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program in some schools, or cut back on already meager educational programs. And so-back we go trying to teach hungry children while trying to tell people we do "care”—and again failing in both.

As your committee deals with the school lunch program I hope one of your guiding principles will be to "promote the general welfare." Sincerely,

JANE A. STARR
Mrs. Clark D. Starr.

PAULDING COUNTY PUBLIC SCHOOLS,

Dalias, Ga., October 5, 1971. Congressman ROMAN PUCINSKI, Chairman, General Subcommittee on Education, House of Representatives, Washington, D.C.

DEAR MR. PUCINSKI: We, in Paulding County, are aware of your untiring work for an adequate lunch at school for the children of the United States. For this we are appreciative and thankful.

With the reduction in personnel at Lockheed of Marietta ; the closing of textile mills and other changes taking place in our section of Georgia, we find the number of requests for free breakfasts and lunches increasing. We find that our breakfast programs are running into great financial trouble. Therefore, there is a need for greater monetary help from Government Funds.

We have increasing need for the replacement of worn out equipment and for the purchase of new equipment if we are to do the best job of preparation and serving food.

These needs cannot be met with the funds we now receive.
Your continued help will be appreciated.
Sincerely,

J. C. SCOGGINS, Jr., Superintendent.

WAHCONAH REGIONAL HIGH SCHOOL,

Dalton, Mass., October 6, 1971. Congressman ROMAN PUCINSKI, Chairman, General Subcommittee of Education, Rayburn Building, Washington, D.C.

DEAR CONGRESSMAN: We would like to persuade you and your sub-committee to act favorably on House Resolution 889 which calls for a reservation of proposed restricted regulation governing the appropriation of the National School Lunch Child Nutrition Program, and which would also provide additional monies for the purchasing of needed equipment for schools not now participating in the program. Sincerely,

JACOB FRANKLIN, Principal.

PRATT-MOTLEY, PTA,

Minneapolis, Minn., October 10, 1971. Mr. ROMAN PUCINSKI, House Office Building, Washington, D.C.

DEAR MR. PUCINSKI: I am writing to you today in your capacity of Chairman, General Subcommittee on Education. I am very concerned about the change in the level of reimbursement for the public schools hot lunch program and the effect the change in USDA guidelines will have in this school district (Minneapolis, Minn.).

First let me say a word about the new guidelines requirement that low-income families apply for free or reduced rate lunch. It has placed our low-income families in an intolerable position. The children are now singled out, an embarrassment which happily was absent under the earlier guidelines.

Any upward change in the income base will adversely effect many children in this school district. Surely this should not be the intent of the legislation.

The change in the amount of reimbursement is a subject of great concern to those of us residing in a school distriet beset by all the usual problems of financing urban education. The school district is under great pressure to reduce its reliance on the local property tax at a time when costs are rapidly rising. In addition we will soon come under a levy limitation to be set by the state legislature. A combination of these factors means that if more local money is needed it is likely the program will be curtailed. The program is, I think, a good use of funds and should be continued and expanded under the former reimbursement level.

Surely there must be some better way to save money at the federal level than to downgrade this worthwhile program. I appreciate your attention to these matters. Very truly yours,

JANET LUND, President.

BOARD OF EDUCATION,

Buffalo, N.Y., October 8, 1971. Congressman Roman PucINSKI, Chairman, General Education Subcommittee, House Office Building, Washington, D.C. Attention : Mr. Jack Jennings.

DEAR MR. JENNINGS: Mr. Sam Husk of the Council of Great Cities asked me to prepare and send you a brief description of the general effects of the proposed United States Department of Agriculture regulations concerning free lunch reimbursement and eligibility standards.

In the interests of time I have been authorized to send the attached as staff information, rather than as official testimony from Buffalo Schools Superintendent Joseph Manch. It is expected that Dr. Manch will file with USDA a formal protest concerning the proposed regulations.

A specific analysis of the effect of the proposals in Buffalo should be ready by Wednesday, October 13. I would be happy to communicate the results by phone if you wish (812–4660 Area 716). Sincerely yours,

EUGENE C. SAMTER, Assistant Superintendent for Administrative Services and Research. It has been announced that the federal administration, through the United States Department of Agriculture, intends to revise school free lunch regulations to raise the rate of reimbursement in all states while at the same time lowering the level of eligibility for such reimbursement in some states. For each free lunch served a needy child a school district will receive 45 instead of 35 cents. But the term needy is to be determined by family income criteria no higher than those established by the federal government. If local districts establish higher criteria, their increased cost must come from nonfederal sources.

It appears that the Department is attempting to be deceptive, giving the impression that it is bowing to the will of Congress, but in reality effecting a saving in appropriations by adding restrictions on reimbursement.

It appears clear that the effect of the announced changes will be a retrenchment and shift in national policy of feeding the needy, as well as a shift in the flow of funds to implement this policy.

What is equally important-indeed, critical in the large cities-is the timing of the action. At this stage, the second month of school, school lunch programs are well underway and children have been receiving free lunches. A change in the eligibility standards at this stage is analogous to changing game rules after the game has started.

