this responsibility to licensed superintendents and principals. Credit toward graduation cannot, then, be assumed to be a citizen prerogative, but rather is a state function. Beyond this fact of certification, it is wrong for students to become involved in work programs without the opportunity to earn credit toward a diploma. The central purpose, in fact, of the youth jobs initiative should be to provide students with job skills, job experience, and a diploma. Implementation: Nonsense and Common Sense Unfortunately, The "Technical Specifications" contain a lot of nonsense. the school principal cannot ignore the ivory tower prescriptions of bureau chiefs once these prescriptions become administrative regulations. We urge the Subcommittee to preclude some of the more mindless specifications. For example, consider this requirement outlined on page 21 of the proposed regulations: In addition, the school plan and program must address The physics or music or French teacher must be involved? The advanced writing or chemistry or painting curriculum must be affected? This requirement is not only absurd, it suggests a fatal myopia. Yes, there does exist a real world of "average" and college preparatory students out there in the schools. These students and teachers have their own legitimate interests to pursue. Furthermore, if these interests cannot be pursued in public schools, they will be pursued in private schools, as we already can observe occurring. This one proposed regulation, incidentally, illustrates clearly a major problem with current federal policy. Programs originally intended as supplements to the total secondary school program very rapidly come to dominate the educational environment by an unrecognized alchemy of monies, regulations, and federal prestige and press releases. The unintended consequences of current federal categorical funding has been to ignore quality education for all students, especially the college bound student. The entire thrust of the technical specifications needs to be reworked. They are too obstructive, too petty, and too detailed. They reflect someone's concept of how they think schools operate, not the way schools actually do operate. The NASSP would be pleased to volunteer four or five secondary school administrators strong in curriculum to write operative specifications that are sensible, workable, and efficient if the Education Department will assume their travel costs. We would like to suggest, however, a more basic reform. This whole grand scheme proposed in the specifications for planning grants and competitions and extensive in-service activities, arises from some false assumptions and obsolete management strategies. The entire approach is wrong. Qualification for federal program monies should not be reduced to the level of a contest for designing the best billboard. This is time consuming and wasteful of professional time and talent. It may be fun for the judges, but it makes cynics of the players. The Education Department should get out of the program administration business. Long-armed administration just doesn't work effectively. Centralized planning and these specifications are expressions of centralized planning does not work as well as decentralized planning. Modern management assumes a quite different posture. Rather than relying upon detailed specifications and close oversight, it relies upon something much more effective -- the talent and expertise of the local site manager. This approach allows great flexibility and initiative by local units, so that overall goals are achieved with a minimum of regulatory control. We urgently request that these technical specifications be recast to provide (1) a clear outline of the objectives of the legislation, (2) a clear description of the criteria to be applied for program participation and to program outcomes, and (3) a reporting date and forms for documenting these outcomes. Then we urge that the monies be distributed without the superficial pre-program requirements, and with a strong statement of accountability requirements. Then let the school districts qualifying for the youth programs go ahead and utilize their monies according to their own best professional judgment. They will respond with initiative and responsibility. use monies for in-service, but others will use monies to stimulate employment activities. Some will Each will use it to the best advantage of their students if they are held accountable for outcomes. The Education Department would then monitor every three or four programs to verify the reported data. It may seem a simple approach, but it works for the big corporations and it will work for big government. More importantly, it will allow principals once again to be educational leaders. Thank you for this opportunity to testify. Chairman PERKINS. Thank you very much. Mr. Torres, please identify yourself for the record and proceed. STATEMENT OF ARNOLDO S. TORRES, CONGRESSIONAL LIAISON, LEAGUE OF UNITED LATIN AMERICAN CITIZENS Mr. TORRES. My name is Arnoldo Torres. I represent the League of United Latin American Citizens. It is this country's largest and oldest Hispanic civil rights organization founded in 1929 and incorporated in 1930 with 385 chapters in the country and in 38 States. Unfortunately we do not have any in Kentucky yet. I am going to summarize briefly the testimony which I present. It is unfortunate more members of the subcommittee are not here. It would have perhaps provided a good opportunity to get into a dialog on the subject