and the other, summer food programs, is without statutory authority. While this division may allow for more efficient administration-a laudable move-it has already provided a rationale for withholding funds left over last summer from this fiscal year's year round non-school food programs.

Section 225.7 (a-1): The filing deadline of April 1 is unreasonable for this year in view of the late date of publication of the proposed rule making. Instead we suggest the following wording:

"1) Applications for participation of special summer programs for summer, 1972, which are filed within (6) weeks of the final publication of these amended regulations shall be given first priority.

2) Applications for participation of summer programs for the following years must be submitted by May 1 of the year. Approval or denial of the application will be made within thirty (30) days or less of the date of filing. Applications received after May 1 shall be reviewed in the order of the date of receipt and shall be approved or denied within thirty (30) days or less of the date of filing.” Section 225.7 (a−1): Delete the proviso that applications shall be considered "to the extent that funds are available for special programs". The size of the federal budget for child nutrition programs has no bearing whatsoever on the requirements for participation of local service programs.

Section 225.7 (a-1): Applications filed before the [designated] deadline shall be considered in the following priority: (1) First, applications from service institutions in economically needy areas serving more than a majority of children from lowincome families and eligible for free or reduced price meals. (2) Second, applications from service institutions in economically needy areas but serving less than a majority of children eligible for free or reduced price meals. (3) Third, applications from service institutions not located in economically needy areas nor serving a majority of children eligible for free or reduced price meals but ones which serve children from low to middle-income families. (4) Applications from service institutions which participated in the program in the prior calendar year.

Section 225.7 (a-1): Delete the following requirement which is irrelevantly and cruelly based on an unknown but, nevertheless, projected federal budget restriction:

"If funds will not permit approval of all applications received prior to April 1. local interest as indicated by the level of local financial support and in-kind contributions shall be considered in determining which applications shall be approved."

The specific focus of this program is on economically needy areas, and yet, outrageously demands that interest in participation be measured by local cash and in-kind contributions.

Section 225.7 (b): The amount of data required to demonstrate that poor economic conditions exist is unreasonably detailed. Only major cities with large bureaucracies could produce such extensive documentation without enormous effort.

This requirement discriminates against small, locally run programs, for example, summer programs conducted by churches or low-income community groups.

Furthermore, the requirement that at least half the mothers in the area be engaged in work outside the home is blatantly sexist and is a misreading of that portion of the statute addressed more specifically to the Breakfast Program.

Section 225.7 (b-1): This requirement that individual applications be submitted for each site serves little use other than to generate additional paper work (which in turn serves to increase the amount of the "in-kind contribution" claimed).

To identify children eligible for free and reduced price meals counters the protection of the anonymity of needy children ensured by the Congress and the laws governing the child nutrition programs. The requirement that service institutions explain the methods they will use to identify needy children is regressive and discriminatory.

We therefore strenuously object to this requirement and suggest that the following wording be deleted: “. a description of . . . and the methods to be used to identify children eligible for participation at the site, including the methods to be used to identify those children eligible for free or reduced price meals."

Section 225.7 (c): Competitive bidding for federal contracts should be required no matter how small that contract may be. If an arbitrary number must be

selected we strongly suggest that any operation serving more than 100 children use a competitive bid procedure.

Section 225.10 (e): This section is unclear and ignores the legislative history of Public Law 92-32 and in particular, the Joint Explanatory Statement of the Committee of the Conference. We have the following objections:

1) The term "severe need" used in the Conference Report is unreasonably translated into the requirement that "all or nearly all the attending children are in need of free meals". We suggest, instead, that that line be deleted and that the only requirement be that the State agency or FNSRO judge whether or not the service institution is unable to contribute financially to the program.

2) There is no real difference between the 80 percentum of the operating costs and 100 percentum of the cash expenditure. The conferees pointed out in their report that they "felt that the Secretary of Agriculture has been unduly restrictive in using the authority to pay up to 80 percent of the operating costs, and it is intended that he will be more liberal in recognizing circumstances of severe need and utilizing the authority to pay all the operating costs in such cases.'

