropriate educational, recreational, civic, social, or religious activities that do not conflict with state or federal law, or Board Policies, including Board Policy EMB (Local), and District procedures.",
        "The District reserves the right to deny or cancel any use in accordance with this Board Policy for any lawful reason.",
        "The District may, at its sole discretion, decline to designate any District Facility as available for use under this Board Policy for any period of time.",
        "The District shall maintain a publicly accessible website or comparable electronic platform that includes all relevant Board Policies and District procedures, all Board-approved fee schedules, and the applications for District Facility use.",
        "The District shall provide an electronic system through which District full-time exempt employees may offer to serve as staff to monitor and support Facility Users. The District may require such District full-time exempt employees to complete training and meet additional qualifications.",
        "The District shall not approve any use that is likely to result in damage beyond ordinary wear and tear, or by any Facility User with a documented history of damaging District Facilities or violating state or federal law or procedure, Board Policy, or District procedure.",
        "Damages to District Facilities, Failure to Pay, Refusal of Facility Use section: Except for Campus-Affiliated Facility Users and other entities designated by the Board, Superintendent or designee, Facility Users are responsible for all damages incurred during use, excluding ordinary wear and tear. The District will determine the extent of any damage and the associated repair costs in its sole discretion, and Facility Users must pay such costs promptly.",
        "Additionally, the District will also refuse District Facility use to any Facility User that refuses to pay for damages or any prior unauthorized use under Facility Use Requirements.",
        "Release of Liability section: Except for Campus-Affiliated Facility Users and other entities designated by the Board, Superintendent or designee, all Facility Users must release and hold the District harmless from any liability for injury, damage to persons or property, or any other claims arising from District Facility use.",
        "Except for Campus-Affiliated Facility Users and other entities designated by the Board, Superintendent or designee, the District will establish required liability insurance coverage amounts, which may vary depending on the nature of the facility use and other relevant factors.",
        "Except for Campus-Affiliated Facility Users and other entities designated by the Board, all Facility Users must provide proof of the required insurance coverage before receiving approval to use District Facilities, if allowed by law.",
        "Facility Use Requirements section: Unless waived by the Superintendent or designee, or otherwise provided in this Board Policy, the following provisions shall apply to all Facility Users and shall be incorporated into District procedures governing the use of District Facilities:",
        "1. Facility Users must complete the application process, satisfy all applicable requirements, and obtain explicit District approval before using any District Facility.",
        "2. The District may cancel any District Facility use at any time without any liability for any lawful reason.",
        "3. The District may refuse facility use on any day at its discretion.",
        "4. Facility Users must execute a Release of Liability in a manner consistent with this Board Policy.",
        "5. Facility Users shall be required to pay all required fees for District Facility use in advance of the scheduled use.",
        "6. Notwithstanding any Board adopted and published fee schedule, the District may assess additional charges for staff, security, District Facility restoration or health and safety needs, as determined in its sole discretion, and such costs shall be borne by the Facility User. The District may assess additional fees for large-scale, special, unusual, or exclusive-use events to reflect the District's costs and ensure cost recovery.",
        "7. The District may conduct background checks of Facility Users and may deny use based on the results.",
        "8. Facility Users must conduct all activities in an orderly manner and comply with all applicable laws, regulations, Board Policies, District procedures, and the Student Code of Conduct provisions related to health and safety, including prohibitions on alcohol, illegal drugs, weapons, and tobacco on District property.",
        "9. Facility Users shall not use District resources or equipment without prior written approval. The District may assess additional fees for unauthorized use, and the Facility User shall promptly pay.",
        "10. Facility Users shall not make any alterations, temporary or permanent, without prior written approval. The District may assess additional fees for unauthorized alterations, and the Facility User shall promptly pay them.",
