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PENNSYLVANIA

Mr. HERBERT D. ROREX,

THE BOARD OF PUBLIC EDUCATION,
Pittsburgh, Pa., August 20, 1971.

Director, Child Nutrition Division, Food and Nutrition Service, U.S. Department of Agriculture, Washington, D.C.

DEAR MR. ROREX: The Pittsburgh Board of Public Education is registering comments on the above noted regulations governing the National School Lunch Program.

The proposed regulations seem to be in conflict with the intent of the Congress under P.L. 91-248. In this Bill they provide for:

1. Up to 12 cents for all "Type A" lunches

2. Full funding of free and reduced price lunches up to 60 cents

3. Year in advance funding

4. No overt identification of needy children

5. The option of identifying needy children by category

6. Formation of a Council on Nutrition

None of these are fully implemented, even though they are in the former guidelines. The new guidelines appear to increase the burden to school districts rather than help them expand old programs or start new ones.

The limits described in 210.4(f) are not in the best interest of feeding needy children. The limit of 35 cents for each free or reduced priced "Type A" lunch to children does not cover the cost of such a lunch.

Pittsburgh has been extremely careful to hold the cost of each lunch to 60 cents. This is for a cold "Type A" lunch served in most elementary schools and also for the hot "Type A" lunch served in our secondary schools. The elementary students pay 10 cents, while the secondary schools pay 20 cents for a reduced priced lunch.

Therefore, our maximum income from elementary lunches sold at a reduced price is 45 cents (.05+.30+.10), or 15 cents below cost. At least 80% of all elementary students in Pittsburgh now being served are eligible for free or reduced priced lunches. We are now projecting an annual need of $393,000+ to keep our present elementary program. This does not allow for any expansion of lunches to more needy students.

Also, in the secondary schools at least 66% of all students are eligible for free or reduced priced lunches. Using the same projections, at least $282,888 will be needed for secondary schools in the 1972 fiscal year.

Even on the full priced lunches of 45 cents, previously established and now frozen, the deficit of 5 cents per meal is incurred. This could result in an annual loss of $72,315.

If it is the intent of Congress to financially aid school lunch programs. FULL FUNDING must be forthcoming. The Pittsburgh Board of Public Education needs a reimbursement of at least 50 cents for each free and reduced priced meal as well as 10 cents for every "Type A" lunch served.

Items 4 and 5 are now over-regulated to the point where every needy child must carry an application home and back to school which, in effect, advertises "I am a needy child". To us, this identifies him to his fellow students, and is discriminatory and not necessary.

As before, school is about to open and new regulations are being imposed which will add to the administrative burdens of the school district, and the amount of reimbursement available is being announced at a time which allows for no advanced planning.

Where is the legislated "National Advisory Council"?

None of the provisions of Section 14 of the National School Lunch Act, as amended, are being implemented, especially part (f) where up-to-date data accounting be assembled "for administrative and legislative changes. .

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The results of these presently proposed regulations will reduce participation in the total program, which does not appear to be the wish of the Congress. They restrict the program and do not cover the full implementation of P.L. 91-248.

We would like to recommend:

1. Continue all present programs at June 1971 levels

2. Submit all proposed guidelines to the National Advisory Council

3. Require their action before May 1972

4. Publish all proposals by June 1, 1972

5. Publish all permanent changes by July 1, 1972

6. New Regulations effective for the new fiscal year

7. All future changes made on this timetable so there is advanced knowledge with enough time to implement.

Very truly yours,

Approved:

Senator GEORGE MCGOVERN,

D. G. BUSSLER, Director of Food Service.

F. L. KELLAMS, Director of General Services.

SCHOOL DISTRICT OF CHELTENHAM,
Philadelphia, Pa., August 25, 1971.

U.S. Senate Office Building, Washington, D.C.

DEAR SENATOR MCGOVERN As a food service director for the School District of Cheltenham Township, Elkins Park, Penna., I am most anxious to enlist your aid in having the United States Department of Agriculture rates for the School Lunch Program increased to provide an average of 6¢ from Section 4 Funds (Cash for Food Assistance) for each Type A lunch served. Also funds for free and reduced price lunches from Sections 11 and 32 should be increased to provide an average of 45¢.

Thank you for any help you can give.
Sincerely,

Hon. GEORGE S. MCGOVERN,

Senate Office Building, Washington, D.C.

(Mrs.) PHYLLIS E. FILEMYR, Director of Food Services.

THE BOARD OF PUBLIC EDUCATION,
Pittsburgh, Pa., August 26, 1971.

DEAR SIR: The attached is a copy of a letter sent to Mr. Herbert Rorex, U.S.D.A., protesting the new guidelines governing the operations of the National School Lunch Act as amended.

