Wagner-Peyser Act

The State’s Unified Plan, which includes the Agricultural Outreach Plan, is posted to the Department of Labor and Economic Opportunity website to solicit comments from interested agencies, partners, and other groups who serve migrant and seasonal farm workers. 

The following is a list of entities that were afforded the opportunity to review and provide comment on the Plan. 

• The Interagency Migrant Services Committee, which includes the following:
   
  • Telamon Corporation (167 NFJP grantee),
  • Michigan Department of Health and Human Services, 
  • Michigan Department of Agriculture and Rural Development, 
  • Michigan Migrant Head Start/Telamon Corporation, 
  • Michigan Primary Care Association,
  • Michigan Farm Bureau, 
  • Migrant Health Promotion, 
  • Michigan Primary Care Association, 
  • Michigan Department of Civil Rights,
  • Michigan Department of Community Health, 
  • Michigan Department of Education - Migrant Education, 
  • Michigan Occupational Safety and Health Administration, 
  • Michigan Department of Licensing and Regulatory Affairs, 
  • Hispanic Center of Western Michigan, 
  • United States Department of Homeland Security,
  • Michigan Migrant Legal Assistance Project, 
  • Farm Worker Legal Services, 
  • Michigan State University College Assistance Migrant Program and High School Equivalency Programs, 
  • Julian Samora Research Institute, 
  • Hispanic Latino Commission of Michigan, 
  • United States Department of Agriculture - Rural Development, 
  • United States Department of Labor – Wage and Hour Division, and
  • Social Security Administration.
     
    All comments will be incorporated into the Unified State Plan.  All commenting parties will be informed whether their comments were incorporated, and if not, the reason(s) therefore.

Appendix V:  Public Comments and Responses: 

Comment: 

Overall, the Interagency Migrant Services Committee (IMSC) members stated concerns with the use of data and conclusory statements throughout the Agricultural Outreach Plan (AOP) without reference to sources/citations. For example, the Tables included in the AOP fail to cite the source(s) of the data used. The IMSC’s Policy, Advocacy, and Civil Rights Subcommittee (PACR) Subcommittee recommends that each Table have a citation to the source(s) from which the data was taken and recommends Figure 1 of the WIOA Unified State Plan as an example.

 Response: 

Overall, the Tables throughout the Agricultural Outreach Plan are preceded by a brief description explaining the contents of the table and provide reference to where the data was obtained. However, we have added brief citations for several tables as suggested.

 Comment:

The second paragraph following the Governor’s proclamation states that housing for migrant farmworkers with families is “becoming scarcer.” Table 1 on the same page shows that the number of camps, units, and capacity have been increasing every year from 2014 to 2018. The discrepancy between these items needs to be reconciled. PACR Subcommittee members acknowledge the increased use of the H-2A Visa program and are suggesting that this reflects a reduction in the number of units that employers are making available to migrant farmworkers with families.

 Response:

The paragraph was modified to reconcile the discrepancy noted. The last sentence was revised to “therefore more grower owned housing is being converted to worker-only housing which is reflected by the increase in the number of camps, units, and capacity shown in Table 1 below.” In addition, the paragraph that precedes Table 1 was also revised to “The number of licenses for migrant housing remained virtually the same over the last four years, however, the number of inspections for H-2A worker housing doubled from 2014 to 2015, again from 2015 to 2016, again from 2016 to 2017 and continued to increase in 2018.”

 Comment:

That paragraph continues: “There appears to be a reduction in domestic worker migration due to the safety and security concerns mentioned in the governor’s proclamation. This is increasing the demand for foreign workers under the H-2A Visa program…” These are conclusory statements without any data or sources cited to support them. PACR Subcommittee members have identified a reduction in domestic worker migration due to growers’ stated use of the H-2A program as well as the reduction in grower-owned housing being offered to domestic workers.

 Response:

Outreach contacts have also identified the safety and security concerns as a reason for decrease in migrant family migration. While there may not be a specific citation to reference, this is a common theme heard across multiple agencies and states. The reference to housing as a cause has already been referenced.

