WHEREAS, Such efforts on the part of state legislatures will advance the objectives of the Intergovernmental Cooperation Act of 1968 and therefore merit endorsement and support at the federal level, including the provision of financial assistance; now, therefore, be it Resolved by the Assembly and Senate of the State of California, jointly, That the Legislature of the State of California respectfully memorializes the President and the Congress of the United States to enact amendments to the Intergovernmental Cooperation Act of 1968 to permit state legislature to receive funds for research, demonstration and feasibility purposes under existing federal grantin-aid programs; and be it further Resolved, That the Chief Clerk of the Assembly transmit copies of this resolution to the President and Vice President of the United States, to the Speaker of the House of Representatives, and to each Senator and Representative from California in the Congress of the United States. Attest: Speaker of the Assembly. President of the Senate. Secretary of State. THE ASSOCIATION OF STATE AND TERRITORIAL HEALTH OFFICERS, Hon. EDMUND S. MUSKIE, Chairman, Subcommittee on Intergovernmental Relations, U.S. Senate, Washington, D.C. DEAR MR. CHAIRMAN: I am writing on behalf of the Association of State and Territorial Health Officers to submit recommendations on S. 2479, the Intergovernmental Cooperation Act of 1969, and S. 2035, the Grant Consolidation Act of 1969. This Association favors S. 2479 over S. 2035 for a number of reasons. First of all, we strongly support Title II of S. 2479 that pertains to accounting, auditing and reporting of Federal assistance funds. There is no such title under S. 2035. S. 2479 would authorize joint funding projects that would improve the administration of Federal financial assistance programs at the State level. There is no comparable title under S. 2035. Both S. 2035 and S. 2479 would authorize the President to submit grant consolidation plans for Congressional approval in the case of Federal assistance programs in the same or closely related functional areas. We wonder if the term "functional" should be defined or at least interpreted in the legislative history. Are health, education and welfare closely related functionally? Under both bills the formulas of grant programs could be modified under the consolidation plan. This authority could result in problems for States to the extent that Federal funds were redistributed. Furthermore, the consolidation plans would take effect within 60 or 90 days after submission to Congress. There is no provision for advance notice to States and no opportunity for their advice or consultation. Under section 1006 of S. 2035 the appropriations unexpended by reason of the grant consolidation plan would revert to the Treasury. Language should be added to this section to insure that program objectives of Federal assistance programs are not sacrificed in the interests of economy alone. Section 1004 (a) (4) of S. 2035 provides that the administration of a program or programs of a consolidation plan may only be carried out by an agency that was responsible for one or more programs prior to the effective date of the consolidation plan. This would prohibit the establishment of an "umbrella" agency at the State level and could interfere with efficiency in administration. This Association respectfully requests the enactment of S. 2479 and asks that this letter be made a part of the printed record of hearings. Sincerely yours, J. E. PEAVY, M.D., President. Hon. EDMUND S. MUSKIE, NATIONAL EDUCATION ASSOCIATION, Washington, D.C., September 19, 1969. Chairman, Subcommittee on Intergovernmental Relations, Old Senate Office Building, Washington, D.C. DEAR CHAIRMAN MUSKIE: Thank you for giving the National Education Association the opportunity to comment on S. 2479, the "Intergovernmental Cooperation Act of 1969," and S. 2035, the "Grant Consolidation Act of 1969." As you know, NEA has a great interest in proposals such as these because they directly affect the education system and the lives and working conditions of the more than two million educators in the 9000 organizations affiliated with NEA. The Representative Assembly of NEA this July reaffirmed the Association's posture on federal support of public education, and I quote the 1969 resolution in full to give you the rationale of remarks which follow. FEDERAL SUPPORT OF PUBLIC EDUCATION The National Education Association seeks federal support of public education in line with the following principles: a. That federal programs comply with current civil rights statutes and judicial decisions. b. That there be substantial general federal support of the whole of public education. c. That present federal programs of specific aids be continued, expanded, and improved by consolidation and simplification of administration. d. That further expansion of federal support to education be general in nature, and that these funds be allocated without federal control for expenditure and suballocation by state education agencies. e. That the amount of aid be generally predictable for long-range planning and specifically predictable for year-to-year planning. f. That legislation be consistent with the constitutional provision respecting an establishment of religion and with the tradition of separation of church and state. g. That the legislation contain provision for judicial review as to its constitutionality. h. That all federally supported educational programs, including those now assigned to other federal agencies (except those programs designed to train armed forces personnel), be administered by the U.S. Office of Education, pending establishment of a Cabinet Department of Education. When NEA recommends the continuation, expansion, and consolidation of existing programs, it believes that the proper way to accomplish these goals is through legislative action in the traditional sense-development of a bill which is subjected to public hearings in the appropriate committees, markup, reporting, and floor action. It appears from reading S. 2479 and S. 2035 that a potentially dangerous mechanism is established whereby the Congress is not given sufficient opportunity to assess the proposed consolidations in proper legislative style. In other words, the language of the proposed legislation would place undue power in the executive branch and strip the Congress of absolutely vital prerogatives. As a matter of fact, we understand from press reports that Comptroller Staats said to your Committee that there would be less need for the