The "New Federalism" and Federal Transportation Policy Author(s): Herman Mertins, Jr.

Reviewed work(s): Source: Public Administration Review, Vol. 33, No. 3 (May - Jun., 1973), pp. 243-252 Published by: Blackwell Publishing on behalf of the American Society for Public Administration Stable URL: http://www.jstor.org/stable/974802 . Accessed: 22/04/2012 15:27
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THE "NEW FEDERALISM" AND FEDERAL TRANSPORTATION POLICY

Herman Mertins, Jr., West Virginia University The character of federal transportation policy making is undergoing a significant transformation. To some, the current period reflects little more than uncertainty and hesitancy about the roles that federal leadership should play, or not play, in responding to the enormous challenges of providing for national mobility in all of its forms. But the currents of change run far deeper than the surface waters indicate. Indeed, what appears to be taking place represents a fundamental reorientation of the Executive Branch. The specific form is the application of the "New Federalism"-with its emphasis on decentralized responsibility and power-to transportation policy making. Present ferment is not without its disturbing contradictions and unanticipated consequences. These range from the problems produced by specific outputs of applied policy, which are experienced at state and local levels, to the growing number of dilemmas faced by top-level organizational entities, which play vital parts in evolving the substance of national transportation policies. But this is not to imply that the fruits of change within the federal establishment can be assessed meaningfully by focusing solely on the impacts of applying a different "philosophy of government." For while these transpire, the policy environment of planning for transportation continues its own metamorphosis. New and modified patterns of need and response, encompassing both the public and private sectors, are constantly generated. Transportation policy making involves highly complex, interactive processes. Even if no conscious policy framework exists at the federal level, planning for transportation adjusts and evolves in some form or other. The functions of transportation are that fundamental. This article will examine the interaction of the New Federalism with several major features of transportation policy making, as well as with policy areas impacting directly on transportation policy. No pretenses are made to suggest that facets discussed constitute the bulk of important variables now influencing federal policy activities. In fact, most of the article's attention will be devoted to one major aspect of emerging changes-that which affects the movement of passengers in ground transportation. Even here, treatment of interactions must be oversimplified. Of the elements of federal transportation policy making being influenced by the New Federalism, the following appear most prominent: (1) the policy setting, including the Executive structure most responsible for evolving policy; (2) present federal financial aids for transportation; (3) the impact of impoundments as they have been applied to transportation; (4) plans for new financing schemes, particularly general and special revenue sharing; (5) national policies, or the lack of such policies, governing environment, energy, and land use; and (6) proposals for Executive Branch reorganization. In practice, these factors defy indivisibility; they perform as highly interactive elements in a much more elaborated network. The Policy Setting In its earliest period, federal transportation inputs were made on an ad hoc basis with little attention to interrelationships among modes of transportation. The overriding drive was to encourage development of all facilities of transportation. Growth in capacity-whatever its form-was considered a "good." Another early concern involved the cost of transportation; this encouraged developments which would provide "ready substitutes" for the various modes. Matching these piecemeal actions was the fragmented nature of the federal organization concerned with transportation policy making. In fact, it was not until the mid-1960s that the Department of Transportation was established.2 The Department thus inherited a legacy of transportation development within individual modes; each occupied a unique "policy compartment." The spirit of the legislation and hearings surrounding creation of DOT was that it would

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function as a "holding company" for most of the components of federal structure concerned with transportation. Transportation development was viewed primarily as a functional policy goal to be pursued on its own merits, rather than as a facilitator or ingredient in processes designed to serve other ends. In this way, DOT assumed the posture of providing "one roof" under which the Executive Branch could coordinate and consolidate the fragmented pieces of "national transportation policy." One further point concerning the Department of Transportation deserves explication - the matter of leadership and initiative. In spite of the restrictions placed by Congress on the freedom of action of the Secretary of Transportation, so encornpassing was its legislative charge that opportunities for exercising initiatives proved numerous.3

As the first Secretary of DOT noted, up to then the national transportation system was left with a minimum of interference by government; competition was depended on to resolve conflicts. But the new DOT created, for the first time, a centralized mechanism for national transportation planning. And this capacity intensified as planning gained renewed respectability in the late 1960s. In a number of ways, growth of the reputation of DOT initiatives was enhanced during the first Nixon Administration under the leadership of John A. Volpe. However, a new brand of policy yeast in the transportation "cake"-New Federalism-now signals a sharp turn, even reversal, in direction. Specifically, it espouses return of policy initiatives to state and local governments, the "grass roots." Nor is this change in emphasis simply a matter of rhetoric. As will be discussed shortly, the programmatic contents of virtually all major planning and funding programs, as well as federal organizations with transportation policy-making capacities, stand to be substantially reoriented. Federal Funding for Transportation - The Changing Scene Certainly the most critical elements of federal transportation policy making are the level, and character, of federal financial support. One aspect of the total financial picture illustrating the nature of emerging federal policy making, particularly as it begins to take on the imprint of the New Federalism, is aid devoted to urban transportation.

