Comment on FR Doc # E8-18869

This has been a long awaited and needed development by DOL/VETS to strengthen the inital attempt by ETA, which was weak to say the least. While the proposed rulemaking talks about 'representation of covered persons in such programs in proportion to the incidence of representation of covered persons in the labor market"; the next step should be for DOL/VETS to issue performance standards to partner agencies operating the six identified DOL programs similar to how standards are negotiated with States in the LVER/DVOP program. This would strengthen "Vets Priority" and also demonstrate that programs need to get serious about enrolling qualified veterans and spouses within DOL programs. I would further recommend that the "incidence of representation" floor level should be termed as the "minimum achievement level" and that DOL/VETS would expect that agencies responsible for achieving "Vets Priority" look at levels that exceed the threshold level of representation. That is also why standards should be implemented to better identify what would be reasonable and then to continue to achieve higher numbers. The key is not just "point of entry" which will be difficult given the continued staff reductions across the nation in all DOL programs, especially WP. It also is complicated given that LVERs and DVOPs are not to be conducting initial assessments unless the veteran is termed "hard to place". In addition to "point of entry", language is needed to inform partner program agencies that they will need to recruit covered persons in order to meet the labor market representation if they don't meet this from the "point of entry". Something to-date that DOL programs have not done. I would also recommend that State LVER/DVOP program veteran coordinators/supervisors partner with DOL/VETS State Directors to monitor "Vets Priority" and to work closely with workforce DOL program managers to ensure that programs are doing all they can to achieve "Ves Priority" and not just given "lip service" as they have in the past. While the State Vocational Rehabilitation programs falls under the Department of Education and is not a DOL Employment and Training program, the Voc Rehab program works closely with disabled veterans and is a major component of veterans and spouses to find employment. I would recommend that DOL/VETS work to add the Vocational Rehabilitation program within the guidelines of "Vets Priority". This is a major component of an agency that has funds to help disabled veterans. While the US Veterans Administration has the Chapter 31 program, it doesn't provided what the Voc Rehabilitation program can and with both programs working together, it has further impact to helping disabled veterans and spouses.