joint funding provision of S. 2479 if Congress consolidated programs into broader categories of assistance and placed similar programs in a single agency. We could hardly agree any more, and marvel that such a statement would be made by an Administration official. With regard to fiscal reporting, we believe that adequate procedures already exist. Some may be cumbersome and need improvement, but giving the Government Accounting Office and/or the Bureau of the Budget broad powers to regulate reporting procedures strikes us as dangerous. Here again, the proposal has the effect of weakening the powers of Congress. Oversight of federally-assisted programs does not require the presence of federal officials looking over the shoulders of state governments. The proper forum for oversight is the Congressional hearing room where federal, state, and local officials may argue their cases. As a general final conclusion, I would say that the laudable objective of simplifying and coordinating federal programs must not be done in such a way as to invite the expansion of executive powers which NEA feels are much too broad already. Sincerely, JOHN M. LUMLEY, Assistant Executive Secretary, Legislation and Federal Relations. NATIONAL ASSOCIATION OF HOUSING AND REDEVELOPMENT OFFICIALS, September 24, 1969. Hon. EDMUND S. MUSKIE, Chairman, Intergovernmental Relations Subcommittee, Committee on Government Operations, Old Senate Office Building, Washington, D.C. DEAR SENATOR MUSKIE: We would like to present our views on S. 2479 ("Intergovernmental Cooperation Act of 1969") and S. 2035 ("Grant Consolidation Act of 1969"). We hope that the following comments will be helpful to you and to the Committee in your deliberations on these important matters. We respectfully request that they be filed for your hearing record. We have two recommendations on proposed additions to the pending legislation, outlined below, that we hope will have your serious attention. As the organization of 7,000 local officials with responsibilities for the dayto-day administration of federal grant-in-aid programs in the housing and community development field, NAHRO is acutely aware of the need to provide for a more orderly, effective grant-in-aid process. The multiplicity of programs involved in the solution of urban problems and the growing complexity of interrelationships between these programs result in a loss of energy and resources; it also can result in major frustrations and time delays. We support S. 2035 and Title III of S. 2479 as practical approaches at the federal level to move toward consolidation of these programs that are closely allied in both function and clientele, opening the way to a streamlining of effort by local agencies seeking assistance. We support these consolidation approaches with the knowledge that there will be some loss of program identification; perhaps most seriously, a difficulty in gaining public understanding of more complex and comprehensive program designations. It is simpler to explain the objectives of more narrowly-defined categorical programs, i.e., a program to eliminate rats vs. a comprehensive program of neighborhood improvement. However, we believe that the ultimate gains in more effective administration can outweigh any loss of individual program identification. We support joint funding simplification (Title IV of S. 2479) as an important first step in developing joint applications for those programs that are closely related and must be developed together. We particularly recommend the "demonstration approach" to joint applications involving more than one federal agency or department. At the same time, we agree with the view of the Under Secretary of Housing and Urban Development that there is much to be done in program coordination within agencies and departments. This intra-agency coordination should be the priority area for attention, as a preparation for coordination or consolidation between departments. RECOMMENDATIONS BY LOCAL AGENCIES NAHRO would like to make one recommendation in regard to the provisions of the two bills as they are now drawn. Recommendation No. 1 We would like to see a strengthening of the intent, and delineation of the procedures, by which local agencies that are the recipients of grant-in-aid funds can be provided with an opportunity to present their views to Congressional committees regarding proposed consolidations, as well as studies of programs by substantive committees called for under Title V (Sections 501 and 502) of S. 2479. We would suggest that an adaptation of the language of Section 502 (Reports of Federal Agencies-Item 2) might be appropriately added to the sections on consolidation procedures and program review procedures involving congressional committees. (Federal reports shall describe . . . "the consultant procedures employed under each program to afford recipient jurisdiction an opportunity to review and comment on proposed new administrative regulations and basic program changes".) LOCAL MANAGEMENT AND COORDINATION In addition, while the proposed legislation will have a number of beneficial effects in assisting local communities to develop more effective programs, it is basically drawn with the federal organization in mind. As you know, NAHRO has been a firm advocate of more responsibility and initiative at the local level as a prime requisite in elimination of unnecessary red-tape and in speeding urban improvement. In our strong testimony on this subject of last year, (copy enclosed for your record) we asked for a Congressional reaffirmation of the principle of local responsibility and initiative; as well as affirmative moves by the federal agencies to eliminate unnecessary review and red-tape. We are pleased that an amendment to this effect became Section 5 of the Housing and Urban Development Act of 1968. While time has not been sufficient to judge the full impact of ths provision, we know that this subcommittee will be following progress on this matter with great interest. Recommendation No. 2 It is NAHRO's view that effective programs ultimately depend on local management and coordination. We believe that the present bill might well be supplemented, to provide for a limited number of demonstrations in localities of a "block grant" approach to federal aid covering programs administered under one department or agency. We would envision such demonstrations, under the Department of Housing and Urban Development, as providing a total "community development fund" for specified housing and urban development purposes, administered with a minimum of