 Comment:

The last paragraph following the Governor’s proclamation identifies English language proficiency as a “barrier for Migrant Seasonal Farmworkers (MSFWs) access to education, training, and employment, opportunities.” The Plan does not address how it will ensure that each one-stop center is able to meet the needs of English language learners, such as through discussing established procedures, staff training, resources, and other materials. It would be helpful for MSFW service agencies if the Department of Labor and Economic Opportunity (LEO) would provide information that includes, for example: The prevalence of Spanish-speaking staff in one-stop centers, including the significant MSFW offices; the ability of English-speaking staff to use translation services; and, if a center’s plan includes utilizing the migrant services worker who is located in that office, whether the office has a plan for serving customers when the migrant services worker is out of the office on outreach.

 Response:

The WIOA State Unified Plan addresses the provision of service to English language learners (ELLs), in the Adult Education and Family Literacy Act Program section. The State Administrator and the State Monitor Advocate will monitor the Michigan Works! Agencies (MWAs) to ensure they are meeting the needs of ELLs throughout the state.

 Comment:

The first paragraph that states “the agricultural industry in Michigan continues to produce over 300 commodities on a commercial basis”. Some PACR Subcommittee members expressed skepticism about the accuracy of this figure and suggested that it was closer to 200. Therefore, we are asking that the source of this figure as well as others cited to be identified.

 Response:

The source of reference for 300 commodities comes from the MDARD website.  https://www.michigan.gov/mdard/0,4610,7-125-1572-7775--,00.html.  “•Michigan produces more than 300 commodities on a commercial basis, including tart cherries, blueberries, dry beans, floriculture products, and cucumbers for pickles.” 

 No change to the Plan was made.

 Comment:

The last sentence of the second paragraph states that “labor needs remained the same, although the demand for H-2A Visa workers has increased.” Several members commented that this sentence seems contradictory and recommend it be clarified by re-phasing it as “labor needs remained the same, although the use of H-2A Visa workers has increased.”

 Response:

The sentence was revised as suggested.

 Comment:

PACR Subcommittee members are concerned that the data on Table 2, which has been identical since at least 2016, is out of date with respect to the top five labor intensive crops, the heavy activity months, and the labor needed for each crop. PACR Subcommittee members are requesting that the source for Table 2 be cited and that updates be made, if available. Particular attention was paid to the labor needs for Cherries (Sweet & Tart) and the potential that corn de-tasseling and/or floriculture are likely to be in the top five. Given the explosive growth of hemp production in Michigan and the intensive labor needs of the industry, the PACR Subcommittee members also asked that this industry be considered in labor need estimates. Furthermore, the potential that Table 2 is out of date also calls into question the accuracy of estimates of labor needed and the critical period and peak season references.

 Response:

As indicated in the column header on Table 2, “Estimated….”.  These are estimated numbers obtained from multiple sources including MDARD.  No changes were made to the estimated numbers, however, as previously suggested, a citation was added.  "Table 2 provides estimates of the top commodities harvested in Michigan based on historical agricultural data gathered from multiple sources including MDARD."

 Comment:

PACR Subcommittee members noted the first paragraph lacks citations and data to support the assertions made. For example, the plan still indicates that a purported labor shortage can be attributed to “longer growing seasons, increases in fruit and vegetable yield, and MSFW families that are reluctant to remove children from school early and arrive late to their home-base state school.” The plan does not indicate its sources for this information or whether LEO contacted MSFW service agencies or its MSFW customers to obtain information about why some MSFW’s may not be returning to certain jobs in Michigan.

 Response:

These are assertions based upon information obtained through staff outreach efforts, employers, and other MSFW service agencies. The paragraph was revised to add the following: “These assertions are a result of the MSFW contacts made during outreach, and information obtained from employers, and MSFW service agencies.”

 Comment:

The last paragraph that states the “federal e-verify mandate” is impacting the migration of agricultural workers. A couple members questioned this stating that there is no such federal mandate. Members acknowledge that several states have implemented an e-verify mandate which could impact the flow of migrant farmworkers. PACR Subcommittee members ask that this be evaluated and rewritten with the inclusion of citations to any research or data used to support the alleged impact on Michigan’s migration patterns.

