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Chairman PERKINS. I want to say that Congressman Ford is here and he will preside over these hearings a little later. He has always worked very hard on the impact legislation.

Mr. Goodling is here, of course, representing the minority. He is a great friend of education. He served on the board of education a long, long time in Pennsylvania.

Go ahead.

STATEMENT OF DR. H. DAVID FISH, SPECIAL PROJECTS

DIRECTOR, SAN DIEGO CITY SCHOOLS

Dr. FISH. Thank you, Mr. Chairman. I am glad to see a former member of the school board. We work with school board members all the time, of course.

I am David Fish. I am director of special projects for the San Diego city schools and president-elect of the Impact Aid Organization. I have prepared written testimony and would like to request permission to enter it for the record.

Chairman PERKINS. Without objection your prepared statement will be inserted in the record.

Dr. FISH. And also in response to a rather strong plea from the Douglas School District No. 3 at Ellsworth Air Force Base in South Dakota, they have prepared a statement. I would like to requestChairman PERKINS. Without objection that statement will be inserted in the record.

Dr. FISH. Thank you, sir.

[Statement referred to follows:]

DOUGLAS SCHOOL DISTRICT No. 3, ELLSWORTH AIR FORCE BASE, S. DAK.

FOREWORD

This material is presented to the House of Representatives, Education and Labor Committee, to apprise them of the potentially dangerous situation that exists for the Douglas School District #3, Ellsworth Air Force Base, South Dakota, under the provisions of Title III, FEDERAL IMPACT AID PROGRAMS, PUBLIC LAW 93-380.

The Douglas Board of Education has the responsibility of providing a viable educational program for the students of this district. Consequently, there is an urgent need to resolve the financial uncertainties associated with the provisions. of P.L. 93-380 which threaten the continued existence of that educational program and the District.

The Douglas School District is a heavy impact district with more than 80% of the student population composed of dependents of military personnel assigned to Ellsworth Air Force Base. The following table provides a summary of students by category for the past three years.

TABLE 1.-ENROLLMENTS, DOUGLAS SCHOOL DISTRICT NO. 3 BY AVERAGE DAILY ATTENDANCE

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With this degree of impaction the Douglas School System relies heavily on P.L. 81-874 for its educational revenue.

The figures on the following page given a breakdown of this support and a comparison of Douglas and State per pupil average daily attendance expenditures. Since local and state support is already at the maximum limit established by law, it is apparent that Federal revenue in the form of P.L. 81-874 is vital to the operation of this district. Provisions of the old law were designed to provide a level of support comparable to the average per pupil cost in the State. As revealed in Figure I this has not been accomplished. A restricted educational program for all students of the district has resulted from the diminishing level of federal funding.

Public Law 93-380 with proposed tier funding now brings a new threat into focus.

Full funding of Tier I and II is obviously needed by this district if it is to operate at all. Douglas School would lose 40% of its total revenue without Tier II funding. But, even if these were funded, there remains another serious problem involving funding of Section 2, section 2(c) (4) and 3(e). Funding under these

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sections of the old law provided this district with a significant portion of the total operating revenue. This is shown in the following table and figure.

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It is evident that approximately 25% of the total federal receipts came from those sections, and without that support, the district would have ceased to exist. Now, we understand that under the proposed tier funding Section 2 is to be funded at less than 100%, and there is apparently no reference made in P.L. 93– 380 to sections 3 (c) (4) and 3 (e).

SUMMARIZATION

The Douglas School District must have the assurance of full-funding under Section 2, Section 3 (c) (4) and 3(e). We respectfully and urgently request that this Committee include, within the language of its appropriations recommendation, provision for funding of these sections. Moreover, we support the proposed legislation submitted by the Honorable Carl Perkins to delay implementation of P.L. 93-380 until accurate statistical data is made available. The delay will provide this and other Districts the opportunity to present the financial implications of the amendments to P.L. 81-874 and allow time for legislative revisions providing these essential federal funds.

Dr. FISH. I would like to restrict my comments to a few points. Traditionally the impact aid groups have been very proud of their ability to produce facts and figures, statistics, information.

We have a great deal of confidence in our data. We think that over the years impact aid has been notable for the small degree of error both in the information we present and the effects of various Federal bills and regulations.

It has been a simple program and it has been, we believe, effective because of that reason.

Today, unlike many witnesses, I must say that I am in a point of confusion and must say I do not know many facts which I believe are necessary for the successful operation of this program in the next year.

As the chairman stated, we have not seen the guidelines yet at the local level for any of the areas of the program. We have participated in a very few limited discussions. There were some regional meetings of the Office of Education.

But we still do not know and do not have confidence in what the impact aid program would look like under 93–380 next year.

We do not know the numbers. We do not know the conditions of the program. We have various concerns about the locations. And at this time we are not even confident of the number of school districts affected. We are very aware of the basic changes in the law and the inclusion of the low-rent housing students. We support that inclusion.

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The addition of the low-rent housing students is consistent with the basic philosophy of the law where the action of the Federal Government has impacted upon a local community.

We also support the inclusion of provisions for the handicapped children of military dependents. This is clearly a service provided to youngsters that is urgently needed and by having the students participating in programs we think that this does the children well and this is our basic responsibility.

We are also concerned about the area of the minor sections of the law, section 2, section 4 and the other sections. Again we are laboring under some confusion as to final guidelines. Final directions have not

come out.

Douglas School District is a very good example. I think in their testimony they have 80-percent impact and already the basic premise

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