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Plan: West Virginia PYs 2024-2027
Combined Plan C

Section: Wagner-Peyser Act

Narrative: e. 6. B.

Published
Located in:

e. 6. B. Review and Public Comment

In developing the AOP, the SWA must solicit information and suggestions from NFJP grantees, other appropriate MSFW groups, public agencies, agricultural employer organizations, and other interested organizations. In addition, at least 45 calendar days before submitting its final AOP, the SWA must provide a proposed plan to NFJP grantees, public agencies, agricultural employer organizations, and other organizations expressing an interest and allow at least 30 days for review and comment. The SWA must: 1) Consider any comments received in formulating its final proposed AOP; 2) Inform all commenting parties in writing whether their comments have been incorporated and, if not, the reasons therefore; and 3) Transmit the comments and recommendations received and its responses with the submission of the AOP.

The AOP must include a statement confirming NFJP grantees, other appropriate MSFW groups, public agencies, agricultural employer organizations and other interested employer organizations have been given an opportunity to comment on the AOP.  Include the list of organizations from which information and suggestions were solicited, any comments received, and responses to those comments.

View corresponding narrative from PYs 2020-2023

Current Narrative:

On 12/7/23 WorkForce submitted a draft of the AOP to our NFJP partner Telemon for review and comment. Telemon returned the AOP with no comments or additional feedback and agreed to the state's proposed plan for agricultural outreach over the next 4 years. The WIOA State Plan was posted on our website (workforcewv.org) from February 14th 2024 to March 1 2024. Two responses were received but none related to the AOP. 

On April 12th, the updated AOP was sent to WVU Extension, WV Farm Bureau, NFJP grantee and those employers where we have conducted outreach for their comments and feedback. A follow up email was sent on April 30th, reminding them to review the plan and provide any comments by May 11th.  The only comments received were from the NFJP grantee.  The comments were reviewed and appropriate changes were made to the plan. 

Feedback/Comments:

Section 1:  ASSESSMENT OF NEED. PROVIDE AN ASSESSMENT OF THE UNIQUE NEEDS OF FARMWORKERS IN THE AREA BASED ON PAST AND PROJECTED AGRICULTURAL AND FARMWORKER ACTIVITY IN THE STATE. SUCH NEEDS MAY INCLUDE BUT ARE NOT LIMITED TO: EMPLOYMENT, TRAINING, AND HOUSING.

  • First paragraph
    • Telemon provided clarification of who was building worker housing for the poultry industry. This was updated in the plan.
  • Second paragraph
    • Telemon suggested adding “and H2A workers” into the demographics of MSFWS in WV.  That was not added as the current sentence states that the majority of the workers are foreign workers as opposed to domestic migrant workers.  The fact that the AOP stated they are foreign workers also means they are H2A workers so the suggestion was not added. 
    • Telemon commented that in order to provide services to H2A workers, Telemon must ensure that state outreach workers validate the support is not something that is covered under the employer contract and that all community resources have been exhausted. This was not added to the plan because the plan was not specific in the requirements from obtaining those issues for Telemon or community partners. 
  • Third paragraph
    • Telemon commented on the Worker Protection Standards (WPA) and heart stress training that is provided to agriculture employers at no charge.  This was added to the plan.

Section 3: AN ASSESSMENT OF THE UNIQUE NEEDS OF FARMWORKERS MEANS SUMMARIZING MIGRANT AND SEASONAL FARM WORKER (MSFW) CHARACTERISTICS (INCLUDING IF THEY ARE PREDOMINANTLY FROM CERTAIN COUNTRIES, WHAT LANGUAGE(S) THEY SPEAK, THE APPROXIMATE NUMBER OF MSFWS IN THE STATE DURING PEAK SEASON AND DURING LOW SEASON, AND WHETHER THEY TEND TO BE MIGRANT, SEASONAL, OR YEAR-ROUND FARMWORKERS). THIS INFORMATION MUST TAKE INTO ACCOUNT DATA SUPPLIED BY WIOA SECTION 167 NATIONAL FARMWORKER JOBS PROGRAM (NFJP) GRANTEES, OTHER MSFW ORGANIZATIONS, EMPLOYER ORGANIZATIONS, AND STATE AND/OR FEDERAL AGENCY DATA SOURCES SUCH AS THE U.S. DEPARTMENT OF AGRICULTURE AND THE U.S. DEPARTMENT OF LABOR (DOL) EMPLOYMENT AND TRAINING ADMINISTRATION

  • Telemon commented that they have seen a large influx of Haitian Creole workers in the Hardy County poultry plant.  This was added to the plan
  • Telemon commented that they provide heat stress train and NFJP program information during the onboarding events for Pilgrims Poultry plant on a weekly basis.  This was added to the plan. 

Section 4: 

A.  THE LOCAL OFFICES OUTREACH ACTIVITIES MUST BE DESIGNED TO MEET THE  NEEDS OF MSFWS IN THE STATE AND TO LOCATE AND CONTACT MSFWS WHO ARE NOT BEING REACHED THROUGH NORMAL INTAKE ACTIVITIES. DESCRIBE THE STATE AGENCY’S PROPOSED STRATEGIES FOR: A. CONTACTING FARMWORKERS WHO ARE NOT BEING REACHED BY THE NORMAL INTAKE ACTIVITIES CONDUCTED BY THE EMPLOYMENT SERVICE OFFICES. 

  • Telemon commented they have one staff person strategically  located in Hardy County to provide workforce and career services to MSFWs and their families.  This was added to the plan. 

C. INCREASING OUTREACH WORKER TRAINING AND AWARENESS ACROSS CORE PROGRAMS INCLUDING THE UNEMPLOYMENT INSURANCE (UI) PROGRAM AND THE TRAINING ON IDENTIFICATION OF UI ELIGIBILITY ISSUES

  • Telemon suggested “NFJP grantee” be added to the list of core programs.  This was not added as the NFJP grantee is not a core WIOA program.

E. COORDINATING OUTREACH EFFORTS WITH NFJP GRANTEES AS WELL AS WITH PUBLIC AND PRIVATE COMMUNITY SERVICE AGENCIES AND MSFW GROUPS

  • Telemon commented that their funding enables the provision of workforce and career services to the easternmost counties of West Virginia, with virtual services accessible statewide.

Telamon focuses on the Potomac Highlands area, encompassing Grant, Hardy, Hampshire, Mineral, and Pendleton Counties. WorkForce West Virginia coordinates with the NFJP grantee for outreach activities in these designated counties, ensuring joint efforts and effective planning. Additionally, collaborative outreach extends to Berkeley, Jefferson, and Morgan Counties. Regular quarterly meetings convene with our NFJP partner and other organizations serving farmworkers, fostering discussion and strategy development to enhance services for MSFWs. This was added to the plan. 

 OTHER REQUIREMENTS

(A) Collaboration. Describe any collaborative agreements the State Workforce Agency (SWA) has with other MSFW service providers including NFJP grantees and other service providers. Describe how the SWA intends to build upon/increase collaboration with existing partners and establish new partners over the next four years (including any approximate timelines for establishing agreements or building upon existing agreements). 

  •  Telemon wanted the following sentence removed “ The state will work toward identifying additional NFJP grantees and their respective directors who are operating components of this program in West Virginia and work with them to streamline and coordinate services in a seamless manner.” Their comments was “we are the only grantee in the state, please don’t look to replace us” There was no change made in the plan based on these comments.