Chapter 537, Statutes of 1983 was signed by the Governor on July 28, 1983. That statute contained an urgency clause and was intended to implement JTPA. Section 15045 was added to the Unemployment Insurance Code to require a public hearing by the PIC on the proposed Plan with at least 30 days advance notice and a 30-day comment period prior to final adoption of the Plan. JTPA required that interm plans be submitted by August 31, 1983. The Plan for the Los Angeles County SDA was submitted timely. Therefore, it is concluded that the Plan was developed, submitted and approved in accordance with JTPA. Strict compliance with section 15045 of the UI Code was not possible due to the time limitations required by JTPA.

PLAN TARGET GROUP

The program narrative for the Los Angeles County SDA Plan provides, at page 1, as follows:

"Potentially Eligible Population

"Los Angeles County plans to serve targeted
welfare recipients, specifically General
Relief (GR), Aid to Families With Dependent
Children-Unemployed (AFDC-U), Aid to
Families With Dependent Children-Family
Group (AFDC-FG), youth (ages 16-21), and
other JTPA eligible individuals during this
nine-month interim program. The targeted
welfare client population, all of whom
are unemployed, will make up a large portion
of the client population to be served."

Section 141 of JTPA (29 USC 1551) provides, in part, as follows:

"Except as otherwise provided, the following
conditions are applicable to all programs
under this Act: (a) Each job training plan
shall provide employment and training
opportunities to those who can benefit from,
and who are most in need of, such opportuni-
ties and shall make efforts to provide
equitable services among substantial segments
of the eligible population."

Neither JTPA nor FESA prohibit an SDA Plan from targeting its employment and training opportunities for an identified segment of the eligible population, so long as youth, recipients of Aid to Families With Dependent Children and school drop-outs are properly served.

It is concluded that this Plan contains provisions to satisfy the employment and training services to the groups identified in JTPA. Dated:

November 29, 1983

CC:

State Job Training
Coordinating Council
T. Bruinsma, Chairman

Western Center on Law
and Poverty, Inc.

K. R. KIDDOO
Director

Employment Development Department

At the Council meeting of October 13, 1983, concern was expressed that
Job Training Partnership Office (JTPO) staff had inadvertently approved
the Los Angeles County Job Training plan without ensuring that the
conditions imposed by the Council Subcommittee had been met. The attached
report summarizes the steps in the process by which the Los Angeles County
plan was reviewed and approved.

Briefly, the Subcommittee recommended approval of the plan on condition
that four defects would be cured. The areas requiring modification were:
• The SDA would rewrite the plan narrative to eliminate statement
that only General Relief recipients would be served

The SDA would submit a PIC/CEO Agreement

• The SDA would revise Table CIII Performance Objectives

• The SDA would detail the process for selection of service providers.
Prior to providing administrative approval of the plan, staff was
responsible for ensuring that the plan was modified to meet each one of
these conditions. Subsequent to the Council Subcommittee meeting the
SDA developed the required plan and on September 22, 1983 revised
documents were transmitted to the Job Training Partnership Office. The
defects having been corrected, the plan was processed, signed and approved.
As a result of concern that has been expressed by the Western Center on
Law and Poverty and others regarding Los Angeles County's intended use of Job
Training Partnership Act funds to reduce General Assistance welfare caseloads,
it came to our attention and to the attention of the SDA staff that Table
CIII and Exhibit D contained numerical inaccuracies which incorrectly

indicated that AFDC recipients, Hispanics, older workers and females would be under served.

In discussions County staff indicated an intent to submit corrected copies of Table CIII and Exhibit D so that the service levels shown for these groups will reflect the actual intended service levels.

It should be noted that many of the concerns expressed by local service providers and other interested parties will not be satisfied by these changes, since those concerns relate more to the way in which the SDA is exercising the discretion provided to it under the Act and under state statutes. It is our intent to closely monitor the performance of the County to ensure that its operation of the program is in conformance to Federal and State laws and the policies of the Council.

In addition, the Legal Office of the Employment Development Department is conducting a formal investigation of the Los Angeles County Plan in response to the complaint submitted to the Director of EDD by the Western Center on Law and Poverty.

The results of that investigation will be reported to the Council by the Director.

Sincerely,

KARL W. GROSSENBACHER, Chief
Job Training Partnership Office

Attachment

CC: L.A. Subcommittee Members
Michael O'Reilly

Dave Paulsen

REVIEW AND APPROVAL OF THE LOS ANGELES COUNTY JOB TRAINING PLAN

August 29, 1983

August 30, 1983

September 6, 7, 8

September 14, 1983

September 16-26, 1983

September 27, 1983

September 29, 1983

Interdisciplinary Review Teams reviewed the plans. Also JTPO staff began to perform their summary review to prepare their comments and make staff reports to the SJTCC subcommittee members.

Subcommittee conditionally approved the plan with the following conditions:

• SDA will rewrite narrative to exclude references that the SDA will serve only GR participants.

• SDA will submit PIC/CEO Agreement.

• SDA will revise CIII - Performance Objectives. SDA will detail the process for selection of service providers.

SDA, with some technical assistance from the SDA Liaison, responded to the subcommittee's conditions on 9/22/83.

• Rewrote and submitted a narrative that more accurately reflects who the program will serve • Submitted the

PIC/CEO Agreement, and

A narrative describing the Service Provider
selection process.

Revised Chart III, Revised Planned Enrollment
levels changes performance objectives.

JTPO staff routed the plan to the EDD Contract
Coordinating Group

Plan signed by Chief of JTPO

Service Delivery Area Liaison routed plan to EDD
Contract Coordinating Group for final processing.
Contract Coordinating Group returned plan to liaison
staff to maintain in file and to send to SDA.