First, it sets up national priorities which do not necessarily speak to the priority problems of local communities. The concept of "maximum feasible participation" loses its meaning if the priorities do not emerge from the local community as a result of its own experiences and as a result of the expression of the people who are most affected by poverty. For instance, some communities may already have successful preschool programs but yet would find that their basic allocation has been reduced because of this provision in the law. The question again is that of local determination versus Federal dictation. A second point is that our experience has been that there exists a tragic shortage of title II funds to carry out what many local communities consider the necessary first steps in the "building block" approach to community action. Rather than cut up the available funds under title II, the most important section of the act, every effort should be made to increase the total amount without specific program allocation in an effort to further promote the concept of local determination by those who are closest to the community problem.

A third concern is that section 211 of the Economic Opportunity Act of 1964 which provides for preference to programs and projects. which are components of a community action program is being deleted. We feel again that community action agencies and their programs must be supported firmly and specifically in their role as coordinators of services.

San Francisco has experienced enough problems to be very sensitive to the dangers in eroding the responsibilities and the integrity of the community action agency. A case in point is that on the basis of this preference clause, two unprecedented and far-reaching agreements have resulted between the San Francisco Economic Opportunity Council and the San Francisco Unified School District, and between the San Francisco Economic Opportunity Council and the local California State Employment Services.

The final concern which I shall mention is in regard to the recommendation which requires that at least 20 percent of title II, section 205 funds be used for independent funding of programs outside of the community action agency. We are somewhat confused as to the intent of this provision. Whatever the reason, it is a dangerous threat to the effectiveness and the integrity of the local community action agency. If the intent is to support groups in the local community unrepresented in the CAA, then this is a backdoor approach. OEO pressure should be to make the local CAA truly representative rather than encourage local components to pull away from the central community action agency.

A much better assignment of these funds would be to provide adequate compensation to low-income board members who frequently are using their limited personal resources in order to participate in the CAP which makes more and more demands on their time and energy as it becomes more effective.

We estimate that some 200,000 of the target area population of San Francisco have been reached and a large percentage have participated in some way in the San Francisco community action program. We have sold to them the concept of individual involvement and self

assistance.

We, therefore, hope that this new idea of local community action with such dramatic potential will not be scuttled by introducing such restrictive legislation before the program is given a fair opportunity to prove itself.

Senator JAVITS. Thank you very much, Mr. Brandon. I understand that yours is reputed to be one of the best community action programs in the country. I congratulate you on it. May I ask, do you see any help to the program in the Economic Opportunity Corporation for which I have introduced legislation?

Mr. BRANDON. I certainly think there is a great need for the introJuction of business techniques and business ingenuity into the overall effort to fight poverty.

While I have not completely been familiarized with the details of the operation of the Corporation, I certainly think the potential is a great one and we would very much like to be a part and would like at least to be consulted on the development of this particular program. Senator JAVITS. Thank you very much. We will do exactly that. Mr. Kurzman will be in touch with you.

Mr. BRANDON. Thank you.

Senator JAVITS. Our next witness is Mr. E. J. Safford, Council of the Southern Mountains, Inc., Berea, Ky.

Mr. Safford, we welcome you to the committee. You used to be here as a correspondent. We hope you are happy in your new work.

STATEMENT OF E. J. SAFFORD, COUNCIL OF THE SOUTHERN MOUNTAINS, INC., BEREA, KY.

Mr. SAFFORD. Thank you very much, Senator. If the Senator will permit, because of his admonition on time I would like to insert my statement and comment on portions of it.

Senator JAVITS. Without objection, the statement will be made a part of the record.

(The prepared statement of Mr. Safford follows:)

PREPARED STATEMENT OF EDWIN SAFFORD, COMMUNITY ACTION TECHNICIAN, COUNCIL OF THE SOUTHERN MOUNTAINS, INC., BEREA, KY.

My name is Edwin Stafford. I work for the Council of the Southern Mountains which has a technical assistance contract with the Office of Economic Opportunity. Under this contract some eighteen Community Action Technicians have worked in seven states in the region known as the Appalachian South helping to develop and administer community action projects and other programs related to the Economic Opportunity Act.

Our technical assistance program has been operative for nearly a year. We have witnessed and participated in all phases of community action. During this time, we have been struck by certain instances in which it has seemed apparent that many of the communities and people with whom we were working were virtually excluded from certain benefits of the Economic Opportunity Act because it simply could not be adopted to their unique rural nature.

I think a most graphic example of how the present Economic Opportunity Act has somehow missed the point in rural areas is the way in which the Work Experience and Training Program, Title V of this act, has operated. Since it is designed basically as a public works program, it assumes that many state and municipal agencies will be able to take unemployed parents and put them to work in areas where they can get training. These state and municipal staff's just don't exist, for the most part, in the Appalachian South. It is not the fault of

the states and municipalities that these staffs do not exist. They are not justifiiable on the basis of population density, or more important, available revenues. Because these staffs do not exist, the Work Experience and Training Program is often little more than a welfare program in which the beneficiaries are required to perform menial work which is useless as training and quite often of little value to the public.