 Response:  The sentence was revised to "Employers are choosing to use the e-verify system to verify employment eligibility of workers, and therefore it is impacting the recruitment of migrant workers who may otherwise not be eligible." 

 Comment:

PACR Subcommittee members note the inconsistency between the alleged labor shortages and reduced labor demand caused by the 2019 weather anomalies that resulted in “crops that could not be grown or harvested.” PACR Subcommittee members request citations or sources be identified for the data in Table 3 and Table 4 and the assertions related to the labor shortages and impacts of the weather anomalies.

 Response:

A citation was inserted however this information does not pertain to Tables 3 & 4.  The last paragraph was revised to include the following: “According to an MLive News article posted June 21, 2019 by Lauren Gibbons noted that ”According to Michigan Farm Bureau, as of June 9 Michigan farmers have had 3.5 days with proper conditions for fieldwork this year....””

 Comment:

The first paragraph references a peak season of April through November; however, Table 2 indicates that February is a “heavy activities month” in apples and cherries. The increase in job orders including work periods in January and February and migrant labor camp occupancy periods beginning in February further supports a more thorough review and analysis of the “critical months.”

 Response:

While some areas within the state experience heavy activities during the months of January through March, through the outreach conducted by LEO staff, we've identified that mid-March through mid-November remain the critical months for outreach.

 No change to the Plan was made.

 Comment:

The paragraph before Table 5 estimates that there are approximately 23,000 MSFWs during the non-peak season while Table 5 indicates 3,000 migrant workers and 7,000 seasonal workers for a total of 10,000 workers during non-peak season. PACR Subcommittee members ask that this contradiction be resolved. Also, PACR Subcommittee members note that the National Agricultural Statistics Services (NASS) was referenced as a data source, despite the assertion on that the NASS data is likely to result in low estimates of MSFWs employed in Michigan due to the survey methods. PACR Subcommittee members request the AOP clearly identify how estimates were calculated and data sources were used in arriving at those estimates.

 Response:

The sentence was revised as suggested to “10,000 MSFWs during Non-Peak Season” to resolve the contradiction.

 Comment:

The fifth bullet in the list of printed materials references a Migrant Resource Council Brochure. There are nine Migrant Resource Councils (MRCs). PACR Members recommend that the fifth bullet in the list be changed to “Migrant Resource Council Brochures” and that the brochures from each MRC be included in the packets.

 Response:

While the comment is taken into consideration, the brochures provided in the packets contain the information that is pertinent to that locality/region.

 No change to the Plan was made.

 Comment:

The seventh bullet in the list of printed materials contained in each packet provided to MSFWs incorrectly refers to “Farm Worker Legal Services” instead of its actual name – Farmworker Legal Services. Also, since 2016, the calendar has been a joint project of the Michigan Immigrant Rights Center (MIRC) and Farmworker Legal Services (FLS). PACR Subcommittee members recommend acknowledging both MIRC and FLS and further acknowledge that the Calendar is made available to MSFW outreach workers through the various MRC meetings, pre-season events, and upon request.

 Response:

The bullet was revised to “Annual Calendar - a joint project by Farmworker Legal Services and the Michigan Immigrant Rights Center (if available); and.”

 Comment:

 PACR Subcommittee members recommend adding in the packet of printed materials a list of H-2A jobs available in the state of Michigan, which includes the advanced pay rates for those jobs and how workers can access those jobs.

 Response:

A tip sheet on how to search for work using the Pure Michigan Talent Connect website was developed and will be included as part of the packet. This will allow job seekers the ability to search for work using a computer or mobile view platform.

 Comment:

PACR Subcommittee members are concerned with the statement that “MSFWs are encouraged to visit the local Michigan Works! Service Center to receive the full range of services.” PACR Subcommittee members contend that the full range of services should be provided to MSFWs in the field.

