IN RE PETITION FOR AUTHORIZATION TO CONDUCT A REFERENDUM ON THEÂ WITHDRAWAL OF THE BOROUGH OF WOODCLIFF LAKE FROM THE PASCACK VALLEY REGIONAL SCHOOL DISTRICT (NEW JERSEY DEPARTMENT OF EDUCATION), A-4084-13T2

Background

Pascack Valley Regional School District comprises four municipalities: River Vale, Hillsdale, Woodcliff Lake, and Montvale; each operates PK–8 districts and sends 9–12 students to two regional high schools (Pascack Valley and Pascack Hills).
Historically tax levies were apportioned per pupil; 1975 law forced apportionment by equalized property value; 1993 statute allowed reversion to per-pupil apportionment only by unanimous consent of constituent municipalities.
Woodcliff Lake hired experts and prepared feasibility studies (including enrollment projections and financial models) concluding withdrawal or dissolution would be viable and would produce substantial tax savings for Woodcliff Lake (and Montvale), while increasing costs for River Vale and Hillsdale but not to an "excessive" level.
Appellants (River Vale and Hillsdale) submitted a counter-feasibility report warning of educational program losses, administrative duplication, and multi-million-dollar operational/technology/transportation costs if withdrawal occurred.
The Bergen County Superintendent recommended against withdrawal; Woodcliff Lake petitioned the Commissioner and Board of Review for authorization to hold a referendum under N.J.S.A. 18A:13-56. The Board granted the petition, finding none of the statutory denial grounds were met. River Vale and Hillsdale appealed.

Issues and Key Cases Cited

Issue	Plaintiff's Argument (River Vale & Hillsdale)	Defendant's Argument (Woodcliff Lake / Board)	Held
1) Whether Woodcliff Lake may use the withdrawal statute to change tax allocation	Withdrawal statute cannot be used as vehicle to effect tax-apportionment change; petition improperly seeks that outcome	Withdrawal statute authorizes referendum on withdrawal; tax allocation consequences are collateral and properly considered in the Board's review	Court: Petition properly brought under N.J.S.A. 18A:13-56; Board need not treat the request as an improper attempt to change tax method
2) Whether the Board was required to articulate independent legal/educational/financial reasons to grant the petition	Board erred by failing to articulate a legally sufficient basis to authorize referendum	Board’s role is circumscribed: it must deny only if one of four statutory grounds is met; otherwise it must grant authorization	Court: Affirmed; Board correctly applied statutory standard and need not supply other reasons to grant petition
3) Whether withdrawal would impose an "excessive debt burden" on remaining districts or withdrawing district	Appellants: Financial models show multi‑million dollar impacts that are excessive and justify denial	Woodcliff Lake experts: projected savings for Woodcliff Lake and manageable increases for others; borrowing margin adequate; no excessive debt identified	Court: Substantial record evidence supports Board’s finding no “excessive debt burden”; appellants failed to show arbitrariness
4) Whether withdrawal would prevent maintenance of an efficient, properly graded school system (including insufficient pupils)	Appellants: Withdrawal would reduce program offerings, require duplication, harm curricular opportunities and staffing	Woodcliff Lake experts: remaining districts have facilities, adequate enrollments, and could maintain thorough and efficient education; any negative effects would be minor	Court: Board reasonably concluded remaining districts and Woodcliff Lake could maintain efficient, properly graded systems; no statutory grounds for denial met

Key Cases Cited

In re Petition for Authorization to Conduct a Referendum on the Dissolution of Union Cty. Sch. Dist. No. 1, 298 N.J. Super. 1 (App. Div.) (discusses narrow scope of Board review under withdrawal statute)
In re Petition for Authorization to Conduct a Referendum on the Withdrawal of North Haledon from the Passaic Cty. Manchester Reg'l High Sch. Dist., 181 N.J. 161 (2004) (interpreting statutory grounds for denying regional withdrawal)
In re Petition for Authorization to Conduct a Referendum on the Withdrawal of Oradell from the River Dell Reg'l. Sch. Dist., 406 N.J. Super. 198 (App. Div. 2009) (examines meaning of "excessive debt burden" and related financial considerations)
Stallworth v. (In re), 208 N.J. 182 (2011) (standard of review for agency decisions; presumption of reasonableness)
In re Carter, 191 N.J. 474 (legal framework for reviewing agency action and three-part arbitrary/capricious analysis)