or to develop an employability development plan. Presumably, in most cases, if the individual is job ready, he or she has been placed in an unsubsidized

job during the job search assistance program.

Section 265(a)(1):

definition of "project."

This raises a serious problem in connection with the

In section (3) (19) of the Act, specifically, projects are defined as a task or group of related tasks which will be "completed within a definable period of time." Unfortunately, many of the most useful public services cannot legitimately meet this part of the definition. An ongoing day care project which benefits clients with child care while providing useful employment is eliminated by this definition. With an 18-month limit on individual participation, certain "permanent" project activities could be provided, so long as those activities would not otherwise be available through local tax dollars. Section 265(a): Paragraphs (2) and (3) are meaningless so long as the

cost limitations of section 264(a) are in effect.

Section 265(a)(5): Delete. This requires that jobs be held open every time a participant terminates. Whether the prime sponsor chooses 30 or 45 days to freeze the position, it poses an unnecessary hardship on the employing agency and seriously reduces the prime sponsor's ability to manage its own program funds.

Section 265(b)(1): Delete. It is essential that participants under this

title be treated equitably with other enrollees.

Section 265(c) (2): This would not be necessary if prime sponsors are given the first right of refusal on the job search program.

Section 266(1)(C): This uses different language than currently in CETA. We expect that implementation of this fine distinction may create confusion that makes it impossible for prime sponsors to comply with the Act.

Section 3(33): We urge a simplification of these definitions. We suggest that "principal earner" be deleted. Instead, simply require as a part of eligibility that only one adult per family participate. If, subsequently, a second adult attains unsubsidized employment, it should not be necessary to terminate the family member already a part of CETA. In other words, in addition to the family's eligibility for a welfare program, it should only be necessary to assure at the time of application and/or enrollment that no other adult is employed or enrolled in CETA.

Senator NELSON. Thank you very much.

Our next witness is the Honorable Carol Bellamy, city council president, New York, appearing on behalf of the National League of Cities.

Your statement will be printed in full in the record. You may present it however you desire.

STATEMENT OF HON. CAROL BELLAMY, CITY COUNCIL PRESIDENT, NEW YORK, N.Y., APPEARING ON BEHALF OF THE NATIONAL LEAGUE OF CITIES

Ms. BELLAMY. Thank you very much, Mr. Chairman. I am Carol Bellamy, president of the council in the city of New York, and chair of the National League of Cities Human Development Committee.

I'm pleased to be here today to testify on behalf of the League of Cities, and its 15,000 cities which it represents. I will testify first on the welfare reform jobs proposal now pending before your subcommittee; and secondly, on the youth employment measures.

First, I would like to say that while relatively few cities-and my town is an exception-have direct responsibility for the administration of income support programs, city officials recognize the impact that dependency has on the quality of life in our urban areas. Unemployment has been well documented as one of the root causes of many other urban ills, rising crime, delinquency rates, disintegration of families, deterioration of housing, poverty, outmigration from inner cities, and inequality between races and genders.

Individuals who are employed not only enjoy the economic rewards of their job status, but respect within their families and the community, and personal dignity as well.

We firmly believe that job opportunities for all persons should be one of the highest priorities of this Nation. In June of last year, I chaired a League of Cities task force to review the administration's welfare reform proposals, both the cash assistance and the employment and training components.

The testimony I present today will be based on the analysis the members of the task force conducted.

Before dealing with the specifics, I wish first to advise you of the major concern expressed by the task force members. As this subcommittee knows well, Congress totally revamped and revised CETA in the last Congress. We city officials as prime sponsors are just now beginning full implementation of that revised program, which I shall call for purposes of my testimony the new CETA, because it is after all an entirely new and completely restructured employment and training program.

While many of the criticisms leveled against our local administration of this program may be valid, we believe it is unrealistic to expect a positive measurable result when the rules of the game never remain constant long enough to develop a smoothly functioning employment system.

Indeed, we believe that our operation of the CETA system has demonstrated an ability to adjust with remarkable speed to new and changing circumstances, and that we have accomplished the stated congressional objective, employing the unemployed.

What we see in the administration's job proposal is yet another attempt to redirect and restructure a program that in its very short history has scarcely had a year of operation without some major alteration. The new CETA in our opinion already contains the elements appropriate to target employment and training opportunities to the most severely economically disadvantaged. Certainly the new CETA's more restrictive eligibility criteria moves substantially in the direction of providing the preponderance of employment and training funds to assist precisely the individuals most in need of assistance.

However, the new CETA does not go so far-and I think wiselyas to exclude single individuals and childless couples from participation who may be equally economically disadvantaged as unemployed parents. Many of these single individuals and childless couples have no alternative support systems available to them since they are ineligible for AFDC, and in many cases, also for SSI. The full burden of providing assistance to these needy individuals falls entirely on State and local governments participating in general assistance programs.

In New York City, for example, we have over a hundred thousand recipients on home relief, which it-we call it home relief. It's generally called general assistance-of whom we estimate approximately 30,000 are employable. Thirteen thousand of these individuals are currently employed in some form of public activity to meet State requirements that welfare recipients work for their benefits. The preponderance of these individuals are between the ages of 17 and 30, and included among them are a substantial number of minorities, both black and Hispanic.