 Response:

To clarify, the full range of services are provided in the field if preferred by the worker, however, they are encouraged to visit the Michigan Works! service center or access services via phone or virtual measures, as applicable. The second sentence of the paragraph states, “However, if the MSFWs are unable or unwilling to visit a service center, MSFW outreach workers provide as much service as possible while on site.” There are a limited number of services that cannot be provided in the field primarily due to technology connectivity issues in rural areas, and/or the scope of the work falls outside of the MSFW outreach workers job duties. Example: Filing for Unemployment, TABE assessments, etc. In addition, per federal regulations: “The objectives of the outreach program are: to contact MSFWs where they work, live, or gather and inform them of the full range of employment and training services available at American Job Centers;”

 Comment:

The list of services that migrant service workers can provide in the field does not include informing farmworkers about potential H-2A jobs. Given the enhanced pay rates for these jobs and the inability of these H-2A employers to find domestic laborers, PACR Subcommittee members request that information about these jobs be offered in the field. PACR Subcommittee members also suggest that services provided in the field include coordination with Unemployment Insurance Agency to ensure MSFWs are able to register for unemployment, have proof of their work search, and are provided full access to unemployment benefits while they are unemployed in Michigan.

 Response:

Outreach staff inform workers of all available jobs, including non-agricultural jobs. Regarding Unemployment Insurance, the Unemployment Insurance Agency policy requires that the unemployed worker report in person to the Michigan Works! service center to register for work. Outreach staff make themselves available to assist workers in the registration and work search process.

 No change to the Plan was made.

 Comment:

The Plan allocates only 9 permanent positions and 11 seasonal positions. This is a reduction in permanent staff from prior plans. The Plan should address the time frame for the seasonal positions and should address how outreach activities and services to the MSFW population may be effective by the reduction in permanent positions, especially with the increase in job orders for periods of employment during the “off peak” seasons.

 Response:

The Plan does provide that peak-season is from mid-March to mid-November and therefore one could glean the time frame for the seasonal positions.  The staffing structure changed in 2019 to include two full-time Departmental Supervisors which should account for the addition of permanent positions.  The Departmental Supervisors are not counted as outreach staff; however, they were referenced in the paragraph.  The addition of the Departmental Supervisors established a career ladder among the work unit.  

No change to the Plan was made.

 Comment:

The penultimate paragraph concludes by stating that “MSFW outreach workers have been assigned to areas based upon a centralized methodology which allows for the most efficient approach to provide outreach.” This centralized methodology is not explained so it is unclear to PACR Subcommittee members how efficiency is determined or evaluated. Therefore, PACR Subcommittee members recommend clarifying what data and methods will be used to assign MSFW outreach worker to an area and to assess the effectiveness of outreach.

 Response:

Comment is taken into consideration.

 No change to the Plan was made.

 Comment:

PACR Subcommittee members raise additional concerns to the extent that the assignment of MSFW outreach workers does not correspond to the offices designated as “significant offices” as stated in the final paragraph. The Plan asserts that “the MSFW outreach workers will still provide vigorous outreach in the areas covered by a significant office” but it does not explain why the placement of a migrant service worker in a non-significant office is preferable to placing the worker in a significant office or how “vigorous outreach” will be accomplished. For example, Dowagiac is a significant office but does not have a permanent migrant services worker assigned to it. While Lapeer is not a significant office but has a permanent and seasonal worker assigned to it.

 Response:

Comment is taken into consideration.

 No change to the Plan was made.

 Comment:

The last sentence of the first paragraph refers to providing services in a language readily understood by the MSFW. Prior WIOA Unified State Plans also indicated that “significant offices maintain the Translator Resource List at the front desk to use when a bilingual staff person in unavailable.” PACR Subcommittee members request that this language be restored and that a copy of Translator Resource List be included the appendix again.

 Response:

With the evolution of translation services available via telephone, Michigan Works! Agencies have adopted the use of these services to be able to communicate with ELLs when a bilingual staff person is unavailable. Many no longer use a Translator Resource List.