        "11. Facility Users must review and agree to comply with this Board Policy, Board Policy EMB (Local), and all applicable Board Policies, District procedures, guidelines, and rental terms as a condition of approval.",
        "12. The District may require Facility Users to complete training prior to using the facility.",
        "13. Facility Users must ensure that participants remain within designated and authorized areas at all times. The District may assess additional fees for unauthorized use, and the Facility User shall promptly pay.",
        "14. Facility Users shall not exceed approved occupancy limits or authorized time periods. The District may assess additional fees for unauthorized use, including overcapacity or extended use beyond the time allotted, and the Facility User shall promptly pay.",
        "15. Facility Users shall not assign, sublease, or otherwise permit use of District facilities by any unapproved third party without District permission.",
        "16. Facility Users shall promptly pay for any damages or unauthorized use determined by the District.",
        "17. All Facility Users shall comply with the relevant provisions of the School Board Policy FFG (Legal) and FFG (Local) and take measures to protect individuals from abuse or misconduct, including maintaining appropriate supervision and avoiding, where appropriate, one-on-one contact between adults and minors in inappropriately concealed or locked areas. Facility Users shall help with investigations of abuse or misconduct and comply with all mandatory reporting requirements.",
        "18. The District may at any time and for any reason permanently or temporarily revoke a Facility User's District Facility use without liability for violating this Board Policy or District procedure.",
        "Facility Use Fees section: The District will not approve any District Facility for use unless the Board has adopted a fee schedule for that District Facility.",
        "Facility Users may be charged fees sufficient to recover the District's direct and indirect costs associated with facility use, including, but not limited to, minimum rental periods, operations, supervision, opening and closing, cleaning, staffing, overhead, ordinary wear and tear, equipment and room restoration, rubbish removal, and other related costs.",
        "The District may develop, and the Board may adopt and publish, one or more fee schedules consistent with this Board Policy. Fee schedules may vary based on relevant, nondiscriminatory factors, including the type of Facility User, the nature, timing, and duration of use, the facility involved, whether use occurs during or outside regular business hours, nonprofit status, and similar considerations. Similarly situated Facility Users shall be charged the same or comparable fees.",
        "Except as otherwise provided in this Board Policy, Facility Users shall be charged in accordance with the applicable Board-approved fee schedule.",
        "Except as expressly authorized by this Board Policy, only the Board may waive or modify published fees by formal Board action.",
        "Complimentary or Reduced Fees section: Subject to provisions in this Board Policy, Campus-Affiliated Facility Users shall be granted complimentary use of District Facilities, subject to District and campus availability, reasonableness and practicality of the request, and scheduling priorities. The District may refuse use by any Campus-Affiliated Facility Users for any reason.",
        "The District may develop, and the Board may adopt and publish, complimentary or reduced fee schedules for Employee Facility Users or Student Activity Users. Any such discounts must be consistent with the District's cost-recovery objectives and may not result in an excessive loss of District funds.",
        "Fees shall not be charged for use of District Facilities for public meetings sponsored by state or local governmental agencies or as otherwise required by law.",
        "The District may designate any District Facilities, times, or uses as ineligible for complimentary or reduced fees.",
        "The District shall estimate annually the cost to the District of complimentary or reduced fees.",
        "Emergencies Or Disasters section: The Superintendent or designee may authorize use of District Facilities by civil defense officials or other organizations in response to emergencies or disasters and may waive provisions of this Board Policy as appropriate. The Superintendent shall inform the Board of any such use and waiver as soon as practicable.",
        "Appeals section: Appeals of decisions under this Board Policy may be made in accordance with the District's grievance processes.",
        "Implementation section: The District shall adopt District Procedures to enact this Board Policy. The District shall fully transition and comply with this Board Policy by December 31, 2026, including presenting fee schedules for Board approval."
