May 23, 2002

Dear Senator,

We are writing to express our opposition to the "super-waiver" proposal that was included in H.R. 4737, welfare reauthorization legislation passed by the House on May 16. We believe that the super-waiver poses serious dangers to a broad cross-section of federal programs and the people they serve.

The super-waiver would give sweeping authority to cabinet secretaries to eliminate congressional standards and requirements for federal programs. Under this proposal, cabinet secretaries could approve requests from governors for state-wide waivers of many different federal statutes and regulations in multiple federal programs. We have serious concerns about the impact that this far-reaching proposal could have, including that it would:

1. Represent a massive and unprecedented transfer of power from Congress to the executive branch and the governors. Congressional authorizing committees have worked on a bipartisan basis on numerous occasions to set careful standards and policy for important federal programs. The super-waiver would effectively give governors and cabinet secretaries veto power over those policy decisions. The ability of Congress to negotiate legislation with the White House would also be seriously undermined if the Administration could then pick and choose which provisions would actually be enforced, by granting waivers of those provisions it did not support.

1. Weaken congressional control over how federal dollars are spent. The super-waiver could be used to alter the fundamental nature of a federal program. As a result, states could use federal funds in ways Congress never contemplated, including to replace state dollars in state-run programs, so that states could then use those dollars for entirely unrelated purposes. Resources could also be redirected from less politically powerful geographic areas or groups of people, to areas or groups that a particular governor favored more.

1. Undermine important protections for federal program participants. The super-waiver would permit the elimination of important protections for people served by federal programs, with no opportunity for input or oversight on the part of affected communities. Many vital requirements in programs covered by the super-waiver could simply be waived away.

We are not opposed to state flexibility in federal programs, where appropriate. However, this can be accomplished through state options or through waiver authority that is targeted to areas where it has been demonstrated that waivers may help states operate programs more effectively, rather than allowing sweeping waivers of federal standards across programs.

We urge you to oppose legislation containing this super-waiver proposal.

Sincerely,

ACORN (Association of Community Organizations for Reform Now)

AFL-CIO

AFSCME

Agenda for Children (New Orleans, LA)

Akron Canton Regional Foodbank

Alliance for Children and Families

Alliance for Children’s Care, Education and Support Service

Alliance for Family Success

American Academy of Pediatrics

American Association of People with Disabilities

American Association of University Women (AAUW)

American Association of University Women of Maine

American Association of University Women of South Dakota

American Civil Liberties Union (ACLU)

ACLU-Wisconsin

American College of Obstetricians and Gynecologists (ACOG)

American Congress of Community Supports & Employment Services (ACCSES)

American Counseling Association (ACA)

American Educational Research Association

American Federation of Teachers

American Library Association

American Network of Community Options and Resources (ANCOR)

Americans for Democratic Action

America’s Second Harvest

Anti-Hunger Action Committee (Utah)

Applied Research Center

The Arc of the United States

Arise Citizen’s Policy Project (Montgomery, AL)

Association for Career and Technical Education (ACTE)

Association of Farm Worker Opportunity Programs

Association of Maternal and Child Health Programs (Washington, DC)

Association of Tech Act Projects (ATAP)

Association of University Centers on Disabilities (AUCD)

Arizona Association of Food Banks

Audubon Area Child Care Resource and Referral Agency

Bazelon Center for Mental Health Law

The Benedictine Sisters of Baltimore

Boston ACORN (Association of Community Organizations for Reform Now)

Brain Injury Association of America

Bread for the World

California Child Care Resource and Referral Network

California Food Policy Advocates

Caring Unlimited (Maine)

Catholic Charities USA

Center for Adolescent Health & the Law (Chapel Hill, NC)

Center for Civil Justice (Saginaw, MI)

Center for Community Change

Center for Law and Social Policy

Center for Public Policy Priorities (TX)

Center for Women Policy Studies

Center on Budget & Policy Priorities

Child Care Law Center (San Francisco, CA)

Child and Family Services of New Hampshire

Child Welfare League of America

Children’s Action Alliance (Phoenix, AZ)

Children’s Alliance of Washington

Children’s Defense Fund

Children’s Defense Fund - Minnesota

The Children’s Foundation

Children’s Home Society of Washington

Children’s Village Child Care Center

Church of the Brethren, Washington Office

Citizen Action of New York

The City of Madison, Wisconsin

Cleveland Foodbank

Cleveland Reads

Coalition of Religious Communities (Utah)

Coalition on Human Needs

Coastal Enterprises, Inc. (Maine)

Colorado Center on Law and Policy

Communication Workers of America (CWA)

Community Coordinated Child Care, Inc. (Madison, WI)

Community Food Bank of Tucson, Arizona

Community Food Resource Center (New York, NY)

Community Legal Services, Inc. (Philadelphia, PA)