 No change to the Plan was made.

 Comment:

The paragraph preceding Table 6 states that the data represents the three prior program years beginning July 1, 2016 through June 30, 2019; but Table 6 only includes data through program year 2018. PACR Subcommittee members request that the data in Table 6 include available 2019 data.

 Response:

We are currently in Program Year 2019: therefore, the data would be incomplete to provide a valid comparison to other program years.

 No change to the Plan was made.

 Comment:

Furthermore, Table 6 states that it contains “Data Used to Determine Significant Offices.” This table only includes 2016 data for Benton Harbor, Dowagiac, Greenville, Holland, Paw Paw, Shelby, and Traverse City. Furthermore, according to Table 7, Holland is a Significant Office, however, Table 6 does not provide data for Holland in 2018. PACR Subcommittee members suggest that data be provided for all ten One-Stop Centers with migrant services workers—including Holland, Adrian, Lapeer, and Three Rivers—for each program year. Including all One-Stop Centers will give a more complete picture of both MSFWs as well as the total registered participants at these locations.

 Response:

A change was made to add Holland data to table 6 for PY 2018, and update table 7 to reflect that Greenville is a significant office.  

No change to the Plan was made.

 Comment:

The AOP lists all the official workstations and outreach areas. PACR Subcommittee members have continuing concerns that having the Migrant Service Workers stationed at the designated one-stop centers results in some being physically located more than 30 miles away from actual migrant concentrations. At IMSC meetings, LEO is reporting that they are making staffing changes and expanding to other areas across the state and that seasonal staff are being better positioned to cover those areas between one-stop centers. However, these efforts are not reflected in the AOP. PACR Subcommittee members request that an explanation of the changes and data supporting the proposed changes be included in the AOP.

 Response:

While outreach staff are assigned to a Michigan Works Office as an official workstation, they can telecommute to ensure they are providing services to MSFWs within a 50-mile radius. The request for an explanation is noted.

 No change to the Plan was made.

 Comment:

PACR Subcommittee members seek clarification on the statement that “Regions 1, 3, 7, and 10 are not currently utilizing migrant and seasonal farm workers for agricultural labor.” The 2013 Migrant and Seasonal Farmworker Enumeration Profiles Study, 2019 MDARD migrant labor camp list, and job orders in the agricultural recruitment system suggest that there are MSFWs employed in agricultural labor in those regions.

 Response:

The sentence was revised to "Please be aware that there is not a significant use of migrant and seasonal farm workers for agricultural labor in Regions 1,3,7, & 10.”

 Comment:

PACR Subcommittee members recommend updating the last sentence of the last paragraph to include the purpose of the State Monitor Advocate’s (SMA’s) attendance at meetings is “to connect with MSFW service providers regarding valuable information for workers.”

 Response:

Comment is taken into consideration; however, this section is referring to Agricultural Employer Outreach. A revision was made to the second to last sentence to “The State Monitor Advocate presents at various meetings to explain the Employment Service Complaint System and the Agricultural Recruitment System.”

Comment:

The first paragraph emphasizes building strong and trusting relationships with employers. PACR Subcommittee members acknowledge that MSFWs have a well-documented “fear of retaliation from their employer” and refuse to make a complaint because “they believe that inspectors are too friendly with the grower to take any action.”1 PACR Subcommittee members request the AOP identify how MSFW outreach workers will overcome any biases or perceived biases that may result from these relationships and could otherwise interfere with their mandate to provide MSFWs with full services, including assistance with employment related complaints.

 Response:

Comment is taken into consideration however this section is referring to Agricultural Employer Outreach.

 No change to the Plan was made.

Comment:

PACR Subcommittee members recommend including unemployment insurance in the list of training provided to migrant service workers.

 Response:

The Unemployment Insurance training is provided to MSFWs and is mentioned in the appropriate section of the AOP.

 No change to the Plan was made.

 Comment:

PACR Subcommittee members request that the proposed estimates in the second to last paragraph be updated to reflect the estimates for Program Year 2020 and include the actual figures for Program Year 2019.