procedures, but subject to a federal post-audit. We believe that a major testing of this approach could well lead to a simplification of the entire federal grant-in-aid process. We recommend it for your serious consideration as a supplement to the pending legislation. If we can supplement our views in any way, please let us know. Sincerely, [Enclosure.] WILLIAM L. RAFSKY, President. LOCAL INITIATIVE, RESPONSIBILITY NAHRO TESTIMONY BEFORE THE SENATE SUBCOMMITTEE ON INTERGOVERNMENTAL RELATIONS, MAY 14, 1968 (S. 698 AND S. 2981) NAHRO sees the need for a new concept and mechanism that will make local initiative and responsibility truly possible, and asks for joint deliberations by the Association, the Department of HUD, and the Congress to develop such a new approach. In the meantime, it specifically requests the Congress to reaffirm the principle of local initiative and responsibility. My full statement is perhaps the most detailed public response NAHRO has ever made to a housing and urban development bill. We are firmly in support of the proposed Housing and Urban Development Act of 1968. Yet, at the specific direction of the NAHRO Board of Governors, which met in Washington just two weeks ago, I must express to you our belief that none of this promising activity can be effectively moved forward unless there is a new understanding about the placing of initiative and responsibility at the local level. Over the past year, the members of our Association have been increasingly concerned about the number of important national policies and procedures relating to our programs that have been issued without prior opportunity for local officials to make suggestions and comments. These omissions have covered a wide range of issues, including the "urban goals" policy; property management and land negotiation procedures in the urban renewal program; and the site selection, tenant assignment, and priority production procedures in the public housing program. This matter is of such serious concern that our Program Policy Resolution for 1967-69, adopted by the full membership of our Association last October, expressed "... dismay and frustration . . . over the fact that a full measure of responsibility is not vested in local agencies . . ." and suggested that a first order of business for HUD should be ". . . the granting to local communities of a full measure of initiative and responsibility, in accordance with the declaration of purpose of the Housing Act of 1959." NAHRO recognizes that there are important, critical matters related to national policy that are the proper concern of the Department of Housing and Urban Development at the federal level. But the full impact of national policy decisions can only be measured accurately at the local level. The difficulty concerns no individuals or officials at either the federal or local level-the fault lies in the present method under which national and local goals are established, and the inadequate mechanism that we now use to join them in a common program effort. The present system of detailed federal reviews of local operations breeds delays and frustrations. We need a new concept and a new mechanism that will make local initiative and responsibility truly possible, while recognizing the proper interest of federal government in program goals and the allocation of national resources. Mr. Chairman, NAHRO realizes that it has an important responsibility in making recommendations that will help to establish the new concept and mechanism for the federal-local relationship. We are presently preparing a report that defines more fully our concept of local housing and urban development goals and a balanced local community development program. We hope we will have an opportunity to present this report to the Congress, as well as to undertake intensive discussions with the Department of HUD. In the meantime, we specifically request that the subcommittee include in its report a reaffirmation of the principle of local initiative and responsibility. STATEMENT OF THE NATIONAL ASSOCIATION OF MANUFACTURERS The National Association of Manufacturers appreciates this opportunity to present its views on S. 60, the Program Information Act, S. 2035, the Grant Consolidation Act of 1969, and S. 2479, the Intergovernmental Cooperation Act of 1969. We support the principles embodied in these measures and have some specific comments on the proposed legislation, particularly on S. 2035 and S. 2479. The Association has a long history of interest in intergovernmental relations and in the administration of federal grants-in-aid. We have testified or commented regularly on these topics since 1957, and have subjected our policies in this area to periodic review. Just as we find the process of review valuable for our own policy determinations, for about a decade one of our key recommendations to Congress was for the periodic review of federal grants-in-aid. That was finally achieved in P.L. 90-577, the Intergovernmental Cooperation Act of 1968. Now, it is a source of gratification that the Administration and the Congress have turned so soon to some of the unfinished business of that Act. We also have supported renewal of the Reorganization Act (based on the proposals of the first Hoover Commission) which delegates to the President the authority to reorganize the Executive Branch agencies subject to the approval of Congress. Use of this device to improve the administration of the grants-in-aid system offers most interesting possibilities. Purpose of the legislation When your Chairman, Senator Muskie, introduced S. 2479, he pointed to the need to reduce to a more manageable number the more than 420 categorical grants. During the 90th Congress alone, 42 broad grant programs-involving more than that many authorizations-were enacted. Referring to the series of studies made by this Subcommittee, he commented on the ample evidence you have gathered indicating that public officials at all levels are acutely aware of the adverse consequences produced by the "profusion and excessive fragmentation" of Federal assistance programs. One of those adverse consequences-the "information gap"-is the specific target of S. 60. The same theme of the acute problems arising from grant-in-aid proliferation was dominant in President Nixon's message to the Congress of April 30th last, in which he urged enactment of a Grant Consolidation Act. There is apparently general agreement, then, on the purpose of this legislation. S. 2035 states (Section 1001) that the President's determinations are to be made 34-851-69-18 |