      ],
      "changes_removed": [
        "The District shall permit nonschool use of designated District facilities for educational, recreational, civic, or social activities when these activities do not conflict with school use or this policy. (old opening provision)",
        "Scheduling Priorities (old section): The campus principal and/or the District facilities manager shall have authority to cancel a scheduled nonschool use if conflict arises with a District activity.",
        "Approval Of Use section: An individual or organization desiring use of a District building or facility shall obtain and complete a written building use application and submit it to the campus principal.",
        "The campus principal or other appropriate administrator shall review the application and determine whether the requested building or facility is available for use. If the building or facility is available, the principal or administrator shall note the availability on the application and shall forward the application to the District facilities manager, who shall determine if the proposed use is consistent with District policy. Upon approval by the District facilities manager, arrangements for the collection of fees, scheduling of personnel, verification of insurance, and compliance with all other administrative requirements shall be made.",
        "Building use applications may be obtained from the District facilities manager or online through the District's website.",
        "Release Of Liability (old section): In applying for use of a District building or facility, an organization or individual shall agree to release the District from liability for personal injury and/or damages to personal property. Any group using a District building or facility shall be responsible for the cost of damages incurred during use. Damages and the cost associated with repairs shall be determined solely by the District and borne by the user.",
        "Approval shall not be granted for any purpose that would damage school property or to groups that are known to have damaged other rented property.",
        "[See CNB regarding nonschool use of District vehicles and FNAB regarding student group use of school facilities]",
        "Private Lessons, Clinics, And Summer Athletic Leagues section: Private lessons, clinics, and summer athletic leagues serve an important school purpose because they enable students to be more proficient; therefore, a separate fee schedule for these activities shall be established by the Board. Criminal history checks shall be required of all persons providing individualized instruction. The fine arts department or the athletic department shall be responsible for obtaining and monitoring these criminal history checks.",
        "Special Provisions section: The following shall apply:",
        "1. All rental agreements shall be reviewed annually.",
        "2. The District reserves the right to cancel a rental agreement at any time use would interfere with school activities or when the wear and tear to the building or facility becomes too great. Determinations regarding interference with school activities or regarding excessive wear shall be within the sole discretion of the District.",
        "3. District buildings and facilities shall not be rented on Christmas Day, Thanksgiving Day, New Year's Day, Independence Day, or Labor Day, unless a waiver is granted by the Superintendent or designee.",
        "4. Any use of District kitchen facilities shall require the presence of a District cafeteria manager.",
        "5. The District athletic director shall approve all sports-related activities, and the District fine arts coordinator shall approve all fine arts-related activities.",
        "6. An organization using a District building or facility shall be required to show liability coverage unless a waiver is granted by the Superintendent or designee. [See Release Of Liability, above]",
        "7. The District reserves the right to charge any appropriate fee that is deemed necessary for use of a District building or facility. The District, when it deems necessary, reserves the right to require an administrator or police presence for any building or facility rental at the sole cost of the user.",
        "Usage Fees section: Users shall be charged a fee to pay for operation, supervision, or cleanup costs at District buildings and facilities. The Board shall publish a schedule of fees for the use of District buildings and facilities.",
        "All users shall be charged a usage fee except as set out below.",
        "Complimentary, Reduced, Or Waived Fees section: Parent/teacher/employee organizations and other adult groups organized for the express purpose of supporting District activities and/or programs, such as PTA/PTO, booster clubs, and employee organizations, shall be permitted to use District buildings and facilities for meeting purposes without charge during normal business hours. [See DGA and GE]",
        "Complimentary use shall not include the use of Districtwide facilities such as stadiums and the natatorium.",
        "Building use fees shall not apply when District buildings and facilities are used as polling places for public elections, for precinct and county conventions, or for public meetings sponsored by state or local governmental agencies.",
        "Each organization that qualifies for complimentary use of a District building or facility shall be allowed two free functions per year during nonschool hours. These functions may be activities such as fund-raisers, meetings, or special events.",
        "All individuals or groups that qualify for complimentary use of a District building or facility that request use beyond the two nonschool-hour functions provided by this policy shall be required to pay usage fees. However, the Board delegates to the Superintendent or designee the authority to approve additional complimentary use of District buildings or facilities to such groups when the Superintendent or designee determines such complimentary use is in the best interests of and benefits the students who attend school at the requested building.",
        "School employees who conduct nonschool camps, clinics, workshops, or lessons for District students shall pay reduced building or facility use fees in accordance with the District's fee schedule.",
        "Except as noted above, only the Board can waive all fees associated with the use of District buildings and facilities.",
        "Fee waiver requests shall be handled in accordance with administrative procedure GKD.",
        "Emergencies Or Disasters (old section): The Superintendent or designee may authorize the use of District buildings or facilities by civil defense officials in case of emergencies or disasters.",
        "Public Meetings Of State Or Local Governments section: Fees shall not be charged when District buildings or facilities are used for public meetings sponsored by state or local governmental agencies.",
        "Required Conduct section: Organizations using District buildings or facilities shall: 1. Conduct their business in an orderly manner. 2. Abide by all laws and policies, including but not limited to those prohibiting the use, sale, or possession of alcoholic beverages, illegal drugs, and firearms and the use of tobacco products on school property. 3. Make no alteration, temporary or permanent, to school property without prior written consent from the Superintendent.",
        "Applicability Of Policy section: This policy shall apply to the use of all District buildings and facilities unless this policy is specifically superseded by another policy, rule, or contract."