Community Voices Heard (New York, NY)

Connecticut Association for Human Services

Connecticut Coalition to End Homelessness

Connecticut Housing Coalition

Consortium for Citizens with Disabilities TANF Task Force

Corporation for Ohio Appalachian Development

Council for Advancement of Adult Literacy

Council for Exceptional Children

Council of State Administrators of Vocational Rehabilitation (CSAVR)

Crossroads Urban Center (Salt Lake City, UT)

CWA Local 1081

Day Care Action Council of Illinois

D.C. Employment Justice Center

Early Childhood Policy Research

Economic Policy Institute

Employment Unit, Greater Boston Legal Services

ENPHRONT (Everywhere and Now Public Housing Residents Organizing Nationally Together)

Evansville Goodwill Industries, Inc.

Families USA

Family & Children’s Service (Evansville, IN)

The Family Economic Initiative (Boston, MA)

Family Planning Association of Maine

Family Services of Delaware County, Indiana

Family Violence Project (Maine)

Federation for Community Planning (Cleveland, OH)

Fiscal Policy Institute

Florida Legal Services, Inc.

The Food Bank of Alaska

Food Research and Action Center (FRAC)

FreeStore Foodbank (Ohio)

Greater Hartford Legal Assistance

Greater Upstate Law Project (Albany, NY)

Helen Keller National Center (Sands Point, NY)

Higher Education Consortium for Special Education

Hunger Action Network of New York State

I-NABIR (Inter-National Association of Business Industry and Rehabilitation)

Indiana Coalition on Housing and Homeless Issues (ICHHI)

Institute for Wisconsin’s Future

International Brotherhood of Teamsters (IBT)

Kennebec Valley Community Action Program (Maine)

Kentucky Task Force on Hunger

Kentucky Youth Advocates, Frankfort and Louisville

Leadership Conference on Civil Rights

League of Women Voters of the U.S.

Learning Disabilities Association of America (LDA)

Legal Action Center

The Legal Aid Society (Brooklyn, NY)

The Literacy Initiative

The Literacy Network of Greater Cincinnati

Los Angeles Coalition to End Hunger & Homelessness

Lutheran Advocacy Network/Illinois

Lutheran Office for Governmental Affairs, ELCA

Lutheran Office of Governmental Ministry — Colorado

Lutheran Office of Governmental Ministry — New Mexico

Lutheran Office on Public Policy in Maryland

Lutheran Public Policy Office of Washington State

Lutheran Services in America

Lutheran Social Services of Illinois

Maine AFL-CIO

Maine Association of Interdependent Neighborhoods

Maine Center for Economic Policy

Maine Centers for Women, Work, and Community

Maine Chapter of the National Association of Social Workers

Maine Children’s Alliance

Maine Coalition Against Sexual Assault

Maine Coalition to End Domestic Violence

Maine Coalition for Food Security

Maine Council of Churches

Maine Equal Justice Partners

Maine Head Start Directors Association

Maine People’s Alliance

Maine Women’s Policy Center

Maryland Budget and Tax Policy Institute

Maryland Committee for Children

Massachusetts Law Reform Institute

Mayor’s Commission on Literacy (Philadelphia)

McAuley Institute

Metro CareRing (Denver, CO)

Michigan 4-C (Community Coordinated Child Care) Association

Michigan Child Care Task Force

Michigan League for Human Services

Mid-Ohio Foodbank

Minnesota Budget Project

Minnesota JOBS NOW Coalition

Mississippi Human Services Coalition

Montana Food Bank Network

Mountain Empire Older Citizens, Inc. (Big Stone Gap, VA)

NAHRO (The National Association of Housing and Redevelopment Officials)

NARAL

National Alliance of Urban Literacy Coalitions (Houston, TX)

National Association for the Education of Young Children

National Association of Child Advocates

National Association of Child Care Resource and Referral Agencies

National Association of Community Health Centers

National Association of Elementary School Principals

National Association of Housing Cooperatives

National Association of Public Hospitals and Health Systems (NAPH)

National Association of School Psychologists

National Association of Social Workers

National Association of State Directors of Career Technical Education Consortium

National Association of State Directors of Special Education (NASDSE)

National Center on Poverty Law

National Coalition of 100 Black Women, Metropolitan Atlanta Chapter

National Coalition on Deaf-Blindness

National Coalition for the Homeless

National Coalition for Literacy

National Community Action Foundation

National Community Reinvestment Coalition

National Congress for Community Economic Development

National Council of Churches

National Council of Jewish Women

National Council of La Raza

National Council of Nonprofit Associations

National Council of State Directors of Adult Education

National Education Association

National Employment Law Project

National Family Planning and Reproductive Health Association

National Head Start Association

National Health Law Program

National Housing Law Project

National Institute on Out-of-School Time

National Law Center on Homelessness & Poverty

National Low Income Housing Coalition

National Mental Health Association

National Neighborhood Housing Network

National Partnership for Women and Families

National Priorities Project

National Rural Housing Coalition

National School-Age Care Alliance

National Women’s Law Center

Nebraska Appleseed Center for Law in the Public Interest

NETWORK, A National Catholic Social Justice Lobby

Network for Environmental & Economic Responsibility of the United Church of Christ