The administration's proposals to redirect more than half of the public service jobs available under CETA to families with children. will significantly reduce any form of Federal assistance available to economically disadvantaged single and childless individuals. Consequently, they will be forced to rely more heavily on State and local assistance.

Since our major premise is that poverty is a national problem requiring national solutions, we believe that job programs, both training and public service employment, should be available to a broad mix of economically disadvantaged individuals. One segment of the Nation's needy population should not be benefited at the expense of another.

While we support coordination of employment related programs such as WIN, the employment service, and CETA, to reduce overlap and duplication, and to broaden the effectiveness of current expenditures, we believe such coordination cannot be accomplished by Federal mandate. Cooperation and coordination only work effectively where such arrangements are ultimately voluntary.

The dominant State role provided for in the administration job program at the expense of existing local government planning and operational arrangements will not work as currently drafted, and has the potentional to undo the achievements thus far realized through local efforts.

We recognize the validity of attempting to maximize the effectiveness of existing programs, and recommend that at a minimum, States be required to involve local elected officials substantially in

the development of the State plan coordinating employment related activities, and at the same time that the local chief elected officials approval of that plan be required prior to its implementation.

The prime sponsor's right to complain to the Secretary of Labor that it is unsatisfied with a given State plan is not sufficient to guarantee willing and effective local government participation.

Since the legislation proposed by the sdministration appears at least from the League of Cities' perspective to permit the employment service to cream from among the pool of eligible individuals, I would like to raise a question concerning the time limits on participation in the administration's proposal. Previous speakers have also raised this.

As we understand it, heads of household referred to the prime sponsor for employment under the administration's proposal may participate in public service jobs for 78 weeks. They are then required to go through another 8-week job search period, and if unsuccessful in locating unsubsidized employment, may be placed again in a subsidized job. This clearly creates a disparity of treatment between family members and all other CETA participants. Family members are permitted to participate in the program indefinitely. All other individuals are limited to this 78-week participation period.

Insufficient account is taken of the individual's capacity to develop appropriate job skills likely to result in securing unsubsidized permanent employment.

It has been our experience as prime sponsors that many CETA eligible individuals-this includes welfare recipients and nonrecipients require a substantially longer participation period in training and jobs programs than is allowable. The assumption at least for those placed in public service employment, that it is possible to move a significant number of individuals with little or no attachment to the work force from a training program or public service employment to self-sufficiency within this 78-week period, and thereby remove them from the welfare roles, is in the opinion of the League of Cities, overly optimistic.

We believe the training in jobs programs can and will be effectively ultimately if they can be tailored to the needs of the individual participants.

We cannot take an individual lacking basic skills, lacking in concept of the daily routine of work, and perhaps with numerous physical and other related problems as well, and achieve successful transition to unsubsidized employment within the permissible time frame.

Efficient and rational accommodation of individuals with little attachment to the lab or force, cannot be achieved overnight. Performance standards should be keyed to achieving long-term employment, rather than merely to immediate placement.

Others, to be sure, require far less assistance to make the appropriate transition and should be encouraged and aided in moving through the system more rapidly. Perhaps there will always be malingerers and sloppy administrators, but I believe Congress should not lose sight of our vested interest in seeing these programs succeed. There's no better legacy that we can leave our

constituents-your constituents, my constituents-than the permanent improvement in the quality of life which can be realized when individuals become bona fide selfsufficient members of the Nation's work force.

Mr. Chairman, I am aware that you and others on this subcommittee are sympathetic to the difficulties we are encountering with the average wage provisions. I believe, however, that it is important to raise this issue at every opportunity. There are few, if any, positions in city government, and far too few to meet the need in the private nonprofit sector at the wage levels now permitted. We understand the fiscal constraints facing the Federal Government, and the reluctance to increase spending, particularly for what are commonly perceived to be, at least in this day and age, unpopular social programs. Perhaps it would be appropriate for Congress to reconsider granting some flexibility in wages by permitting us to supplement these wages from local funds. Many localities would be willing to make a commitment of admittedly scarce local revenues where necessary to insure the success of the program.

There are relatively few jobs at the local government level that cannot at some point be duplicated in the private sector. Consequently, experience in a bona fide city job should enhance the target population's mobility in the overall job market. Permitting more flexibility in supplementing wages will also enable those of us at local government to coordinate other federally funded activities, such as CDBG, UDAG, and EDA, into a comprehensive job creation effort with CETA.

Mr. Chairman, I'd like now to turn to the second issue before you today.

As League of Cities did with respect to welfare reform, we also convened a task force of city officials to examine the causes of the Nation's unacceptable rates of unemployment among young people, and to consider some possible solutions.

This task force was chaired by council member Jessie Rattley of Newport News, Va., who is the new president of the National League of Cities. It met last summer, and the testimony I present today will in large part be based on the recommendations of this youth task force.

We are pleased to note that some of our recommendations have been incorporated into the administration's proposed youth legislation. I must say, however, as we pointed out with respect to the revision of CETA, the administration's youth employment proposal again raises the prospect of having to deal with significant revisions to a youth employment initiative which itself is only 3 years old.

Again, I think it fair to presume that the first year of the program involves the development of regulations at the Federal level. Next, local governments must spend time learning, understanding, and developing a rational program consistent with these regulations. Then, programs are actually implemented.

The time lapse from enactment to full implementation is usually 18 months. We are talking, then, about a program that is only 18 months old.