believe this should be accomplished without federalizing the system. I recognize the very difficult problems of financing and administering unemployment insurance for casual farm employment, but let us not let this delay any longer unemployment insurance coverage for full-time employees in all States.

Now, this is not what is in the administration's proposal. This is a fundamentally different proposition than that presented to the Congress by Secretary Shultz. I do not believe that Governor Reagan's comments can properly be used as an argument in support of Secretary Shultz' proposal. On the contrary, it supports a fundamentally different proposal-and that is coverage of permanent farmworkers, basing coverage on the nature of the work experience of the worker rather than on the nature of the employment of workers by the employer.

Certainly, we do not know very much about what farm labor coverage would mean. Would benefits be 15 percent of payrolls? Or 50 percent? Or what? There really is not much factual data to support any conclusion. The California report that farm coverage would result in a $30 million deficit annually does not include the additional costs that would result from the program itself in the form of reduced annual employment and reduction of incentive to seek new employment as summarized above. There needs to be an objective study by an agency with no policy position or preconceived ideas of what we do know as a result of studies and experience to date, and the experience in other industries with at least some degree of comparability with agriculture.

In section 4 of our written statement we have reviewed the unique administrative problems. They should not be underrated. They are difficult if coverage was extended to farmworkers, particularly because so many farmworkers work for a series of employers in two or more States. In some situations they even work for virtually a different employer every day, in those cases where the local day haul program has been highly developed.

Now, I do not say that the problems in agriculture will be unique in character. All of these problems are encountered in the present program to some degree. But they would be unique in terms of the number of occurrences, and in terms of the multiple complications in particular cases. And I would suggest that as of now we simply do not know no one has any conception based on any careful analysis of the administrative complications involved or how expensive the costs of unraveling such complications might be.

I would like to conclude with a short quotation from the final paragraph of our written statement.

We recognize that the arguments we have set forth in our statement do not apply with equal force to seasonal and permanent workers. Periodically farmers in farm organizations have looked at the question of covering permanent farmworkers with unemployment insurance. If a workable program could be developed, there would be some advantage to farmers in such coverage. In 1969, at the request of our delegate body the previous fall, a pro and con review of the coverage of permanent workers was sent to State farm bureaus for use in their policy development program last fall. Again, at our annual meeting last December our delegate body urged further study. But the study given to this problem in the respective States, and that includes

California, has not resulted in the development of any practical approach to the problem. Certainly, and particularly we do not believe that the proposals which have been presented to this committee are workable.

Thank you, sir.

Senator WILLIAMS (now presiding). Thank you, Mr. Triggs. Any questions?

Senator BYRD (now presiding). Senator Williams? Senator Bennett?

Senator BENNETT. No questions.

Senator BYRD. Thank you, Mr. Triggs.

(Mr. Triggs' prepared statement follows:)

STATEMENT OF THE AMERICAN FARM BUREAU FEDERATION, PRESENTED BY MATT
TRIGGS, ASSISTANT LEGISLATIVE DIRECTOR

SUMMARY STATEMENT

The American Farm Bureau Federation supports the following principles relating to federal unemployment compensation statutes:

1. Provisions for the adjustment of employer premiums to reflect employer experience in stabilizing employment should be continued.

2. State responsibility to determine eligibility and benefits should be preserved.

3. Coverage of temporary, seasonal and casual employment of farm workers would be impractical.

Since many witnesses will testify relative to the first two points, and since so far as we know we will be the only witness to testify concerning the third point, we will limit our testimony to the latter.

We must oppose the proposals presented to this Committee by the Secretary of Labor, which we believe would be unworkable, for the following reasons: 1. Most farm employment is temporary and seasonal

In 1968, 2,919,000 persons worked one or more days as hired farm workers. 44.5% of these worked less than 25 days for all farm employers and averaged 10 days of such employment per worker.

69.6% worked less than 75 days for all employers.

Only 30.4% worked 75 days or more for all farm employers.

Farm employment is becoming even more casual than in past years. This trend

s indicated by the fact that the average number of days worked by hired emloyees in agriculture is declining.

Supporting statistical data are set forth in Appendices B, C, and D.

2. Most farm labor is not regularly attached to the labor force

In 1968, 65% of all farm workers were students, housewives, retired people, nemployed persons, or people working on their own farms when not working as ired farm workers.

Statistical information concerning the non-attachment of most farm workers o the regular work force is set forth in Appendix E.

· Benefit claims in relation to covered employees would be excessive. Approximately 70% of the farm labor force works less than 75 days a year and would have insufficient base employment to be eligible for benefits even if the mployers of such workers were covered.

