Dear Secretary Clinton:

In early December the Associated Press reported that you had ordered an “extensive and thorough” review of the troubled Summer Work Travel program that is regulated by the State Department. We at the Center for Immigration Studies hope that the series of articles we have just published will be useful to your effort to reform the program so that it advances our nation’s foreign policy goals without seriously damaging the labor market for young Americans.

Unfortunately, we believe that the program is doing serious damage, especially in areas where the young SWT participants concentrate, and especially during this time of recession and record youth unemployment.

That damage is caused primarily by the failure of the State Department to reform its long record of weak regulation, indifference to the domestic labor market, and refusal to respect the values of accountability and open government that you seek to advance around the world.

We believe that while you yourself can do much to reform the SWT program, you will need the assistance of Congress. Our nation’s lawmakers have not only failed to fulfill their own oversight responsibilities, they have stepped in to frustrate suggestions by the Government Accountability Office to restrict employers’ access to young workers from around the world. At present, the SWT program offers such a remarkable and unregulated package of benefits to low-wage employers that one SWT recruiter has acknowledged that it “sounds like a scam."

What is most worrisome about the program is that it has a virtually unlimited capacity to continue to grow and displace young Americans from the workplace. While SWT sponsors join the State Department in celebrating the program’s contributions to the maturation of its participants and their preparation for international economic competition, we believe the State Department must understand that the program has grown so rapidly that it poses a threat to the future of young Americans.

Over the past decade, the State Department has shown no concern for domestic labor market effects. It has even stricken the regulation that once timidly encouraged sponsors to steer SWT participants away from areas of high unemployment. It has allowed the placement of SWT participants in urban areas notorious for high unemployment.

Meanwhile, our embassies and consulates around the world have conducted SWT promotional campaigns that have expanded the program into areas where tens of millions of young people have already been influenced by the Americanization of worldwide popular culture. Many are eager to sign up for SWT, which now promotes the globalization of the American summer job.

Here at home the sponsoring agencies, which relentlessly advertise the program and annually collect more than $100 million in fees from the participants, have developed a lobby that persistently and successfully pushes for permissive regulation. The State Department has responded with a flabby regulatory regime that requires no effort to recruit Americans, no labor market test of employers’ claims to need access to SWT workers, and no meaningful protection of the wages, working conditions, and living conditions of the young SWT participants.

The State Department’s recent decision to freeze SWT participation at current levels is a welcome sign that it recognizes the need for reform. We urge that it also recognize the need to reform its own stubborn refusal or inability to inform the American people about its administration of the program.

That failure is evident in the difficulty journalists and researchers have in obtaining information about the program and in the absence of reliable data that would allow a rigorous examination of the program’s dimensions and its effects on American workers. In our interview with Rick Ruth, the program’s new director, he acknowledged the need for such data. We encourage State to facilitate research by independent experts who could provide it.

Meanwhile, we can only express alarm that the poor quality of information produced by SWT administrators has apparently deceived your own office. We believe our series proves that there is no justification for your office’s assertion last August, in a letter to Sen. Mark Udall, that State Department officials “continuously monitor the public and private entities we designate to administer the exchange visitor program to ensure that American jobs are protected.” We believe that assertion flies in the face of the State department’s long record of futility in providing such oversight.

We ask that you hear the voice of Sarah Smith, the former State Department Foreign Service officer who understands the value of exchange programs but who also believes that SWT “is out of control” in the damage it has caused to many young Americans, including her own son.

We ask that you recall your own experience working in Alaska during your youth. The opportunities you enjoyed there – first sliming fish in Valdez and then cleaning dishes at what is now Denali National Park – were a part of your growth and maturation. We ask that you do what you can to preserve such opportunities for the young people of the United States.