In view of this statement by the conferees we urge the following wording: "in lieu of reimbursement for meals, up to 100 percentum of the cash expenditure for the costs of its food service, provided, however, that "such financial assistance shall not exceed 60 cents for a lunch of supper, 20 cents for a breakfast, and 15 cents for supplemental food.

Section 225.18 (a-1): The State Agency or FNSRO should not be responsible for the meal-time schedules of each site operation.

Our conclusion is that these proposed rules serve little else than the interests of the Office of Management and Budget.

We urge you to revise them to serve the needs of hu gry children in America. Bread and justice,

BARBARA BODE, Vice President.

Mr. VANIK. In short, Mr. Chairman and members of the committee, it is my hope that you can base your judgments on H.K. 13452 upon existing child-feeding programs and the manner in which they have been administered. It is my contention that the administration of presently existing child-feeding programs has been directed toward trying to reduce systematically the number of children to be fed. In addition, this administration has never, in my judgment, sought to make the funds accessible in a timely fashion or with any degree of

ease.

The major question is, will the administration continue to react in this cynical and callous fashion, when the stakes are even greateras is proposed in H. R. 13452 presently before the commitice?

I hope that as you consider II. R. 13452, you will combine it with an effort to improve the existing programs which are so vitally needed. Chairman PERKINS. Let me compliment you again, Congressman Vanik, on your leadership. I regret that we do not have a majority of the committee here this morning to hear this testimony. But you have always been a great crusader in this area. You have been in the past and will be in the future a tremendous help to this committee.

Let me thank you for coming here this morning and giving us the benefits of your views.

Mr. VANIK. Thank you, Mr. Chairman.

Mr. Chairman, I might ask unanimous consent to insert in the record a letter that I received from your State on this issue.

Chairman PERKINS. Without objection, it is so ordered.

Mr. VANIK. I also wanted to submit a letter I had from Minnesota. I thought Mr. Quie might be interested in this.

(The letters referred to follow:)

DEPARTMENT OF EDUCATION,

Frankfort, Ky., January 6, 1972.

Hon. CHARLES A. VANIK,

Congress of the United States,

House of Representatives, Washington, D.C.

DEAR MR. VANIK: As requested in your letter dated December 20, 1971, the following information is presented:

1. Kentucky's Special Food Service Program for Children (Section 13) allocation for Fiscal Year 1972 is $700,278.

2. Estimated dollar value of all Section 13 applications received to date is:

3, 943

14, 865

18, 808

3. Number of children being served under existing programs to date:

(a) Year-round programs..
(b) Summer-only programs.

Total___.

4. Number of additional children who could have been included if all applications received had been approved: 1,700.

It seems at this time that Section 13 funds available to Kentucky for Fiscal 1972 are adequate. Had the participation period been longer in several cases, the financial picture would have been different and no doubt additional funds needed. Your assistance and support with respect to Section 13 as well as all other phases of child nutrition are recognized and greatly appreciated. It is commonly known that most individual states as such do not contribute much financial assistance (cash contribution) toward the support of food service programs; therefore, the efforts of Congress and its grants-in-aid are most significant and vital to the continued success of all food service activity.

Sincerely,

Hon. CHARLES A. VANIK,

Congress of the United States,

House of Representatives, Washington, D.C.

C. E. BEVINS, Director, Division of School Lunch.

DEPARTMENT OF EDUCATION,
St. Paul, Minn., January 7, 1972.

DEAR SIR: The data you requested concerning the allocation of funds to Minnesota for feeding of low-income children in nonschool situations through the Special Food Service Program is attached.

Representing the needy children of Minnesota, we are deeply grateful to you as author of the Section 13 amendment. This program not only gives direct help to hungry children, but provides fringe benefits in the vocational training of adults in the care of children. In Minnesota, we have used several of the day care centers as laboratories for vocational school training.

We appreciate your help in obtaining sufficient funds not only to maintain, but expand this program. From the data given, you can understand that this fine program will be terminated unless funds are given soon.

Thank you for your concern.
Respectfully,

CHARLES L. MATTHEW, Director, School Lunch Section.

