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place the responsibility or blame for this inattention to one of our

children's most basic needs. We need action.

Recommendations

We need the HEW Office of Education to approve a new school for the Antilles Consolidated Schools at Fort Buchanan. We need Congress

And we

to appropriate the required funds to construct this school. need the ACSS Board, Council, and Administration to do their part in securing a new school for our children.

As parents and taxpayers who support ACS, we want our schools to function economically and efficiently in the best interest of our children with open communication between administration, teachers,

and parents.

There are two ways this can be achieved.

1. Expand the school board and school council to have Federal agency representation proportionate with civilian enrollment. 2. Enlarge and strengthen the parents' organization.

As parents we plan to enroll interested parents in our organization during registration on 8 August 1977. With names and addresses we can send a parents organization newsletter announcing our meetings, ACS calendar of monthly events, and suggestions of ways in which we can cooperate with ACS for the educational benefit and enrichment of our children. It is our hope to involve the school administration, teachers, and parents working together for the continued improvement of our children's education.

TABLE 1

CONTRIBUTION OF MILITARY AND CIVILIAN FEDERAL AGENCIES
TO STUDENT ENROLLMENT AT ANTILLES CONSOLIDATED SCHOOLS,
FORT BUCHANAN, PUERTO RICO.

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**Including qualifying dependents from 52 Federal agencies in the

San Juan area.

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I received your letter of July 25, 1976 and can assure you that I share your concern.

The antilles Middle School Campus has been a problem area for many years, and we have tried to arrive at a solution, but to no avail.

As you know, Public Law 815, the School Construction Act, has suffered from critical funding shortages for several years, and I have been informed on many occasions that there are no funds available with which to alleviate the deplorable conditions at the school.

I regret that I must respond to your letter in this manner, however, I can offer no solution at this time.

The U.S. Office is currently conducting an in-depth analysis of conditions of military base schools; and final recommendations will be sent to the Secretaries of the Department of Health, Education and Welfare and the Department of Defense. The recommendations, however, will be no guarantee that the required construction funds will be made available.

I am sending a copy of this letter and am taking the liberty of enclosing a copy of your letter to our Central Office.

Thank you for your interest and concern in this important matter.

Yours truly,

Robert R. Watkin's

Robert R. Watkins

Senior Program Officer

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The Acting Commissioner's office has referred your letter of July 25. concerning the middle school at Fort Buchanan to this office for reply.

The program within the Office of Education responsible for alleviating the conditions described in your letter is the school construction program authorized under Public Law 81-815. However, that program has been short funded since Fiscal Year 1967, a condition which has had a direct bearing on our inability to fund an eligible application to construct new schoolhousing facilities to replace the temporary wooden buildings made available on Fort Buchanan several years ago by the Department of the Army. Incidentally, the use of those temporary facilities was not suggested by the Office of Education. Rather, their use represents an arrangement between the Antilles Consolidated School System which operates them and the local military command, in lieu of what to them seemed like less desirable alternatives. The Office of Education neither sanctioned nor disapproved the arrangement.

Following the initial request for new junior-senior high school facilities in June of 1966 under Section 10 of Public Law 81-815, a number of factors caused delays to occur in the provision of those facilities. A construction project was authorized tentatively in September of 1966; however, at the request of the Federal installation, and after review by this office, the proposed project was reviewed and enlarged twice because of increased pupil membership requirements. Ultimately, final plans and specifications for the enlarged project were approved in October of 1969. However, due to limitations imposed upon obligations and expenditures as a result of Public Laws 90-218 and 90-364, coupled with the President's Construction Reduction Plan, it was not possible to proceed further with the project in Fiscal Year 1970.

Subsequently, it became necessary to classify all Section 10 school construction projects, including those previously approved but for which construction contracts had not been awarded and funds therefor obligated, according to their relative priority. That action was

influenced by two factors: First, Public Law 91-230, approved April 13, 1970, amended Public Law 81-815 to make applications under subsections 14(a) and 14 (b) of that Act equal in priority for payment purposes to applications filed under Section 10. Second, it was and remains apparent that appropriated funds are not sufficient to fund all applications under Sections 9, 10, and 16, and those under subsections 14(a) and 14(b) which, by priorities established in the Act, must be funded before any other applications may be considered.

In the period from Fiscal Year 1967 to the present, appropriations for impacted area school construction have been made in amounts ranging from $13 million to $20 million annually. That level of funding has enabled this division to meet only a few of the highest priority construction needs as prescribed in the basic law. With respect to the direct federal construction of school facilities on military installations, those restrictions became more stringent in Fiscal Year 1972 when appropriations language was inserted which required that practically all of the Public Law 81-815 funds made available be expended to fund applications eligible under Sections 5 and 14 of the Act, thus leaving only about $1 million per year for emergency repairs to existing school facilities that had been previously constructed under Section 10. Repair of the temporary wooden facilities at Fort Buchanan has not been appropriate because they were not constructed with funds authorized under Section 10, nor are they under permit to the Commissioner of Education. Applications under Section 5 of the Act (grants to local educational agencies serving military installations) were not fundable from Fiscal Year 1968 through 1971.

In 1969 we realized, in the face of short funding, that we were receiving and would continue to receive requests for the use of alternative procedures to provide needed school facilities on Federal property. alternative procedures were expected to include the rehabilitation of existing non-school facilities and other methods that would seek to accomplish by indirection that which could not be accomplished by direction, i.e., the construction of needed new school facilities. We also realized that children attending on-post school facilities might be forced into double-session attendance patterns because of the lack of adequate facilities, or that other undesirable arrangements might have to be made.

Despite the imminence of these undesirable conditions, including those known to exist at Fort Buchanan, the Deputy Associate Commissioner, Bureau of Elementary and Secondary Education, approved a policy statement whereby this division would not authorize. any expenditure of funds under Section 10 of Public Law 81-815, or under Section 6 of Public Law 81-874, for the purpose of providing additional school facilities on Federal property through purchasing, leasing, renovating, remodeling or

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