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It is evident that approximately 25% of the total federal receipts came from those sections, and without that support, the district would have ceased to exist. Now, we understand that under the proposed tier funding Section 2 is to be funded at less than 100%, and there is apparently no reference made in P.L. 93– 380 to sections 3(c) (4) and 3(e).

SUMMARIZATION

The Douglas School District must have the assurance of full-funding under Section 2, Section 3(c) (4) and 3(e). We respectfully and urgently request that this Committee include, within the language of its appropriations recommendation, provision for funding of these sections. Moreover, we support the proposed legislation submitted by the Honorable Carl Perkins to delay implementation of P.L. 93–380 until accurate statistical data is made available. The delay will provide this and other Districts the opportunity to present the financial implications of the amendments to P.L. 81–874 and allow time for legislative revisions providing these essential federal funds.

Dr. Fish. I would like to restrict my comments to a few points. Traditionally the impact aid groups have been very proud of their ability to produce facts and figures, statistics, information.

We have a great deal of confidence in our data. We think that over the years impact aid has been notable for the small degree of error both in the information we present and the effects of various Federal bills and regulations.

It has been a simple program and it has been, we believe, effective because of that reason.

Today, unlike many witnesses, I must say that I am in a point of confusion and must say I do not know many facts which I believe are necessary for the successful operation of this program in the next year.

As the chairman stated, we have not seen the guidelines yet at the local level for any of the areas of the program. We have participated in a very few limited discussions. There were some regional meetings of the Office of Education.

But we still do not know and do not have confidence in what the impact aid program would look like under 93–380 next year.

We do not know the numbers. We do not know the conditions of the program. We have various concerns about the locations. And at this time we are not even confident of the number of school districts affected.

We are very aware of the basic changes in the law and the inclusion of the low-rent housing students. We support that inclusion.

The addition of the low-rent housing students is consistent with the basic philosophy of the law where the action of the Federal Government has impacted upon a local community.

We also support the inclusion of provisions for the handicapped children of military dependents. This is clearly a service provided to youngsters that is urgently needed and by having the students participating in programs we think that this does the children well and this is our basic responsibility.

We are also concerned about the area of the minor sections of the law, section 2, section 4 and the other sections. Again we are laboring under some confusion as to final guidelines. Final directions have not come out.

Douglas School District is a very good example. I think in their testimony they have 80-percent impact and already the basic premise of impact aid has been violated in the last 3 years as funding from impact aid has declined in proportion to the cost of education.

The district's cost of education has gone actually from slightly above the national average to where they are more than $100 now below the national average for their regular programs. So already they have taken a beating. Twenty-five percent of their funding comes from the minor sections of import aid.

Therefore we are confronted with the fact that here is a school district serving an Air Force base out in South Dakota, a low-expense educational State, and already they have been hurt by the loss of the funds over the last several years from impact aid in comparison with the cost of education and now the minor seetions have been neglected. We feel they have been threatened with a further loss at this time.

The final effects of this we do not know in the confusion of the bill itself.

In consideration of the problem that was encountered and in direct response to the request of the chairman of this committee we have mailed to 4,600 impact aid school districts an elaborate questionnaire which over 2,000 districts have responded to at this time.

The information is included in our testimony, the recap sheets which are laid out by State and congressional district. It includes approximately 1,400 of these reports.

This information was forwarded to the Office of Education to help them in attempting to develop an analysis, an estimate, of what it would cost to fund the complex new bill this year.

The data therefore we believe is consistent with the data that they will present possibly in terms of an entry point.

However we must stress several major problems with it.

One, it went to only the districts that are now or within the last vear have been in the impact aid program. The inclusion of new school districts through the addition of the public housing students was not taken care of.

It did not go to all the school districts of this country. Again, we have not seen the report from the Office of Education. They have in their estimates of need 688,000 low-rent housing students.

We understand that last year or possibly later the Library of Congress was estimating that there were over 900,000 low-rent housing students in this country. There is a discrepancy of approximately 220,000 between what is shown in the figures that are reported to you by the Office of Education and what had been previously estimated by the Library of Congress.

Also we must say that in dealing with the school districts, since the school districts returned the data to us, they have to say, "These are only estimates. These are only guesses when it comes to low-rent public housing students because they have never been funded before."