The lesson here, I believe, is that programs for rural areas cannot assume the same sort of base of already existing professional talent in the social and public services area that can be anticipated in the urban areas. The problem of supervision and training of Title V beneficiaries is critical in the Appalachian South. Unless Congress is willing to insist on closer federal supervision of Title V programs in rural areas so that the goal of training can be made more realistic, the current plan to limit participation in the program to two years would be disastrous. I say this because it is obvious that men who have been removing weeds from roadsides or sweeping courthouse floors will be no more employable after two years on Title V than they were before they joined the program. After the two-year stint some new welfare approach will have to be devised for the majority of the men now working on Title V in the Appalachian region.

There are other examples of this same phenomena, i.e., national programs that somehow just don't work in rural areas as they were conceived by their originators. We have encountered examples in Community Action Programs and I believe that some of the changes now being considered in Title II could compound these problems. For example, the proposal to set a minimum amount to be spent on Headstart within each community's overall allotment of CAP funds could cause serious problems in rural areas such as Appalachia. Unlike cities rural counties can vary greatly from each other in terms of their demographic profile. That is to say that the ratio of Headstart aged youngsters to the overall population fluctuates from county to county much more than the same ratio would in large population centers. Yet the proposal to earmark funds for Headstart seems to be based on an overall national average. By holding small rural counties and communities, of which many have been decimated by out-migration of their young people during the past decade, you may be forcing them to spend unrealistically large sums on Headstart.

The proposal to limit the federal contribution to staff salaries of Community Action Agencies to a maximum of $12,500 a year for any one individual would limit the ability of the larger CAP agencies to attract suitable directors and other executives. This will be especially true in the coming year because of the concerted effort by the Office of Economic Opportunity to create large multi-county districts in which a single Community Action Agency has been imposed over many county agencies. The Office of Economic Opportunity's rationale for this multi-county concept has been that it will enable these enlarged Community Action Agencies to attract qualified and experienced people in the $12,000 to $15,000 range. This $12,500 ceiling will effectively reduce the ability of large Community Action Agencies in the Appalachian region to attract desperately needed professionals from outside the region. I might add that in most Appalachian counties local cash contributions are non-existent. The ten per cent in matching funds is usually supplied as "in-kind." Thus unlike urban areas, which could conceivably supplement the federal contribution to salaries with a local cash contribution, the $12,500 federal maximum would in fact set the overall maximum for Community Action Agency salaries in Appalachia.

Mr. SAFFORD. Senator, in my statement I make the point that the 2-year limit in which a person can participate in title V, the WET program, is a dangerous suggestion as it now stands, because most participants in the program will not be ready to participate in private industry after that time.

I believe our experience in the Appalachian South has shown that the training now offered in title V, by and large, will not bring the majority of those in the program to a point where they can apply for jobs in private industry. Furthermore, after discussion of this point with a friend of mine in HEW, he reinforced my feelings by giving me these figures on the title V program of the Commonwealth of Kentucky.

became apparent that there were many thousands who could not benefit from the regular vocational programs even though some were relatively simple. These were the people who lacked fundamental literacy. It was decided that a special project should be developed for these people. The program as presently structured consists of an initial course of twenty weeks in basic education and in prevocational training. Classes meet five days a week for six hours a day with three hours devoted to basic education and three hours to pre-vocational training. There are five prevocational areas and the student spends four weeks in each of these areas. These cover: clerical and marketing, machining and fabrication, service trades, electricity and electronics, and mechanics. Where necessary. training is extended beyond the basic twenty weeks and also, as appropriate, the training is shortened or, in cases of very rapid progress, the student is transferred to one of the regular training programs.

Upon completion of the basic twenty weeks, the student is then placed in one of seventeen special vocational areas specifically set up for Project 3000 trainees. Training in these areas varies in duration from 16 to 48 weeks. These include such trades as electrical appliance repair, clerk-typist, hospital ward clerk, electronics assembler, drapery operator, typewriter service maintenance and garment alterations. In April of this year, there were 874 students enrolled in the basic phase, 850 students in the special vocational training phase and another 150 to 200 in the regular vocational training program.

The administrative structure for carrying out this program is quite complex. The program is administered by the Illinois State Employment Service under the Manpower Development and Training Act. This service has contracted with four vocational schools in Chicago to give the needed training. It has also contracted with the Cook County Department of Public Aid for caseworkers to supply supportive services to the students. Thus each student, in a sense, is handled by three different sets of counselors. The counselors of the Illinois State Employment Service handle the initial interview, the placement in the program, the necessary forms for payments under the terms of the Manpower Development and Training Act, other technical and legal matters and the final job placement. The counselors at the vocational schools deal with the student in terms of his class work, the need for tutoring and other such educational problems. The caseworkers are concerned with family problems, health problems, attendance problems and any and all of the multitude of personal and social problems that can arise.