Current balance on hand (year around) $125,271.32.

1 The sum of $292,827.00 was requested but only $154,779.00 was allocated to Minnesota by the U.S. Department of Agriculture. As a result, we still owe the City of St. Paul for their Summer Program $26,197.27; at that, we curtailed many applications received after June, 1971.

2 & 3. Estimated Dollar Value and Number of Meals Served:

Note: Total SFSP funding (year round and summer)-$707,915. Estimated expansion of program-20 percent for 1973$849,498. The total amount we anticipate will be needed for the year round programs is $545,991. The present allocation amounts to $343,388 leaving a balance of $202,503 to pay the balance of the claims for the fiscal year 1971-72. Figures unavailable for nonfood assistance.

Chairman PERKINS. Do you want to make a statement at the present time, Miss Martin?'

Miss MARTIN. I would like to make a statement at some appropriate time.

Chairman PERKINS. Why don't you commence now?

STATEMENT OF JOSEPHINE MARTIN, LEGISLATIVE CHAIRMAN, AMERICAN SCHOOL FOOD SERVICE ASSOCIATION

Miss MARTIN. My name is Josephine Martin. I am administrator of the school food service program, Georgia Department of Education. I am chairman of the American School Food Service Association's legislative committee.

It is a pleasure for me to be testifying in support of H.R. 13452, a bill to test the concept of universal school food service and nutrition education.

The pilot programs would provide answers to some of the questions. you are asking today-questions that we do not have answers for. In 1969, the American School Food Service Association adopted a blueprint for action, and that blueprint contained the concepts. embodied in H.R. 5291, a bill to establish universal school food service and nutrition education.

Since the program started in 1946, the Federal Government has been subsidizing all lunches served to rich and poor. The level of subsidy varies with socioeconomic level of parents.

Another question to be demostrated with the pilot program is that food service is basic to the child's well-being. It is not a "frill" or "option." It should not be considered as "athletic," where children. pay for tickets to the ballgame.

In behalf of the 49,000 members of American School Food Service Association, I express appreciation to Congressman Perkins, and the members of this committee for leadership in advancing child nutrition programs through more adequate funding and legislation.

Since the passage of the Elementary and Secondary Education Act which made funds available in several States for school lunches for disadvantaged children, the relationship between hunger in the classroom and the education of the disadvantaged children has been recognized.

Furthermore, studies reveal that malnutrition and undernutrition exist among all socioeconomic groups and that hunger and learning are related irregardless of the cause of hunger.

The ESEA (title I) demonstration, Public Law 91-248 passed in 1970, and Public Law 92-153 passed in 1971, have made possible for schools to increase the number of economically needy children having lunches from 2.9 million in 1968 to 8.1 million in 1971 (November).

Lunches are available to 44.8 million children daily and yet only 25.4 million children have lunches. I have been advised that the number of paying children has declined drastically in the past few years. Fewer paying children are eating now. Increase in sale price means fewer paying children.

The goal of H.R. 5291 is to provide at least one meal each day to all children as an integral part of the educational process; to incorporate nutrition education into the school food service program; to provide funds to local systems to assist with professional staffing. The goal is to provide universal food service by 1975. The statistics cited above reveal in a startling manner the magnitude of the task. The growth of school food service since 1968 has been phenominal, but the growth has basically been along the lines of school food service systems as they have evolved over the past 25 years. If the school food service practitioner and the educator are to be in a position to implement the universal program in 1975 which will not only require expansion in existing schools, but expansion into buildings without facilities, we must begin now to build pilot programs to test procedures and techniques to devise strategies and to build models in all types of schools and districts throughout the United States to serve as guides for the program.

We must find answers to questions being asked by proponents of universal school food service as well as by the opponents. There are plaguing questions related to universal school food service that have not been answered, because they have not been posed.

Many schools in Georgia are serving all children daily, but none are serving all children under the concepts of H.R. 5291-universal school food service and nutrition education. So new questions will be posed in test situations, and answers will be found, questions relating to quality service to pupils, effective nutrition education; administrative procedures, quality control, and cost effectiveness.