 Response:

Comment taken into consideration:  however, we are currently in PY 2019, therefore the figures for PY 2019 are not fully available and therefore we're unable to estimate projections for PY 2020.

 No change to the Plan was made.

 Comment:

The penultimate paragraph speaks to outreach worker’s involvement with the regional migrant resource councils without noting the policy forbidding them to serve as officers. This deprives the Migrant Resource Councils (MRCs), particularly the smaller MRCs, of full participation and jeopardizes their future viability. PACR Subcommittee members ask for this policy to be reconsidered. In addition, PACR Subcommittee members recommend adding outreach worker attendance at annual IMSC Outreach Worker Training as an example of trainings provided and collaboration with partner agencies.

 Response:

Comment is taken into consideration.

 No change to the Plan was made.

 Comment:

The list of partnering agencies and services provided is inadequate. Partnering agencies are only listed once, even when they are responsible for several services. For example, the Michigan Department of Health and Human Services is only listed as providing “Food, Clothing, Housing, and Utility Assistance” when it also provides “Child Care” and “Health Care” assistance. In addition, several agencies were misspelled, mischaracterized, or inaccurately named while others were omitted. In addition, the Whirlpool Hispanic Network needs to be removed as they are no longer participating in the annual Christmas Basket Project. Please see the attached list as an example of partnering agencies and services provided. This list may require additional updates regarding services provided and is not exhaustive.

 Response:

This section was revised as suggested.

 Comment:

The first paragraph states: “Services delivered in the One-Stop centers include assistance with job descriptions, writing job orders, and the referral of workers to job postings.” However, at a recent IMSC meeting, it was stated that the One-Stop centers are not providing technical assistance in writing information that would be used in a job orders, such as the ETA 790. PACR.  Subcommittee members request clarification regarding what, if any, assistance is provided to employers in drafting job descriptions and job orders.

 Response:

Comment taken into consideration. This was either a misunderstanding of a comment that was made, or more information will be required to follow up with the specifically identified one stop center.

 No change to the Plan was made.

 Comment:

The final paragraph indicates that the state received “nearly 400 complaints during the previous four-year cycle of the Agriculture Outreach Plans (AOP).” PACR Subcommittee members request data regarding the types of complaints, regions complaints were received, and form of complaint be included in the AOP and be used to instruct the priorities and activities set forth in the AOP in order to improve equity and access to workforce programming.

 Response:

Comment is taken into consideration.

 No change to the Plan was made.

 Comment:

The third item on the “Marketing the Employment Service Compliant and the Agricultural Recruitment System” list, which provides the different marketing techniques used by the SWA to promote recruitment of migrant farmworkers and ways for them to file a complaint, states: “One-Stop centers will display the poster ‘If you have a complaint.’” PACR Subcommittee members recommend that list clarify that both Spanish and English posters be included due to the limited English proficiency of MSFWs as indicated in the AOP.

 Response:

Revision was made as suggested. One-Stop centers will display the poster "If you have a complaint;" in both English and Spanish.

 Comment:

The first paragraph discusses the Memorandum of Understanding (MOU) between LEO, the Department of Health and Human Services, and Telamon’s National Farmworker Jobs Program. The committee recommends that a copy of this MOU be included in the appendix, as it was in prior Agricultural Outreach Plans. In addition, the Plan should indicate what actions and results have been accomplished as a result of the MOU. For example, the plan should describe the numbers and types of referrals made, the special projects that have been undertaken, and whether joint staff meetings have occurred and what they have accomplished.

 Response:

Comment taken into consideration. The AOP does not require the extent of accomplishments that is being requested by the IMSC PACR subcommittee, however, LEO staff are open to further discussion with MOU partners.

 No change to the Plan was made.

 Comment:

The fifth paragraph discusses LEO’s intention to expand English as a Second Language (ESL)/English Level Proficiency (ELP) and states that “There are best practices already in place within the state that will serve as a model for other communities” without identifying any of these best practices. The PACR Subcommittee members request that examples of these best practices be provided.