Those in this special program face many particular and unique problems. They have been educationally deprived; many of them are older persons; most have been unemployed or underemployed for long periods of time. They are being called upon to enter school again. The fears and self-doubts are immense and the slightest illness or family emergency is sufficient to persuade them to miss a class and thus avoid what can be an anxiety provoking situation. All of these problems must be met. I wish now to contrast this with the procedures under the Parents' Opportunity Program. In that program one caseworker dealt with all problems. He called upon the services of other specialists, counselors and psychologists. But the case was completely handled by him. In Project 3000, three sets of counselors are involved and their various activities must be coordinated.

Now, I wish to make it clear that I am not speaking against this present structure. It is realistic in terms of this particular program and represents the type of coordination that already exists between the Department of Health, Education and Welfare and the Department of Labor. Yet, the proposed amendment has as its stated goal the development of such coordination. The coordination exists and I feel certain that it would create administrative confusion to change the structure now.

In addition, the proposed amendment would make such a three-fold structure mandatory for all training programs. But such a structure is just not appropriate to all training programs. Three different counselors dealing with the many complex problems of the man from Tennessee would have created nothing but confusion. In this regard, I wish to call the attention of the subcommittee to the testimony of Dr. Winston before the House Subcommittee: "I would just like to comment that one of the things we do if these people come to us is to explore the use of other training resources in the community. If they can go into a Manpower Development and Training Act Program and we can put in some health services or perhaps needed counseling for the family,

that is just splendid. If there is an opportunity for vocational training under other auspices we would use that other resource rather than making arrangements to provide it directly.

"In other words, the more we can do to work ourselves out of a job here by helping people either get into other training settings, if they are ready for them, or to become equipped to move into the training settings, the better off everybody is. So it is not really an either/or proposition; it is a fact that we have people who, because of the complexity of their problems, are not able to meet whatever the requirements are of certain other types of programs."

To separate the administration of the Title V program and place one part in the Department of Labor and another part in the Department of Health, Education and Welfare is the creation of just such an "either/or" situation. The very nature of the program and the people who must be served requires great flexibility and coordination. The flexibility exists when a single agency is responsible. The coordination exists because it has already been developed. The goals of this amendment are already attained.

This represents my major objection to the proposed amendments. I would, however, like to comment quite briefly upon two other aspects of the amendments. The last sentence of the proposed Section 502 states: "Provided, That such funds may not be used to assist families and individuals insofar as they are otherwise receiving or eligible to receive assistance or social services through a State plan approved under Titles I, IV, V, XVI or XIX of the Social Security Act." It is the obvious intent of this amendment to prevent some states from transferring persons eligible for, for instance, Aid to Dependent Children Assistance, to the Title V program. In effect, this would mean that the Federal Government which only partly matches expenditures under the Social Security Program would be giving full matching for those under the Title V Program. I agree with this goal. But the proposed amendment has a small side effect with which I disagree. In Chicago, persons in Title V Programs who are eligible for Social Security Programs continue to receive the full grant that is due them. However, the Title V Programs frequently involve expenditures above and beyond basic needs. Transportation allowances must be met, special clothing allowances exist and other special grants must be made. Since these needs arise exclusively from enrollment in the Title V Program, the Department of Health, Education and Welfare has ruled that the local agency can receive full reimbursement. In Chicago and Cook County, this amounts to about $2,000 a month. It is a small amount, but in many jurisdictions it could be a significant factor in the development of local programs. I should hope that the amendment could be rephrased to eliminate this impact. Finally, I note in the report of the House Committee that Title V is to be funded in the amount of $119,000,000. This is $41,000,000 below the President's budgetary request, and I hope the Senate will restore this amount. The program deals with a most difficult group of citizens. It has demonstrated a great

deal of success and should be kept at its present level.

Senator JAVITS. Our next witness is Mr. Archie W. Hardwick, executive director, Westminister Neighborhood Association, Los Angeles.

STATEMENT OF ARCHIE W. HARDWICK, EXECUTIVE DIRECTOR, WESTMINISTER NEIGHBORHOOD ASSOCIATION, INC., LOS ANGELES, CALIF.

Mr. HARDWICK. I would like to thank the subcommittee for inviting me here this afternoon.

Westminister Neighborhood Association, Inc., is a settlement center and a multifunctional agency located in the heart of Watts.

Senator JAVITs. Mr. Hardwick, will you be good enough to cooperate by confining your statement to 5 minutes?

Mr. HARDWICK. Yes; I will.

Senator JAVITS. Your statement will be included in full in the record.