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2026-06-16_regular",
      "confidence": "high",
      "source_redline": "GKD_LOCAL.pdf",
      "notes": "The document is a comprehensive redline replacement of the GKD Local policy. All red-underlined text constitutes the new policy framework; all red-strikethrough text is the prior policy being removed. The board action is inferred as \"first_reading\" based on the document context and CISD conventions (no explicit \"Adopt\" language without \"First Reading\" qualifier was visible in the cover page title area shown). The new policy is substantially longer and more detailed than the prior version, introducing formal definitions, an Employee Facility User category, 18 enumerated facility use requirements, an appeals process, an implementation deadline, and requiring Board-adopted fee schedules before any facility can be approved for use.",
      "compliance_assessment": {
        "classification": "Mixed",
        "elements": [
          {
            "element": "Definitions section (District Facility, Facility User, Campus-Affiliated Facility User, Employee Facility User, Student Activity User)",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "All five definitions are locally created categories with no statutory equivalent or requirement in the provided statute analysis. The policy creates a new governance framework entirely absent from statutory text."
          },
          {
            "element": "Scheduling priorities favoring Campus-Affiliated, Employee, and Student Activity Users over other Facility Users",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The statute analysis contains no requirement or permission for prioritizing specific classes of facility users. This prioritization structure is a local design choice."
          },
          {
            "element": "Facility use limited to educational, recreational, civic, social, or religious activities not conflicting with state or federal law or Board Policies including EMB (Local)",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "No verbatim statutory text was retrievable for TEC §11.151 or §11.158. The District's decision to condition facility use on compliance with Board Policy EMB (Local) and to enumerate permitted activity categories is a local governance choice. The addition of 'religious activities' as a permitted use category may track TEC §11.173 permissive authority but that statute does not mandate this language."
          },
          {
            "element": "Permission for religious organizations to use facilities (implicit via 'religious activities' language) subject to conditions tracking TEC §11.173",
            "classification": "Permitted by Law",
            "statutory_basis": "TEC §11.173, as enacted by S.B. 2986 (89th Leg., R.S.)",
            "supporting_quote": "A school district or open-enrollment charter school may allow a religious organization to use the district's or school's facilities to host religious worship, services, sermons, or assemblies only if (1) the use of the facilities does not interfere with the district's or school's primary educational mission; (2) the religious organization provides the fair market rental value or reimbursement for utilities, security, and other costs related to the use of the facilities as determined by the board of trustees of the district or the governing body of the school, unless waived by the board or governing body; (3) the religious organization agrees to be held liable for any damages that occur in the organization's use of the facilities; (4) the religious organization is subject to the same rental terms for the use of the facilities that a nonreligious organization would be subjected to for that use; and (5) any additional requirements imposed by other law for the use of the facilities are satisfied.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified. S.B. 2986 enacted 89th Leg. (2025); no active injunctions identified as of June 2025.",
            "local_additions": "The District's policy permits religious activities among the enumerated permitted uses and imposes equal-terms, liability, and cost-recovery conditions on all Facility Users generally—consistent with the statute's equal-treatment and liability requirements. The District's election to allow such use at all, and the general framework of liability, insurance, and fee requirements applicable to all users, constitutes the District's local implementation of the permissive statutory authority. The statute does not mandate that districts allow religious use; that remains a district choice."