since it appears our perspective is somewhat different from the one that has been given consistently during your 3 or 4 days of hearings on this subject. The testimony that I present gives a brief overview of the educational situation which confronts Hispanics at the present time. On page 3 of my testimony we indicate the fact that in 1976, 64 percent of persons between the ages of 20 and 24 who were Mexican Americans had completed high school. For Puerto Ricans we find that it is 68 percent and for whites we find there were 87 percent. Information is provided to us by the Civil Rights Commission. The reason why we provide you with some type of profile on the condition of Hispanics in education is to try to highlight the fact that what has taken place in many of the educational institutions or the systems in this country has been somewhat less than what we would have expected realizing that we cannot solely blame the educational institutions for the misfortune of our youth. We nevertheless are concerned that perhaps the commitment and the resources have not been given to the institutions in order for them to do a more adequate job. The second point we tried to highlight is the lack of data which is provided on Hispanics regarding their labor situation. On February 29, which was last Thursday or Friday, the New York Times reported a study which was done by Ohio State University which indicated the figures provided by BLS were somewhat below the actual figure of unemployment of minority youth. Unfortunately and to our frustration but it appears to be fairly consistent with what the situation is, we find that there is very little information on the actual situation of unemployment confronting Hispanic youth. As I indicate the continued lack of information has dulled many attempts aimed at dealing with our communities' youth unemployment problems. We have recently heard that the Department of Labor intends to publish data which would give us a more accurate picture of the actual unemployment of Hispanic youth. In view of the facts that the administration has decided by the introduction of the legislation, they obviously feel that a brand new youth employment program is merited under the circumstances. The proposal is obviously an effort to improve the future employability of disadvantaged youth through in-school remediation and job training efforts. The educational component of the bill reads more like title I of the Elementary and Secondary Act of 1965. It reads more like title I than a new initiative aimed at resolving the youth unemployment problems of disadvantaged youth. The difficulties makes us wonder how effective title I programs have been in dealing with the educational needs of children of lowincome families. We would assume the intended recipients of this new proposed program by the administration would also be that same youth that should have or has received services under title I. We are concerned that if title I has indeed been ineffective in resolving the educational needs of children of low-income families, how will this new initiative so similar to title I be effective in addressing these problems? Perhaps it would be best that Congress and the administration better assess the workings of title I and make necessary changes in its design and purpose. Perhaps this action would demonstrate a more prudent and effective approach of dealing with youth unemployment. We recognize the attempt of the administration to somewhat deviate from the traditional approaches to employment and training programs by introducing this piece of legislation. We are concerned there are not the types of provisions which mandate cooperation at the local level. My background before I came into this position was as a budget analyst for the State of California. I was specifically in charge for analyzing on the part of the legislation all of the employment programs in the State. I have found from that experience which was just last year that there is very little cooperation and a very little sharing of information between the two entities, the prime sponsors and the local educational agencies. There may be people in this room that would like to contest that but I think the studies I have done under the direction of the legislature would indicate otherwise. In addition the major role is provided for vocational education. There are no provisions mandating a comprehensive outreach service aimed at attracting dropouts back to school. This subcommittee has received a great deal of testimony from educational representatives indicating their support for the initiatives. The gentleman who I have just followed indicated his support for the local school site advisory councils as long as it was advisory. There have been people who have indicated their dissatisfaction with this approach. It is unfortunate that perhaps they have had a negative experience with advisory councils but we feel there is a necessity for it. The individual before me has also indicated a concern with the monumental reporting system that would be undertaken by this new legislation. There is no doubt there is a need to be concerned with that. There is a concern that too much money will be spent on this type of endeavor or this aspect of the program. We feel up to now there has not been enough monitoring in an effective manner of many of the Federal programs, primarily your job programs. We realize the complexities of developing a comprehensive and effective youth employment program. We seriously question wheth |