New Hampshire Commission on the Status of Women

New Hampshire Women’s Lobby/New Hampshire Women’s Policy Institute

New Jersey Department of Community Affairs - Advisory Board President

New Mexico Center on Law & Poverty

New York State Coalition Against Domestic Violence

New York State Education Department

9to5 Colorado

9to5, National Association of Working Women

NISH (National Industries for the Severely Handicapped)

Non-Profit Housing Association of Northern California

Northwest Federation of Community Organizations

Northwest Health Law Advocates (NoHLA) (Seattle, WA)

Northwoods Wilderness Recovery (Marquette, MI)

NOW Legal Defense and Education Fund

Nutrition Consortium of New York State

Ohio Association of Second Harvest Foodbanks

Ohio Literacy Network

OMB Watch

Oregon Center for Public Policy

Oregon Food Bank

Oregon Human Rights Coalition

Oregon Hunger Relief Task Force

Oregon Law Center

The Ounce of Prevention Fund (Chicago, IL)

Pennsylvania Child Care Association

Pennsylvania Hunger Action Center

People’s Regional Opportunity Program (PROP) (Portland, ME)

Philadelphia Citizens for Children and Youth (PCCY)

Planned Parenthood Federation of America

Planned Parenthood of Northern New England

The Poverty Institute at Rhode Island College School of Social Work

P.O.W.E.R. (Maine)

Prebble St. Resource Center Consumer Advocacy Project (Maine)

Presbyterian Church (USA), Washington Office

Progressive Leadership Alliance of Nevada

Public Policy Center of Mississippi

Quality Care for Children, Inc.

Religious Coalition for Reproductive Choice

Research Institute for Independent Living

Rhode Island Adult Education Commission

Rhode Island Conference, United Church of Christ, Division of Church in Society

Rhode Island Public Housing Tenants Association (RIPHTA)

River Valley Child Development Services (West Virginia)

Roman Catholic Diocese of Portland (Maine)

Sacramento Hunger Commission

Salt Lake Community Action Program

School Social Work Association of America

Schuyler Center for Analysis and Advocacy (Albany, NY)

Second Harvest Foodbank of Clark, Champaign, and Logan Counties (Ohio)

Second Harvest Foodbank of the Mahoning Valley (Ohio)

Second Harvest Foodbank of North Central Ohio

SENSES (Statewide Emergency Network for Social and Economic Security) (Albany, NY)

Service Employees International Union (SEIU), AFL-CIO

Shared Harvest Foodbank (Ohio)

Sisters of Mercy of the Americas

The Sisters of the Presentation Leadership Team (New Windsor, NY)

South Carolina Appleseed Legal Justice Center

South Dakota Family Economic Self-Sufficiency Project

South Dakota Peace & Justice Center

Southeast Technical Institute (Sioux Falls, SD)

Special Concerns Ministry

State Associations of Addiction Services

Survivors, Inc. (Boston, MA)

Tennessee Justice Center

Toledo Northwestern Ohio Foodbank

Unemployment Law Project (Seattle, WA)

United Auto Workers (UAW)

United Cerebral Palsy Associations

United Church of Christ Justice and Witness Ministries

United Food and Commercial Workers International Union

United Way & Community Chest of Greater Cincinnati

Upstate Homeless Coalition of South Carolina

US Action Education Fund

USA Child Care

Utah Issues

Utahns Against Hunger

Vermont Legal Aid, Inc.

Virginia Interfaith Center for Public Policy

Virginia Poverty Law Center, Inc.

Volunteers of America

Washington Citizen Action

Washington Food Coalition

Washington Ethical Action Office, American Ethical Union

Washington Low Income Housing Network

We Who Care (Maine)

Welfare Law Center (New York, NY)

Westchester Progressive Forum

Western Center on Law & Poverty (Sacramento, CA)

Western Region Anti-Hunger Consortium

West Ohio Foodbank

West Virginia Welfare Reform Coalition

William E. Morris Institute for Justice

Wisconsin Child Care and Education Coalition

Wisconsin Council on Children and Families

Wisconsin Early Childhood Association

Wisconsin Women’s Network Child Care Task Force

Women Employed (Chicago, IL)

Women Unlimited (Augusta, ME)

Working Families Massachusetts

York County Initiative to End Homelessness (Maine)

YWCA of Greater Portland (Maine)

YWCA of Minneapolis

YWCA of the USA