          },
          {
            "element": "Child abuse prevention, reporting, mandatory reporting compliance, and investigation cooperation requirements imposed on Facility Users (Facility Use Requirements item 17)",
            "classification": "Mixed",
            "statutory_basis": "TEC §38.004(a), (b), (c)",
            "supporting_quote": "The policy must require each school district and open-enrollment charter school employee to report child abuse or neglect, including the trafficking of a child under Section 20A.02(a)(5) or (7), Penal Code, in the manner required by Chapter 261, Family Code. Each school district and open-enrollment charter school shall adopt the policy.",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified. TEC §38.004 is long-standing and not newly enacted within 24 months.",
            "local_additions": "The statute requires the District to adopt a TEA-developed child abuse reporting policy and mandates that district employees report abuse—that component is Required by Law. However, the policy extends mandatory reporting and investigation cooperation obligations to non-employee Facility Users, which goes beyond what TEC §38.004 requires. Requiring Facility Users (who are not district employees) to comply with mandatory reporting and assist investigations is a locally chosen expansion. The FFG policy cross-reference and the specific supervision and one-on-one contact provisions are also locally chosen additions."
          },
          {
            "element": "Liability release and hold-harmless requirement for Facility Users (except Campus-Affiliated and Board/Superintendent-designated entities)",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "No verbatim statutory text was retrievable for TEC §11.151 or §11.158. The District's requirement that Facility Users execute releases of liability and hold-harmless agreements is a local governance choice continued from the prior policy. No statute in the analysis requires or expressly authorizes this specific condition."
          },
          {
            "element": "Insurance coverage requirements for Facility Users (except Campus-Affiliated and Board/Superintendent-designated entities)",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "No verbatim statutory text was retrievable for TEC §11.158. The District's requirement that Facility Users provide proof of liability insurance before approval is a local governance choice carried over and refined from the prior policy. No statute in the analysis requires or expressly authorizes this specific condition."
          },
          {
            "element": "Background checks of Facility Users with authority to deny use based on results (Facility Use Requirements item 7)",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The prior policy required criminal history checks specifically for persons providing individualized instruction. The new policy broadens this to permit background checks of all Facility Users at the District's discretion. No statute in the analysis requires or expressly permits this broader discretionary check. This is a locally expanded authority."
          },
          {
            "element": "Facility use fees—general authority to charge fees sufficient to recover direct and indirect costs with Board-adopted fee schedules",
            "classification": "Locally Discretionary",
            "statutory_basis": "TEC §11.158",
            "supporting_quote": "None",
            "verification_method": "unverified",
            "litigation_status": "None identified",
            "local_additions": "No verbatim statutory text was retrievable for TEC §11.158. Per the grounding rule, without a supporting verbatim quote from the statute text, this element cannot be classified as Permitted by Law. The District's decision to charge cost-recovery fees, enumerate eligible cost categories, and vary fees by user type, timing, nonprofit status, and similar factors is classified as Locally Discretionary. The prior policy also charged usage fees pursuant to a Board-published schedule."
          },
          {
            "element": "Requirement that Board adopt a fee schedule before any District Facility may be made available for use",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District imposes a procedural prerequisite that no facility may be approved for use unless the Board has adopted a fee schedule for that facility. This is a local governance choice not required by any statute in the analysis."
          },
          {
            "element": "Authority to assess additional fees for staff, security, restoration, health/safety, and large-scale or special events beyond published fee schedules (Facility Use Requirements item 6)",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District reserves discretionary authority to assess additional charges beyond published fee schedules for specified cost categories and special events. The prior policy reserved a similar right. No statute in the analysis requires or expressly authorizes this specific mechanism."
          },
          {
            "element": "Restriction that only the Board may waive or modify published fees by formal Board action (except as expressly authorized in policy)",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "This procedural restriction consolidating fee-waiver authority in the Board is a local governance choice. The prior policy similarly restricted fee waivers to Board approval. No statute mandates or prohibits this restriction."