The regulations are scheduled to be read into the Federal Register in early September.

I feel these guidelines, regulations, and U.S.D.A. interpretations will strangle our program here in Pittsburgh and are in conflict with the wishes of Congress to feed hungry children.

Please read the attached letter and do what you can by advising the U.S.D.A. as to full implementation of the wishes of Congress as to feeding hungry children in school. The recent guidelines and the timing of their release and effective date will cause a real hardship to Pittsburgh, Pennsylvania, and the rest of the nation.

Implementing changes so close to the opening of school will cost Pittsburgh a loss of reimbursement in September and could well sink the entire program. This same approach of releasing changes was used and protested against last year. Now, this year the U.S.D.A. again releases changes to be read into the Federal Register AFTER school has started. This must be strongly protested. Congress provided a law suitable for planning ahead in P.L. 91-248. In actuality, the hungry school children are not receiving the full benefits of this law because the U.S.D.A. is restricting benefits through ill advised use of regulations, guidelines, and interpretation of a good congressional law.

Very truly yours,

D. G. BUSSLER, Director, Food Service Division.

WILKES-BARRE AREA SCHOOL DISTRICT,
Wilkes-Barre, Pa., August 26, 1971.

Senator GEORGE MCGOVERN,

Senate Office Building, Washington, D.C.

DEAR SENATOR MCGOVERN: The new guidelines issued recently by the Department of Agriculture for child nutrition programs disturb me greatly. If I understand the situation correctly, the amendment to 91-248 stating that a school district must serve 90% of its daily participation free to qualify for full federal funding would wreck our district's successful federal school lunch program.

I am strongly recommending that the amendment to 91-248 be changed to include a seven cent ($.07) reimbursement for Section 4 funding on all Type A lunches served. I am also recommending that a minimum of forty-five cents ($.45) be paid on all "free and reduced price" lunches.

The future of the federal school lunch program depends on your immediate review and action on this critical situation.

Sincerely,

WALTER C. WOOD, Superintendent.

[Telegram]

Senator GEORGE MCGOVERN,

Senate Office Building, Washington, D.C.

The guidelines issued recently by U.S.D.A. for child nutrition areas are unrealistic. Availability of program funds is meaningless when the use and distribution of such funds is rigidly controlled and restricted by U.S.D.A. The amendment to 91-248 that states a district must serve 90 percent of its daily participation free to qualify for full funding, must be changed to read as 90 percent free and reduced price. In fact, the guideline should provide for variables in participation percentages and the amounts reimbursable for certain categories, especially when the larger part served is free.

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May 1971 figures in our school district submitted to the State office show that 75 percent of the lunches served were either free or reduced price.

We are to receive a total of 35 cents per plate (30 cents plus 5 cents), we will have to close the program as we are anticipating close to 800 free meals daily. This would mean a loss of 25 cents per plate for free, 5 cents per plate for reduced price, and due to the freeze 10 cents per plate on full price meals. No district in the country can survive under these conditions. We have reached the needy in our district. We have complied with all regulations pertaining to 91-248. We do have approved applications on file for all free and reduced price lunches served.

Local tax dollars to support a deficit program are not available now, nor in the future.

If a large number of school feeding programs close throughout the Nation, it will have a pronounced effect on our economy. 1-Unemployment for food service personnel. 2-Food processing and packaging industries would be hid by law of supply and demand. 3-Major large and small equipment and supply firms would also suffer. 4-The percentage of dropouts would increase and 5-Hungry students are more susceptable to inciting disturbances.

Where has the Congress placed child nutrition on the priority list? Why must we wait each year until the middle of August to be informed of the department guidelines? Why do we reimburse 4 cents for a half pint of milk under the special milk program and only 5 cents for a complete lunch, including foods, labor and miscellaneous supplies? It doesn't make sense. Why was the 12 cents rule deleted? Congress passes the law and appropriates the money, but restrictions prohibit the maximum use of funds on the State level to benefit all programs. We strongly urge and request reconsideration of the guidelines and

whatever support you can give to help us keep the child nutrition program operable will be greatly appreciated.

Respectfully yours,

Mrs. ALICE E. REED,

President, Pennsylvania School Food Service Association, Director of School Food Services, East Allegheny School District, North Versailles, Pa.

[Telegram]

LIGONIER, PA.

Senator GEORGE MCGOVERN,
Washington D.C.

DEAR SENATOR MCGOVERN: The Ligonier Valley School District, Ligonier, Pennsylvania, is appealing the USDA guidelines for the 1971-72 school term. We solicit your cooperation in having the monies appropriated by Congress for Student Lunch programs utilized on a more equitable basis. Our school district is not in a financial position to carry the cost of a free or reduced price lunch program. MILROY CARNAHAN, Superintendent.

