University of LaVerne - Crigler, Nicole

To Whom It May Concern: As an advocate with over fifteen years of social services experience, it was with great excitement that I reviewed the above NPRM. This document provides an excellent overview of the YouthBuild history and initiatives. Also, impressive was the integration of information from multiple agencies to provide an accurate account of events. I appreciated DOL’s acknowledgment of programmatic successes and wiliness to continue with the past program design. The expansion of employment and educational opportunities will enhance the program. However, where the rule fell short was in providing innovative program measurement tools. The rule stated efforts that are standard and don’t require grantees to be as evaluative as they could be when determining gaps in services. Also, the rule doesn’t specify what “green activities” YouthBuild will commit too. Could such dialogue be an opportunity for cross agency partnership with Environmental Affairs? Lastly, the rule states that it has a positive impact on families but there in no empirical evidence to support that. Actually built-in to the program should be a way for parents and children to work together or at least discuss barriers to success the parent is facing. Thank you for your attention to this matter. Nicole Crigler University of LaVerne, DPA candidate