          },
          {
            "element": "Complimentary use for Campus-Affiliated Facility Users subject to availability and reasonableness",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District elects to grant complimentary facility use to PTA/PTO organizations, booster clubs, Board committees, employee organizations, and designated groups. No statute in the analysis requires or expressly authorizes this specific benefit. The prior policy provided similar treatment for qualifying parent/teacher/employee organizations. This is a continued local policy choice."
          },
          {
            "element": "Discretionary complimentary or reduced fees for Employee Facility Users and Student Activity Users consistent with cost-recovery objectives",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District creates discretionary authority to offer reduced or complimentary fees to Employee Facility Users and Student Activity Users subject to cost-recovery constraints. The prior policy granted automatic discounts to school employees for nonschool camps, clinics, workshops, and lessons. The new policy makes discounts discretionary rather than automatic—a local policy shift with no statutory basis in the analysis."
          },
          {
            "element": "Waiver of fees for public meetings sponsored by state or local governmental agencies",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "unverified",
            "litigation_status": "None identified",
            "local_additions": "No verbatim statutory text was retrievable for any statute that would compel or expressly authorize this fee waiver. The policy retains this waiver from the prior policy and notes it applies 'as otherwise required by law,' which suggests a possible external statutory basis not captured in the statute analysis. Per the grounding rule, without a supporting verbatim quote, this element is classified as Locally Discretionary. If a specific statute compels this waiver (e.g., Texas Local Government Code), that would elevate this element to Required by Law, but no such text is present in the statute analysis."
          },
          {
            "element": "Annual estimate of cost to the District of complimentary or reduced fees",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District commits to annually estimating the cost of complimentary or reduced fees. This is a local fiscal transparency measure with no statutory requirement or authorization in the analysis."
          },
          {
            "element": "Grounds for denial, cancellation, and permanent or temporary revocation of facility use (including discretionary revocation for any reason, item 18)",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District reserves broad authority to deny, cancel, or permanently revoke facility use for specified and wholly discretionary reasons. The new policy's item 18 ('for any reason') significantly expands the prior policy's narrower cancellation grounds (interference with school activities or excessive wear). No statute in the analysis requires or expressly authorizes this scope of revocation authority."
          },
          {
            "element": "Requirement to maintain publicly accessible website or comparable electronic platform with Board policies, fee schedules, and facility-use applications",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District elects to maintain a public electronic platform with all relevant policies, fee schedules, and applications. This is a local operational and transparency choice not required by any statute in the analysis."
          },
          {
            "element": "Electronic system for District full-time exempt employees to volunteer as facility monitors, with optional training and qualification requirements",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District creates a new voluntary staffing mechanism for employee monitors and reserves authority to require training. This is a local operational innovation with no statutory basis in the analysis."
          },
          {
            "element": "Emergency or disaster waiver authority for Superintendent with Board notification",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District retains from prior policy the authority for the Superintendent to authorize facility use by civil defense officials and waive policy provisions during emergencies, with Board notification as soon as practicable. No statute in the analysis requires or expressly authorizes this specific mechanism. It is a local governance choice consistent with good-practice emergency management."
          },
          {
            "element": "Appeals process for decisions under this policy through District grievance processes",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District incorporates facility-use decision appeals into its standard grievance processes. This is a local procedural choice ensuring due process. No statute in the analysis mandates this."
          },
          {
            "element": "Implementation deadline of December 31, 2026, including Board approval of fee schedules",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "District self-imposes a transition timeline for full policy compliance including Board approval of fee schedules by December 31, 2026. This is a local implementation deadline with no statutory basis."
          }
        ]
      },
      "compliance_summary": [
        "Religious Organization Access: State law S.B. 2986 (passed in 2025) allows Texas school districts to permit religious organizations to use school facilities. This policy reflects that option by listing religious activities as an approved type of facility use.",
        "Child Abuse Reporting Rules: State law TEC §38.004 requires school district employees to report suspected child abuse. This policy goes further by also requiring outside groups using district facilities to follow reporting rules and cooperate with investigations — a choice the district made on its own beyond what the law requires.",
        "New User Categories and Scheduling Order: The district created five new official categories for people and groups who want to use school facilities, and set a priority order for scheduling. These categories and the priority system are not required by state law — the district designed them on its own.",
        "Facility Use Fees: The district may charge fees to outside groups using its facilities, and those fees are based on a schedule approved by the school board. No facility can be made available until the board has formally adopted a fee schedule for it.",
        "Broad Cancellation Authority: The district can deny, cancel, or permanently revoke facility use for a wide range of reasons, including for any reason at its discretion. This is a local policy choice that goes beyond the narrower cancellation rules in the previous policy.",
        "Appeals Process: People or groups whose facility use requests are denied or revoked can appeal through the district's standard grievance process. This is a local procedural step the district chose to include — no state law requires it."