To date, USDA regulations state that family income criteria “shall not be less" than those prescribed by the Secretary of Agriculture. The new regulations apparently will set standards which, for all districts in all states, will be those prescribed by the Secretary. In failing to recognize regional variations in cost of living, it discriminates against the poor who live in northern, eastern and western states and in the large cities.

There will be varying effects resulting from higher reimbursement rates coupled with eligibility standards that equal or fall below present criteria. Relatively the most significant increase in federal school lunch revenues will be realized by school districts in those states where eligibility standards have been those prescribed federally. On the other hand, preliminary estimates indicate that in states where family size-income criteria have exceeded federal standards by an average of up to 6 percent to account for higher living costs, losses in federal aid will be incurred that can be avoided under only two alternative conditions.

The first alternative requires the school district to drop from the free lunch lists all those children whose family income exceeds national standards. The second alternative would require that such children be retained in the lunch program, thereby making the district eligible for 5 cents per lunch regular reimbursement and thus defraying the loss in federal aid. In the second case, there would be no loss in total federal aid, but lunch fees would have to be changed and/or additional local funds allocated.

The two conditions mentioned are alternatives, but not realistic options. Resulting as they do from the proposed changes in regulations, they reflect a callous disregard for the needy and for the fiscal plight of school districts, par. ticularly in the large cities of the North, East and West.

Public Law 91-248 makes it clear that national policy is to feed the needy. The proposed revisions in regulations represent the second attempt by a federal agency to abort congressional intent and to twist policy by convoluting procedures.

CENTRAL BERKSHIRE REGIONAL SCHOOL DISTRICT,

Dalton, Mass., October 6, 1971. Congressman ROMAN PUCINSKI, Chairman, General Subcommittee of Education, Rayburn Building, Washington, D.C.

DEAR CONGRESSMAN : We would like to persuade you and your sub-committee to act favorably on House Resolution 889 which calls for a reservation of proposed restricted regulation governing the appropriation of the National School Lunch Child Nutrition Program, and which would also provide additional monies for the purchasing of needed equipment for schools not now participating in the program. Very truly yours,

G. H. FITZPATRICK, Superintendent of Schools.

MINNEAPOLIS PUBLIC SCHOOLS,
SPECIAL SCHOOL DISTRICT No. 1,

Minneapolis, Minn., October 8, 1971.
Hon. ROMAN C. PUCINSKI,
Chairman, General Subcommittee on Education,
Rayburn House Office Building, Washington, D.C.

DEAR MR. PUCINSKI: The confusion surrounding the federal support of school lunch programs is being compounded by the United States Department of Agriculture's (USDA) current threat of an additional change in the guidelines after the school year is almost two months along.

The Minneapolis Public Schools began the 1971-72 school year using the same USDA school lunch program guidelines as last year. These guidelines allowed some schools with a majority of low income children to have free lunches for all children.

Students in all other target areas received lunches at reduced rates, and those who applied anl qualified received free lunches.

New USDA guidelines received in early September forced every family who wanted their children to qualify for free or reduced lunch to complete an application form. This move added a great deal of paperwork to the workload of school teachers, social workers, social work aides, administrators, and parents.

The USDA is now contemplating an additional set of regulations which will force a review of every application, the completion of many new forms, and worst of all, will force many children now receiving free lunches to pay the reduced rate and many paying the reduced rate to pay the total cost.

This proposed change in the eligibility limit on free lunches will make (1) the small wage earner, who is struggling to get along, pay the price of a USDA invoked government saving, and (2) the school enforce these punitive regulations. The family income eligibility limit for free lunch for a family of four will be increased from $3940 to $4200.

A great fear is that the new $4200 income base for a family of four being proposed by the USDA will force many families who receive Aid to Families with Dependent Children (AFDC) off the free and reduced lunch program. The severe income restrictions on AFDC families are such that many AFDC parents will not be able to pay the additional costs, and the poorest of our children will again have to go to school without adequate nutrition.

We currently are serving 26,000 lunches per day. With a population of approximately 15,000 AFDC children, this would mean that approximately 50% of our children would no longer be eligible for the free or reduced price lunch.

Wherever the majority of children are in need of a lunch and for whatever reason are unable to pay for it, that school should be allowed to provide the lunch free or reduced and be adequately reimbursed without the laborious burden of application forms for every child.

While the proposed regulations will succeed in forcing many more children to pay for lunches, the Minneapolis Public Schools will have to make up a deficit of $510,391 based on last year's participation and reimbursement in the school lunch program. Sincerely yours,

DONALD D. BEVIS, Associate Superintendent of Schools for Business Affairs.

ISSAQUAH SCHOOL DISTRICT No. 411,

188aquah, Wash., October 5, 1971. Mr. ROMAN C. PUCINSKI, Rayburn House Office Building, Washington, D.C.