Hon. GEORGE MCGOVERN,

U.S. Senate, Washington, D.C.

SCHOOL DISTRICT OF THE CITY OF ALLENTOWN,
Allentown, Pa., August 27, 1971.

DEAR SIR: Enclosed herewith is a copy of letter forwarded to Mr. Herbert Rorex concerning the announced changes in the School Lunch Program regulations.

It is our understanding that the final regulations will be announced on September 1, 1971, and we would appreciate any help you can give toward a subsidy increase.

Very truly yours,

Enclosure.

Mr. HERBERT ROREX,

WILLIAM J. SANDBROOK, Jr.,
Secretary-Business Manager.

SCHOOL DISTRICT OF THE CITY OF ALLENTOWN,
Allentown, Pa., August 27, 1971.

Child Nutrition Division, Food and Nutrition Services,
USDA, Washington, D.C.

DEAR MR. ROREX: Please be advised that the Board of Directors of the School District of the City of Allentown, Pennsylvania, at a regular meeting held on Thursday, August 26, 1971, directed me to write you regarding their concern over the published changes in regulations for funding the National School Lunch Program.

It is important to remember that the Allentown School District, and many other school districts, have developed plans for expansion of school lunch programs consistent with the need as evidenced by congressional concern and action the last two years.

As we understand the effect of the changes outlined in Article 210.4, paragraph (f), it seems that the average subsidy for a lunch should read "6 cents" as opposed to "5 cents", and the average subsidy for free and/or reduced lunches under special assistance should read "45 cents" as opposed to "30 cents".

You will want to remember that Pennsylvania was not able to reimburse all free lunches last fiscal year at the 30 cent subsidy because of limited funds, and it seems impractical for the department to further restrict payments to states.

The Allentown School District has historically supported the National School Lunch Program with local tax dollars, and considers it imperative that further consideration be given this matter.

Very truly yours,

WILLIAM J. SANDBROOK, Jr.,

Secretary-Business Manager.

[Telegram]

MURRYSVILLE, PA.

Senator GEORGE MCGOVERN,
Senate Office Building,
Washington, D.C.

DEAR SENATOR MCGOVERN: The Franklin Regional School District urges more realistic guidelines for school lunch reimbursement. With increased wages and food costs every national school lunch program has found it more and more difficult to operate without a deficit. If schools are driven off the program, it will be the children who suffer. School districts have been required to feed their needy children which is a good thing, but local budgets cannot assume the cost of this increased load. Please give your support to the reconsideration of these guidelines so our country can move forward in the area of child nutrition. Sincerely,

Hon. GEORGE MCGOVERN,

U.S. Senate, Washington, D.C.

GWEN G. CHEGWIDDEN, Director of School Food Service. Dr. JOHN HOLIDAY, Superintendent of Schools. Dr. JOHN DONALDSON,

President Franklin Regional School Board.

PHILADELPHIA, PA., August 27, 1971.

The Philadelphia School Food Service Division strongly protects the intent of the USDA to bring about changes in the child nutrition programs for the school year 1971-1972.

The reasons being:

1. Most school districts confirm their programs during the summer months. 2. Our budget should be confirmed prior to schools opening.

3. Parents and children look forward to schools opening with at least the same advantages that existed when they left schools at closing.

We offer these suggestions:

1. Any changes in program operations or funding should not be proposed for the current school year.

2. Any changes should be directed toward putting and end to hunger among America's school children.

3. The proposed plan is carried out would curtail our present operations and preclude the expansion required to reach the additional millions of hungry children in America.

Mr. HERBERT ROREX,

JOHN J. FITZSIMMONS, Director, Food Service Division.

PENN HILLS SCHOOL DISTRICT,

ADMINISTRATIVE OFFICES, Pittsburgh, Pa., August 31, 1971.

Director, Child Nutrition Division, Food and Nutrition Services, U.S. Department of Agriculture, Washington, D.C.

DEAR MR. ROREX: As Director of Food Services for the Penn Hills School District, I feel it my duty to inform you of a particular situation which is vital to our school lunch program.

The school districts of Pennsylvania have been compelled into creating and increasing a free or reduced price lunch program designed to reach as many underprivileged and deprived children as possible. My colleagues and I in the school lunch program have worked diligently to increase the program as much as possible. We are now faced with the sad situation of not having enough money to properly fund this program. In the school year 1970-71, we received 34¢ for a free lunch and 4¢ for a regular Type A lunch. It is very clear that these insufficient funds cannot support a successful food services program.

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