 Response:

Comment is taken into consideration.

 No change to the Plan was made.

 Comment:

The last paragraph discusses LEO’s MOU with Love, Inc. which was expected to be completed within program year 2019. PACR Subcommittee members request that the AOP is updated to indicate whether an MOU was completed in 2019 and, if so, include a copy of the MOU as an appendix. In addition, the Plan should indicate what actions and results have been accomplished as a result of the MOU. For example, the plan should describe the numbers and types of referrals made, the special projects that have been undertaken, and whether joint staff meetings have occurred and what they have accomplished.

 Response:

Comment is taken into consideration. As previously indicated, we are in PY 2019 at the present time. Workforce Development will continue the practice of strengthening partnerships such as that with Love, INC. through a mutual acknowledgement of addressing the needs of MSFWs and facilitating referrals for services.

  Comment:

The reference to the “Interagency Migrant Services Council” should be corrected to the “Interagency Migrant Services Committee (IMSC).” Also, the list of IMSC member agencies is incorrect with some agencies missing and others misspelled. Please see the attached list for a full listing of IMSC members with correct spellings.

 Response:

Revision was made as suggested.

 Comment:

IMSC and PACR Subcommittee Members request that Table 8 be updated to include data relating to program year 2019 and also to include the additional following data for each program year: the total number of contacts; number of individuals who were referred and placed in a job; the number of individuals who chose “not to register;” number of individuals who were determined to be a non-applicant, because they already have job commitments at time of contact; the number of individuals who were referred to a local job order; number of individuals who were referred to an intrastate job order, the number of individuals who were referred to an interstate job order; and the number of workers who are referred to jobs outside of the agricultural recruitment system. IMSC members also request that the AOP provide this data for non-MSFW individuals who have contact with Job Development Centers.

 Response:

Comment is taken into consideration.

 No change to the Plan was made.

 Comment:

PACR Subcommittee members seek clarification regarding the discrepancy between the Total MSFW Applicants and Job Development Contact listed in Table 8 and the Total Number of Contacts listed in Table 9. PACR Subcommittee members indicated concern that Table 9 indicates job development had contact with 16,791 MSFWs, but only 7008 MSFW applicants and only 378 MSFWs were referred to a job. PACR Subcommittee members request clarification regarding the discrepancy in these numbers.

 Response:

Comment taken into consideration. There is no discrepancy in the numbers, it may be a misunderstanding of the data presented. LEO staff will be happy to clarify at the next PACR subcommittee meeting.

 No change to the Plan was made.

Comment:

Table 9 is still showing Program Year 2019 as a projected program year. PACR Subcommittee members request that Program Year 2019 data be included as actual numbers and that the projected number of contacts for 2020-2023 be updated. Likewise, the projections in Table 8 and Table 9 should be updated to indicate projections for Program Years 2020-2023.

 Response:

Comment is taken into consideration. As previously indicated, we are in PY 2019 at the present time.

 No change to the Plan was made.

 Comment:

The third paragraph states: “Permission to enter the workers living and working areas is obtained prior to all visits.” PACR Subcommittee members are concerned that this statement implies that obtaining permission from the agricultural employer prior to visiting a worker’s living area is required by law instead of being agency policy and seeks clarification as to how this policy provides MSFWs equitable access to workforce programming.

 Response:

USDOL Guidance and Department policy require outreach staff to attempt to obtain permission. The sentence was revised to “Permission to enter the workers living and working areas is attempted to be obtained prior to all visits.”

 Comment:

PACR Subcommittee members request that data be provided for the actual number of jobs received, the total number of agricultural positions posted, the number of food processing/production positions filled, the number of hand harvesting positions filled, and the number of agricultural equipment operations/mechanics filled as was provided in prior years. In previous AOPs, the Performance Target and Goals Achieved for the prior program year was provided for each data set listed in Table 8. PACR Subcommittee members request this data again be provided.

 Response:

Comment is taken into consideration. The AOP does not require the extent of data collection that is being requested by the IMSC PACR subcommittee.

 No change to the Plan was made.