DEAR MR. PUCINSKI: House Joint Resolution number 889 to increase federal reimbursement of all school lunches to 6 cents and 40 cents for free and reduced price lunches, is a vital piece of legislation in my estimation.

In our area, with the high rate of unemployment, we are glad to be able to give free lunches to about 10% of our students, but the cost far exceeds the 30 and 5 cents we are now receiving. Please put all effort possible into passing this Resolution. Yours truly,

KATHLEEN VOORHEES, Food Services Supervisor.

HOUSE OF REPRESENTATIVES,

Washington, D.C., October 8, 1971. Representative ROMAN PUCINSKI, Chairman, General Subcommittee on Education, Rayburn Building, Washington, D.C.

DEAR ROMAN: I am angered and confused by the Agriculture Department's new school lunch regulations.

On October 6, Assistant Secretary Lyng announced a "liberalization" of the previously revised regulations and the allocation of an additional $135 million for school lunches nationwide.

For some, the new regulations may mean extra funds and a "liberalization,” but for my district they mean that half the youngsters who now get free or reduced-price lunches will be cut out of the program!

The problem in Minneapolis, of course, is caused by the new income eligibility standard set at $3940 for a family of four. Our school system estimates that probably half of the 18,000 children now in the program are from families with incomes between $3940 and the current state reduced-price limit of $4800.

In a district that adjoins mine, the St. Paul Board of Education has even more precise statistics. The St. Paul Board has determined that the new income limitation will disqualify 3,767 of the 10,188 children in its program-or 37%.

Luckily, your subcommittee still has an opportunity to help undo the harm that the new regulations will cause in Minnesota and in other high benefit states. I refer to H.J. Res. 889 which comes before the General Education Subcommittee next week.

I want to urge the Subcommittee to amend this resolution to set $3940 as the income eligibility floor rather than the ceiling. At the same time, the Agriculture Department should be required to allow states some leeway in setting ceilings, as

it has done in the past. If the subcommittee determines that some standard must be established, you might want to consider relating the ceiling to a state's public assistance level under the AFDC program where this level exceeds $3940.

Unless the income eligibility issue is dealt with in H.J. Res. 889, I am afraid that passage of this legislation will merely legitimize an effort to hurt some children so that others can be helped. With best wishes. Sincerely,

DONALD M. FRASER.

Ohio DEPARTMENT OF EDUCATION,

Columbus, Ohio, October 5, 1971. Hon. ROMAN PUCINSKI, U.S. House of Representatives, Rayburn Building, Washington, D.C.

DEAR MR. PUCINSKI: Even though I sent you a telegram this morning urgently supporting the passage of HJR 889, which would increase School Lunch reimbursement on Section 4 to $.06 and Section 11 to $.40, I would like to add some additional information to assist you with your efforts.

At the time the Perkins' supplementary appropriation of $30,000,000 was made in late February, 1970, we took rapid action to use our allocation of these funds. Under urging by the USDA, we encouraged schools that were serving fifteen percent or more of their lunches free to needy children to reduce their charge to $.20 for all children. This permitted many who were on the fringe of not being able to buy a lunch to do so at this reduced price. Participation increased significantly. Four hundred and thirteen schools in Ohio took advantage of this assisstance. We utilized a little over $1,000,000 of these funds from March to June of 1970. We increased the rate of reimbursement to cover the cost on paid lunches, which exceeded the charge of $.20, and on those lunches served without charge.

By last October, 1970, we became concerned about these schools being unable to make ends meet financially by charging $.20. We suggested to these 413 schools that they should consider increasing their charge by at least $.05. Very few of them did. They have now been caught in the President's price freeze which prevents increasing the charge for lunches. Under the proposed new regulations issued by the USDA on August 13, 1971, and the unit limitation on reimbursement of $.05 and $.30, these schools are really suffering financial losses. It is hoped that steps will be taken, when the President's 90 day price freeze is removed, so that charges for lunches will be removed from any future price control.

For several years our State Department of Welfare along with local departments of welfare granted some assistance on needy lunches in our larger cities. This assistance was completely withdrawn the first of September by the State Department of Welfare.

For the last two years we had a block grant of Section 32 funds to divide among Special Assistance, Breakfast Program and Equipment Assistance. This block grant was removed the USDA this fall in order affect the unit control funding of $.05 and $.30 per lunch. This knocked out our ability to further assist those 413 schools that had reduced prices a year and a half ago.

I am enclosing a financial statement comparing our total funds received last year with our initial allotment this year. I believe you will note a significant difference. We have been advised by the USDA to hold our breakfast expenditures at the annualized basis of last April. We have not been able to add any new breakfast programs this year, even though cities such as Cincinnati and Youngstown were ready to initiate a breakfast program. The Model Cities people were going to supplement our food reimbursement with funds to cover the cost of labor.

We have had requests from 76 districts for equipment assistance. Based upon the reduction in the available funds we will only be able to assist about twelve districts including several of our larger cities that have schools without any food service facilities. Respectfully yours,

WADE D. Bash, Chief, School Food Service Program.

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