Approximately 19 percent of the farm labor force works 75-249 days a year. irtually all of these workers would be eligible for benefits if employed by covred employers, and would draw maximum or close to maximum benefits. Approximately 11 percent of the farm labor force work 250 days or more a ear. These workers may properly be termed permanent employees. Even in this ase the ratio of benefits to revenues would be high. Tens of thousands of farmers mploy a few farm workers on a 12-month basis, even though they may really eed them for only 8-10 months during the year. If the economics of the situation re changed so that it is to the mutual advantage of the employer and employee at such employees be laid off in the winter months, it is inevitable that this ill become a common practice.

NO

TH

In addition it should be noted that the ratio of benefits to payrolls would be substantially increased by the fact that thousands of workers who now seek farm employment in other states (or in other parts of the same state) would have less incentive to do so.

The only state with meaningful experience that would be helpful in an endeavor to understand the impact of extending coverage to farm workers is North Dakota.

The North Dakota unemployment insurance program for farm workers is voluntary-and is administered so as to exclude coverage of seasonal farm workers. Despite this important exclusion, during the 9 years of the program's operation benefits have averaged 12.8% of taxable payrolls.

It would appear that if seasonal workers were also covered the ratio of benefits to payroll would be substantially higher.

The North Dakota experience is summarized in Appendix F of our written statement.

4. Multi-state farm workers would present a difficult administrative problem

A substantial percentage of the hired farm labor force consists of migrants who work for a series of employers in two or more states. Such multi-state employment would necessitate, in each case where benefits are claimed, the accumulation of information necesary to determine:

The number of days of employment for each employer in the various states in which the employee has worked;

The gross earnings from each such employer;

Which employers are covered and which are not covered;

Whether the worker has cumulative work experience from covered employment by the series of employers to qualify him for benefits;

The amount and duration of benefits;

The state law which should be applicable in the determination of eligibility, the amount of payments, and the duration of payments;

The division of benefit payments and administrative costs among the states; and

Which state should handle the payment of benefits.

Supplemental problems include these: Many farm workers are illiterate and itinerant, and may be difficult to locate; they often use two or three names, for a variety of reasons; in some cases payrolling is on a family rather than an individual basis; there is a substantial "day-haul" operation in agriculture under which workers may work for different employers almost every day; in many cases farm workers are employed and payrolled by crew leaders rather than the farmer; and much farm labor employment is for only 2 or 3 hours per day.

These are not problems unique to agriculture. But we submit that the number and complexity of these problems in agriculture far exceeds those in any other industry and would involve uniquely difficult administrative problems.

No real study has been made that would throw any light on the impact of farm worker coverage on state funds and state programs. With the exception of the North Dakota data, all that are available are a few casual observations by persons who are not necessarily objective observers.

It would appear that substantially more information concerning the effects of farm worker coverage than has been provided should be available before consideration is given to such coverage.

We recognize that the arguments set forth above do not apply with equal force to seasonal and permanent workers. Periodically farmers and farm organizations have looked at the question of covering permanent farm workers with unemployment insurance. If a workable program could be developed, there would be advantages to farmers in such coverage. In 1969, at the request of our delegate body the previous fall, a "pro and con" review of the coverage of permanent workers was sent to State Farm Bureaus for use in their policy development program last fall. Again, at our annual meeting in 1969, our delegate body urged further study of this proposal. But the study of the problem given to the issue in the respective states has not resulted in the development of any practical approach to the problem. Certainly we do not believe the proposals presented to this Committee are workable.

APPENDIX A.-FARM LABOR EMPLOYMENT

The employment of hired farm workers is declining as illustrated below:

The average number of days of employment of the farm labor force is declining, as illustrated below:

The major reason for the temporary employment of most farm workers is, of course, the seasonal nature of farming.

The scope of the variation in employment (on a national basis) is indicated below for 1968 from USDA "Farm Labor" reports:

Thus the number of farm workers employed in the peak month of July is early three times the number employed in January.

The variations in most states will be sharper than for the United States as a hole.

On individual farms the seasonal variation will be even sharper. On many rms no workers are hired during the winter months, but 20-40 workers may e hired during the harvest period.

APPENDIX D.-DURATION OF EMPLOYMENT

Employment in agriculture is uniquely temporary, casual, short term. This is ustrated by the following data from "The Hired Farm Working Force of 68", published by the U.S. Department of Agriculture:

APPENDIX E.-ATTACHMENT OF FARM WORKERS TO THE NATIONAL WORK FORCE

Of the total of 2,919,000 persons who did some farm work during 1968 about two-thirds are very loosely attached to the Nation's hired work force, if at all. "The Hired Farm Working Force of 1968" reports the chief activity of such workers as follows:

The only state with any significant experience with the coverage of farm workers by unemployment insurance is North Dakota.

The North Dakota statute permits voluntary coverage of workers employed by farmers on approval of the state agency administering the program. The state agency will not approve applications for farmers producing seasonal crops. Even though this eliminates seasonal workers, and even though the payroll tax has varied between 5.82 and 6.63 percent, benefits paid to covered farm workers have been over twice tax collections.

The North Dakota experience with respect to such farm workers is summarized below: