founder and

first chair
Lawrence S. Phillips

board of trustees
Chair
Jim Meier
August 30, 2007 Vice Chair
Linda Heller Kamm
Treasurer
Mark W. Bernstein
Mr. Philip M. Heneghan Secretary
Chief Privacy Officer Nancy Schwartz Sternoff
U.S. Agency for International Development President
Ronald Reagan Building Ruth W. Messinger
Office 2.12-003
Don Abramson
1300 Pennsylvania Avenue, NW Marc Baum
Washington DC 20523-2120 William P. Becker
Joyanne Bloom
Marion Blumenthal
Dear Mr. Heneghan, Jonathan Cohen
James Dubey
I am writing on behalf of American Jewish World Service (AJWS) to protest the David Elcott
Carolyn Everett
recently proposed Partner Vetting System (PVS).1 We urge immediate Marty Friedman
rescission of the PVS and the establishment of an open process with all Sally Gottesman
concerned and affected members of the international development community to Addie Guttag
Ellen A. Harnick
discuss these issues. Rabbi Richard Jacobs
Peter Joseph
AJWS is an international development organization dedicated to alleviating Steve Kantor
Kathleen Levin
poverty, hunger and disease and to promoting human rights in the developing Sara Moore Litt
world. Through grants to grassroots organizations, volunteer service, advocacy Rabbi J. Rolando Matalon
and education, AJWS fosters civil society, sustainable development and human Leo Nevas
Lawrence S. Phillips
rights for all people, while promoting the values and responsibilities of global David Rabin
citizenship within the Jewish community. Allan Rosenfield
Michael C. Rothman
Norman Traeger
AJWS is currently providing over $13 million in grant support to some 330 Diane Troderman
organizations throughout Africa, Asia and Latin America. Our grantees promote William Wardlaw
economic development, education, healthcare and sustainable agriculture while David Ilan Weis
Herbert Weiss
also working to strengthen civil society and to promote and protect human rights. Laurence Wiener
Our partners share our belief that basic human rights, transparency and civil
society engagement are the building blocks of a well-functioning democratic
san francisco
society.
131 Steuart Street
Suite 200
In short, AJWS supports the same goals—democracy, human rights and San Francisco, CA 94105
sustainable development—articulated by the Administration, the U.S. Congress t 415.593.3280
and USAID in providing international development assistance. Moreover, while f 415.593.3290
AJWS does not presently receive USAID funding, 22 of our current grantees are
also grantees or sub-grantees of cooperating agencies receiving and delivering washington, d.c.
U.S. international development assistance. 1413 K Street, NW
5th Floor
Washington, D.C. 20005
t 202.408.1380
1 f 202.408.1429
Re: RIN 0412-AA61; Notice, Privacy Act System of Records, Federal Register, Vol. 72, No. 136, July 17,
2007, Pages 39041-30944; No. 139, July 20, 2007 pages 39768-39770; No. 140, July 23, 2007, Page 40110

45 West 36th Street, New York, NY 10018 • t 212.792.2900 • f 212.792.2930 • e ajws@ajws.org •

www ajws org
 founder and
first chair
Lawrence S. Phillips

board of trustees
Chair
Jim Meier
The proposed PVS is antithetical to our shared goals, and will only serve to Vice Chair
Linda Heller Kamm
burden the very organizations supported by USAID and AJWS working to
Treasurer
promote development and democracy, end hunger and poverty and respond to Mark W. Bernstein
humanitarian, environmental and social crises. Secretary
Nancy Schwartz Sternoff
Specifically, we oppose the PVS on the following grounds: President
Ruth W. Messinger
• The sweeping requirements imposed by the PVS are inconsistent with Don Abramson
promoting democracy and human rights throughout the world. Marc Baum
Requiring organizations to submit personal information on every single William P. Becker
Joyanne Bloom
employee, consultant, board member and other affiliated person for entry into Marion Blumenthal
a classified database without due cause or due process contradicts the very Jonathan Cohen
premise of a democratic society based on transparency, due process and James Dubey
David Elcott
checks and balances on government power. The lack of consultation prior to Carolyn Everett
publishing the draft requirements, and the unacceptably brief comment Marty Friedman
process are worrisome and unacceptable for the very same reasons. Sally Gottesman
Addie Guttag
Ellen A. Harnick
• The requirements are highly burdensome, serve no demonstrated need Rabbi Richard Jacobs
and have no statutory basis. The PVS is ostensibly aimed at ensuring that Peter Joseph
Steve Kantor
US international development assistance is not diverted to organizations Kathleen Levin
supporting terrorism. We believe that existing safeguards and vetting Sara Moore Litt
practices have succeeded in achieving this goal and need not be necessarily Rabbi J. Rolando Matalon
Leo Nevas
and capriciously expanded, especially in light of the fact that to our Lawrence S. Phillips
knowledge, no evidence exists to support the implicit assertion that funds are David Rabin
in fact being diverted to support terrorist groups. Allan Rosenfield
Michael C. Rothman
Norman Traeger
Moreover, the burdens associated with meeting the sweeping PVS Diane Troderman
requirements can not be overstated. Many of our grantees are small, cutting- William Wardlaw
David Ilan Weis
edge organizations working to promote long-term sustainable development Herbert Weiss
while meeting immediate needs, such as ensuring access to food and water, Laurence Wiener
resettling people living in conflict zones and providing access to anti-retroviral
therapy to those suffering from AIDS-related illnesses. Complying with the
san francisco
PVS will so burden our colleague organizations as to profoundly undermine
131 Steuart Street
their daily work and their fundamental missions. Suite 200
San Francisco, CA 94105
We further concur with the points submitted by our colleague organizations t 415.593.3280
InterAction and the Global Health Council, including the concern that the PVS f 415.593.3290
would further serve to imperil the lives and safety of USAID’s partners—including
washington, d.c.
many of our grantees—and would dramatically increase the likelihood of
1413 K Street, NW
questionable use, misuse and abuse of information, of “guilt by association” and 5th Floor
of mistaken affiliation with questionable groups or activities where no such links Washington, D.C. 20005
exist. t 202.408.1380
f 202.408.1429

45 West 36th Street, New York, NY 10018 • t 212.792.2900 • f 212.792.2930 • e ajws@ajws.org •

www ajws org
 founder and
first chair
Lawrence S. Phillips

board of trustees
Chair
Jim Meier
We strongly urge you to withdraw the proposed PVS and to engage in a process Vice Chair
Linda Heller Kamm
of consultation and review with the affected communities, to provide evidence on
Treasurer
the need for any such vetting system, and to consider the profoundly detrimental Mark W. Bernstein
effects of these requirements on the core mission of U.S. international Secretary
development assistance. Nancy Schwartz Sternoff
President
Ruth W. Messinger
Sincerely,
Don Abramson
Marc Baum
William P. Becker
Ruth Messinger Joyanne Bloom
Marion Blumenthal
President, American Jewish World Service Jonathan Cohen
James Dubey
David Elcott
Carolyn Everett
Jodi Jacobson Marty Friedman
Director of Advocacy, American Jewish World Service Sally Gottesman
Addie Guttag
Ellen A. Harnick
Rabbi Richard Jacobs
cc: Henrietta Fore, Acting Administrator, USAID Peter Joseph
Joanne Paskar, Chief, Information and Records Division, Office of Administrative Steve Kantor
Kathleen Levin
Services, Bureau for Management, USAID Sara Moore Litt
The Honorable Patrick Leahy Rabbi J. Rolando Matalon
The Honorable Judd Gregg Leo Nevas
Lawrence S. Phillips
The Honorable Joseph Biden David Rabin
The Honorable Richard Lugar Allan Rosenfield
The Honorable Nita Lowey Michael C. Rothman
Norman Traeger
The Honorable Frank Wolf Diane Troderman
The Honorable Thomas Lantos William Wardlaw
The Honorable Ileana Ros-Lehtinen David Ilan Weis
Herbert Weiss
Laurence Wiener

san francisco
131 Steuart Street
Suite 200
San Francisco, CA 94105
t 415.593.3280
f 415.593.3290

washington, d.c.
1413 K Street, NW
5th Floor
Washington, D.C. 20005
t 202.408.1380
f 202.408.1429

45 West 36th Street, New York, NY 10018 • t 212.792.2900 • f 212.792.2930 • e ajws@ajws.org •

www ajws org