It is particularly ironic to discover that in the distribution of food stamps the worker whose efforts are essential to the availability of fresh fruits and vegetables will be discriminated against by the proposed regulations. We are aware that others have called your attention to the flaws in the proposed regulations. particularly as they affect farmworkers. Inadequate consideration appears to have been given to the unique elements of the migrant way of lifetheir existence in rural areas. their constant mobility. and their exclusion from existing social and worker benefit programs. Issues which have especially been brought to our attention include the emphasis on households as eligible unitsa term that is most difficult to define in view of the realities of the flarmworkers life style. the requirements for detailed documentation and verification of earningsan inappropriate measure for migrant farmworkers with sporadic and unpredictable earnings engaged in seasonal work. the continued emphasis on discriminatory residence requirements. and. administrative procedures for certification. establishing and maintaining eligibility. and fair hearing and appeal procedures that lack time considerations applicable to a mobile population. These issues and others will undoubtedly make it difficult for those people who need food stamp programs the most to obtain benefits. In fact. it appears that few affirmative steps have been taken to assure in a positive way that migrant and seasonal farmworkers will receive full benefits of this program. In view of the seriousness of the situation. and the widespread hunger and malnutrition that characterizes this element of the nations work force. we urge the following course of action: 1. A special task force with a significant representation of migrant and seasonal farm workers should be established to study the extent to which benefits of the food stamp program are made available to migrant and seasonal farmworkers. The task force should be directed to report back within 90 days with suggestions fcr improving the delivery of food stamp program benefits to farmworkers. and. 2. Steps should immediately be taken to establish a national food stamp certification and distribution program for farmworkers. Such a national focus is essential. for the migrant farmworker in particular is constantly on the move to obtain employment. living either temporarily or permanently in a hostile environment. and excluded from programs. We urge that you make a careful study of our objections and proposals. as well as suggestions which you may have received from organizations who have a working familiarity and expertise with the needs of the migrant and seasonal farmworker. In view of the seriousness of this matter. and our respective Subcommittees interest in continuing our investigation into the adequacy of our nations food programs as they affect farmworkers. your immediate attention to these issues will be greatly appreciated.