      ]
    },
    {
      "date": "2026-02-17",
      "school_year": "2025-2026",
      "action": "unknown",
      "result": "unknown",
      "summary": "This is a comprehensive rewrite of Conroe ISD's GKD (Nonschool Use of School Facilities) local policy. The update introduces new defined categories of facility users (District Facility, Facility User, Campus Affiliated Facility User, Employee Facility User, Student Activity, Student After School Facility User), replaces the old paper-based application process with an online portal system, restructures scheduling priorities into a formal numbered hierarchy, overhauls fee structures with detailed provisions for different user categories, and replaces the old \"Special Provisions\" and \"Required Conduct\" sections with a new comprehensive \"Facility Use Requirements\" section, while adding a transition deadline of August 31, 2026.",
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2026-02-17_regular",
      "confidence": "medium",
      "source_redline": "GKD_LOCAL.pdf",
      "compliance_assessment": {
        "classification": "Locally Discretionary",
        "elements": [
          {
            "element": "Creation of new defined user categories (District Facility, Facility User, Campus Affiliated Facility User, Employee Facility User, Student Activity, Student After School Facility User)",
            "classification": "Locally Discretionary",
            "statutory_basis": "TEC §11.151(c)",
            "supporting_quote": "The trustees may adopt rules and bylaws necessary to carry out the powers and duties provided by Subsection (b).",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The statute authorizes general rulemaking but contains no requirement or express permission to define facility-user categories. The specific taxonomy of six user categories is entirely the district's own structural choice with no statutory analog."
          },
          {
            "element": "Replacement of paper-based application process with an online portal system",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "No statute cited in the analysis requires or expressly authorizes an online portal over any other application mechanism. The choice of an online portal is a purely operational and administrative decision by Conroe ISD with no direct statutory basis."
          },
          {
            "element": "Formal numbered scheduling priority hierarchy for facility use",
            "classification": "Locally Discretionary",
            "statutory_basis": "TEC §11.151(c)",
            "supporting_quote": "The trustees may adopt rules and bylaws necessary to carry out the powers and duties provided by Subsection (b).",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "While TEC §11.151 broadly permits the board to adopt rules governing district property management, no statute requires or specifically authorizes a tiered priority structure for scheduling. The numbered hierarchy, its specific ordering, and which user categories receive priority are entirely local design choices."
          },
          {
            "element": "Overhauled fee structures with detailed provisions differentiated by user category",
            "classification": "Locally Discretionary",
            "statutory_basis": "TEC §11.151(a)",
            "supporting_quote": "receive bequests and donations or other moneys or funds coming legally into their hands",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "TEC §11.151(a) permits the board to receive funds lawfully obtained, providing background authority to charge fees for facility use. However, no statute in the analysis requires or expressly authorizes a specific fee schedule, fee differentiation by user category, or any particular fee structure. The detailed fee framework is a district-originated policy choice."
          },
          {
            "element": "Replacement of 'Special Provisions' and 'Required Conduct' sections with new comprehensive 'Facility Use Requirements' section",
            "classification": "Locally Discretionary",
            "statutory_basis": "TEC §11.151(c)",
            "supporting_quote": "The trustees may adopt rules and bylaws necessary to carry out the powers and duties provided by Subsection (b).",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "The restructuring and consolidation of conduct and operational requirements into a new section is a drafting and organizational choice by the district. No statute in the analysis mandates the content, format, or existence of a 'Facility Use Requirements' section. The board's general rulemaking authority under TEC §11.151(c) provides background governance authority, but all substantive content choices are locally discretionary."
          },
          {
            "element": "Transition deadline of August 31, 2026",
            "classification": "Locally Discretionary",
            "statutory_basis": "None",
            "supporting_quote": "None",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "No statute cited in the analysis requires or authorizes any specific implementation deadline. The August 31, 2026 transition date is entirely a district-selected administrative timeline with no statutory compulsion."
          },
          {
            "element": "Overall board authority to govern nonschool use of school facilities",
            "classification": "Permitted by Law",
            "statutory_basis": "TEC §11.151(a)-(c); TEC §11.1511",
            "supporting_quote": "the trustees as a body corporate have the exclusive power and duty to govern and oversee the management of the public schools of the district",
            "verification_method": "verbatim statute text",
            "litigation_status": "None identified",
            "local_additions": "TEC §11.151 broadly vests governance and management of district property in the board and permits rulemaking, but no statute in the analysis specifically requires the district to adopt or maintain a facility use policy at all. The decision to have such a policy and to comprehensively rewrite it is the district's own exercise of permissive board authority. TEC §11.1511 adds authority to enter into contracts and delegate superintendent authority, providing further permissive grounding. No mandatory language compels a facility use policy or any particular rewrite."
          }
        ]
      },
      "compliance_summary": [
        "Board Authority Over Facilities: Texas Education Code §11.151 gives school boards broad authority to manage district property and adopt rules about its use. This policy rewrite is the district's own choice to exercise that authority — no state law required it to update or maintain a facility use policy.",
        "New User Categories: The updated policy creates six defined categories for people and groups who want to use school facilities, such as campus-affiliated users and employee facility users. State law does not require or describe these categories; the district designed this classification system on its own.",
        "Online Application Portal: The policy replaces paper applications with an online portal for requesting facility use. No state law requires or specifically allows an online system over any other method — this is an administrative choice made entirely by the district.",
        "Scheduling Priority System: The policy sets up a numbered priority list that determines which users get first access to facilities when there is scheduling competition. Texas Education Code §11.151 gives the board general authority to manage district property, but the specific ranking order and structure were designed by the district without any state requirement to do so.",
        "Fee Structure by User Type: The policy establishes a detailed fee schedule that charges different amounts depending on which user category is requesting the facility. Texas Education Code §11.151(a) permits the board to receive funds lawfully obtained, but the specific fees and how they differ by user type are decisions made entirely by the district.",
        "Transition Deadline: The policy sets August 31, 2026 as the deadline for moving to the new system. No state law requires this date or any specific implementation timeline — it is a scheduling decision made by the district."
      ]
    },
    {
      "date": "2025-12-16",
      "school_year": "2025-2026",
      "action": "first_reading",
      "result": "first_reading",
      "summary": "This update to Conroe ISD's GKD (Local) policy adds a new \"Religious Organization Use\" section that explicitly permits religious organizations to use district facilities for worship, services, sermons, or assemblies, subject to standard terms and fees (unless waived by the Board), and holds them liable for any damages incurred during use.",
      "changes_added": [
        "Religious Organization Use section (new heading and full text): 'The District may allow a religious organization to use the district's or school's facilities to host religious worship, services, sermons, or assemblies only if the facility use does not interfere with the District's educational mission (see GKD Legal for clarification). A religious organization shall follow the District's standard terms and pay the District's standard fees for usage, unless the Board waives the fees. A religious organization shall be liable for any damages while utilizing district facilities.'"
      ],
      "meeting_notes_url": "https://cisd-meetings.boardmonitor.app/meeting.html?id=2025-12-16_regular",
      "confidence": "high",
      "source_redline": "GKD_LOCAL.pdf",
      "notes": "The only redlined (red underlined) text appears on page 2 under the new \"Religious Organization Use\" heading and its accompanying paragraph. All other policy text is in black (unchanged). No red strikethrough/removal text was detected. The cover page title reads \"Discuss Revisions to Board Policy GKD (Local),\" indicating a first reading."
    }
  ],
  "timeline_legal": [],
  "policy_connect_url": "https://policyconnect.org/policy/conroe-isd/GKD"
}