The districts have reported these. But frankly we did not believe that the same honest searching out of students took place that would take place in a situation in which they were funded. Nany districts in major cities do not report them as part of their survey to the Office of Education.

So we are very concerned about this entry going on the data.

We also are concerned that regulations governing the handicapped program are not included. We are not opposing these sections. We must say again we are supporting these sections. However, we believe that incorporation of these two major new programs into the law for the next fiscal year is about as much orderly change as the program can accomplish.

We bring your attention to the fact that the Office of Education's staff, the SAFA staff, which has a very high reputation in the field or has had a high reputation, has been diminished in numbers and has not been replaced as retirants, illnesses and other factors have reduced the number of people working there.

At the same time a major new program must be cranked up. So at the Federal level they are not prepared. We see no preparation for meeting the challenge of the new laws.

My final statement is: impact aid is part of our general revenues. Under the conditions of the new law as you look at the tier structure and look at our data you will see the overwhelming number of school districts losing a vast amount of income at tier 2.

If the appropriation level does not reach tier 2 we are like a man who is climbing to the top of a cliff. We can't stop at a ledge. We either reach tier 2 and the funding level or we drop back down to the foothills. We drop back down to the bottom of the situation which would mean financial disaster.

In our own case in San Diego this would mean a loss of several million dollars. This is part of our basic support of education and one we cannot afford. It is not a game to us. We cannot afford a Russian roulette with our basic educational programs.

Thank you very much.

Chairman PERKINS. Mr. Husk, do you want to present your testimony at this time? Or does Mr. Bobo want to make a statement?

Dr. Fisi. Vay we turn to Mr. Bobo at this time?
Chairman PERKINS. Go ahead.
[Prepared statement of Thomas Bobo follows:]

PREPARED STATEMENT OF THOMAS A. BOBO, DIRECTOR OF SPECIAL SERVICES,

MONTGOMERY PUBLIC SCHOOLS, MONTGOMERY, ALA.

Mr. Chairman and members of the committee, I come from a section of the country that has a deep appreciation for Impact Aid and the contribution that it has inade to public education. We have been studying the New Law, P.L. 93380, as it relates to Impact Aid, and working among ourselves within the Impact Aid organization to determine its effect. I have talked with a representative group of superintendents as late as Thursday, April 3, 1975. It is their unanimous agreement that a delay until October 1, 1976, for the implementation of various amendments to the Impact Aid program, adopted by Congress last summer as a part of Public Law, 93–380, would be most beneficial. I have conferred with the following superintendents: Dr. V. M. Burkett, Huntsville City Schools, Huntsville, Alabama ; Dr. Byron B. Nelson, Jr., Decatur City Schools, Decatur, Alabama ; Mr. Joseph Pickard, Selma City Schools, Selma, Alabama; and Dr. W. S. Garrett, Montgomery Public Schools, City and County, Montgomery, Alabama.

There is much confusion concerning this law, its payment procedures, eligibility and hold harmless provision. This comes at a time when local boards of education are planning for the 1975–76 school year. Teachers are now being retained or dismissed for the next school year. P.L. 874 supports additional teacher units for many school systems in our state. The Montgomery system alone has 68 additional teacher units that are supported in part or totally by P.L. 874. Most of the systems in our section of the country are in a similar situation.

There is a situation in our state which involves children who attend school in the Phenix City School System, Phenix City, Alabama while their parents are working or serving at Fort Benning across the State line in Georgia. It is my understanding that the Fort Benning Base lies partially within the State of Alabama, Russell County, Alabama, where the Phenix City School System is located. However, the Phenix City School System is separate from the Russell County School System. It is the wish of the people of this area that these children be eligible for P.L. 874 funds; however, their parents do work across the State line. The Chattahoochee River is the dividing line between Alabama and Georgia in this section of the state and there is a portion of the Fort Benning military complex which lies across the Chattahoochee River from Georgia in the State of Alabama.

I point this out to state that there is confusion in the interpretation of the law. It would be most beneficial to the Phenix City School System if a major portion of the new law could be postponed and that a clear definition as to eligibility be rendered in consultation with the local school officials.

We are very interested in the public housing portion of the P.L. 93–380. However, there are uncertainties as to how the children would be counted in some cases, whether A or B. We do have some parents who live in Federal Housing and work on Federal property. The portion of the law which states that “(3) The amount of the payment to any local educational agency which is determined with respect to such agencies under paragraph (1) shall be used for special programs and projects designed to meet the special educational needs of educationally deprived children from low income families,” makes the local educational system know that these funds are limited as to use. We do not know the interpretation that will be made of this portion of the law.

I point out the above uncertainties to state that it is the unanimous opinion of the people with whom I have consulted that changes in P.L. 874 be postponed for one year with the exception of public housing and additional payments for handicapped children of military parents. I believe that working' cooperatively with the Department of Health, Education and Welfare, these two new portions, public housing and payment for handicapped children, could be implemented for the 1975–76 school year. I believe there are many publicly housed children who may not have been counted in the last estimate. The figures in our local system alone indicate that we have over 3,000 publicly housed children out of a student population of 36,000.

The method of funding as to Tier I, II, and III is confusing. If the Montgomery Public School System is funded only through Tier I, it would mean a loss of revenue of approximately $400,000.00. If we are funded through II, the loss would be approximately $20,000.00. This is according to our calculations using the 1974–75 amount of 874 funds as a base. I believe that most local education systems would welcome the opportunity to work cooperatively with the Department of Health, Education and Welfare to know the true dollar effect of the new

law.

Mr. Chairman. I thank you and the members of this committee for your interest and understanding of the educational needs of this nation. I appreciate the opportunity of presenting these views to you.

STATEMENT OF THOMAS BOBO, DIRECTOR OF FEDERAL

PROGRAMS, MONTGOMERY, ALA., PUBLIC-SCHOOLS Mr. BoBo. Thank you, Mr. Chairman, I have prepared a written statement.

I would like to go over some of the highlights of this statement orally, if I may.

Chairman PERKINS. Go ahead, without objection your statement will be inserted in the record.

Mr. Bobo. I come from a section of the country that has a deep appreciation for impact aid and the contribution that it has made to public education.

We have been studying the new law, Public Law 93–380, as it relates to impact aid and working among ourselves within the impact aid organization to determine its effect.

I have talked with a group of superintendents representative of our area. It is their unanimous opinion that this new bill should be delayed until next year.

There is much confusion concerning this law, its payment procedures, eligibility and hold-harmless provision. This comes at a time when local boards of education are planning for the 1975–76 school year. Teachers are now being retained or dismissed for the next school year.

Public Law 874 supports additional teacher units for many school systems in our State. The Montgomery system alone has 68 additional teacher units that are supported in part or totally by Public Law 874. Most of the systems in our section of the country are in a similar situation.

There is a situation in our State which involves children who attend school in the Phenix City school system, Phenix City, Ala., while their parents are working or serving at Fort Benning across the State line in Georgia.

It is my understanding that the Fort Benning base lies partially within the State of Alabama, Russell County, Ala., where the Phenix City school system is located.

However, the Phenix City school system is separate from the Russell County school system.

It is the wish of the people of this area that these children be eligible for Public Law 874 funds. However, their parents do work across the State line. The Chattachoochee River is the dividing line between Alabama and Georgia in this section of the State and there is a portion of the Fort Benning military complex which lies across the Chattahoochee River from Georgia in the State of Alabama.

I point this out to state that there is confusion in the interpretation of the law. It would be most beneficial to the Phenix City school system if a major portion of the new law could be postponed and that a clear definition as to eligibility be rendered in consultation with the local school officials.

We are very interested in the public housing portion of the Public Law 93–380. However, there are uncertainties as to how the children would be counted in some cases, whether A or B.

We do have some parents who live in Federal housing and work on Federal property. The portion of the law which states that:"(3) The amount of the payment to any local educational agency which is determined with respect to such agencies under paragraph (1) shall be used for special programs and projects designed to meet the special educational needs of educationally deprived children from low-income families," makes the local educational system know that these funds are limited as to use.

We do not know the interpretation that will be made of this portion of the law.

I point out the above uncertainties to state that it is the unanimous opinion of the people with whom I have consulted that changes in Public Law 874 be postponed for 1 year with the exception of public housing and additional payments for handicapped children of military parents.

I believe that working cooperatively with the Department of Health, Education, and Welfare these two new portions, public housing and

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