Significant federal involvement in dealing with urban transportation problems is relatively recent. It started in a limited way with the Housing Act of 1961 which initially authorized $50 million for federal loans to be used to acquire and improve mass transportation facilities in urban areas and $25 million for transit demonstration grants. But perhaps the greatest single impetus for reorienting federal policy toward more direct, meaningful involvement was the Transportation Message of President John F. Kennedy, delivered in 1962.4 It paved the way for subsequent legislation by outlining the needs for continuing demonstration grants, comprehensive planning in urban areas (as a qualification for receiving aid), and other programs. One of the products of the Kennedy approach was the Urban Mass Transportation Act of 1964; it has served as the primary instrument for rendering such federal assistance since its passage. The Act initially authorized a $375 million program. Recent Approaches The year 1970 witnessed the emergence of a more sweeping approach to urban transportation problems in the form of the Urban Mass Transportation Assistance Act.5 Developed within the Nixon Administration by DOT, the Act was to provide for a federal program of assistance that was to amount to $10 billion over a 12-year period. Further, it authorized the incurrence of obligations amounting to $3.1 billion in the first five years. Assessed in terms of their responsiveness to national urban needs, these programs appear more significant in intent than commitment. This appears most obvious in capital grant activity which has as its objectives: (1) Providing mobility for urban residents who cannot use autos. (2) Improving peak hour travel in urban regions. (3) Achieving land use patterns and environmental conditions that enhance urban living. The record of performance from February 1965 up to 1972 shows that federal funding provided through the Urban Mass Transportation Administration totaled a little over $1 billion for 279 projects.6 Why this relatively low level of performance, given the magnitude of the problems extant? Several factors account for the situation. First,

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except for the last two fiscal years, the level of requests for funding in both the Johnson and Nixon Administrations was limited. Second, Congress has been wary of committing substantial resources, a reaction closely related to the amorphous nature of the clientele to be servednarrowly conceived as the users of urban transportation-not the entire urban population. As a consequence, requested levels of funding authorization have been consistently and substantially reduced. Third, UMTA has encountered continuing problems in allocating authorized funds. These have been blamed on delays in securing final budgetary authorizations and in qualifying applicant projects. Fourth, until very recently no effective mass transportation lobby existed that could wield sufficient political clout, in comparison to that fielded by the "established" modes of transportation. And most recently affecting the flow of assistance has been the practice of impounding funds. Impounded Funds The interaction of anti-inflation measures, the goals of the New Federalism, and the capacity of federal policy making to be responsive to national transportation needs is well illustrated by the results of impounding funds authorized for mass transportation purposes. This practice was initiated by the Executive Office of the President and was first applied to transportation expenditures. In fiscal 1971, Congress authorized UMTA to obligate $600 million. Subsequently, the Office of Management and Budget limited the amount that could be utilized to a level of $400 million. Of this amount, only $283.7 million was ultimately designated for capital grants. The balance was consumed by UMTA expenses, including R & D and administrative costs.7 Thus, fiscal 1971, which started out as a "good" year for mass transportation, concluded by looking very much like its predecessors. Expenditure levels for fiscal 1972 encountered a similar fate. Congress authorized a limit of $900 million; OMB subsequently limited obligations to $600 million and $510 million was ultimately spent. Yet unclear is what will happen in fiscal 1973. It is estimated that $863.7 million will be spent. If such occurs, effects of impoundments in the previous two years may be eased somewhat, but they cannot be erased. Executive impoundments of funds are not new;

they have been employed for a variety of reasons over the years. Standing in back of such practices are the provisions of the Anti-Deficiency Act8 that provide for temporary deferrals and control of funds in excess of immediate needs, awaiting congressional action affecting their use, or held in accordance with congressional action. However, the nature of current practices differs from the past. Its rationale rests on the desire to control the level of total federal spending, not on the basis of limiting expenditures because of programs that have encountered technological, administrative, or implementation problems. Current impoundment practices are not without their defenders. Even DOT pronouncements have provided ready explanations for the policies adopted. The following is typical: ... It is notconsideredas being "withheld"because its planned use is consistentwith congressionalintent. The Congress provided a total of $3.1 billion of contract authority for the 5-year period 1971-1975. Executive branch apportionmentswill result in $1 billion of this amount having been used by June 30, 1972, for fiscal 1973, leaving $1.1 billion, or $550 million per year for fiscalyears 1974 and 1975.9 Questions about Impoundments Why have these practices been employed to govern allocation of funding or capital grants for urban mass transportation projects? Why has up to one-third of the available grant money been impounded? It could well be that the Administration has serious reservations about the efficacy of the program. It is difficult to tell. No specific basis has been established to justify withholding of federal expenditures for urban mass transportation. One clue may be the backlog of capital projects awaiting federal matching funds in urban mass transportation. It is staggering-and growing continuously. Indeed, as of this writing, UMTA had over $4 billion of such applications pending. What bases should be used to decide upon the allocation of limited funds? Indeed, in view of the spirit of the New Federalism, the Administration might have concluded that specific decisions of this nature should not be made in Washington and, therefore, have decided to slow the process. Such would then build further pressure for revenue sharing, an approach much more compatible with New Federalism. Whatever the case, the annual testimony rendered by DOT officials in support of capital grants

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creates some anomalies. These appear replete with elaborate justifications for authorizing agency funding at levels that, almost without exception, exceed those finally approved by Congress. Virtually all programs recommended fall into the category of "vitally needed." Yet when the matter of budgetary performance is evaluated, one might conclude that numerous new activities, or extensions of existing programs, apparently are not so "vital" after all. On the surface, at least, the withholding of one-third of UMTA capital grants reflects a lack of federal commitment to continuing past funding practices.l But that should not be interpreted as a lack of concern about the need for governmental action. The more basic question may be which government should decide and act. Under New Federalism, the expected answer would be "state and local." The Issue of Operating Subsidies Also intimately involved with the impact of New Federalism is the growing concern about the need for operating subsidies for mass transportation. The year 1972 produced a growing tide of pressure for such federal assistance which took form in the proposed Housing and Urban Development Act of 1972. Chapter 6 of the bill included authority for DOT to provide $400 million per year to assist in maintaining urban transport services. Further, under its proposed capital grant program, requirements for local matching grants would have decreased from one-third to 10 per cent.1 These provisions ultimately failed to survive in the House. Similar measures included in the 1972 Federal-Aid Highway Act also failed of enactment when the entire piece of legislation died at the close of the 92nd Congress. How has the Nixon Administration responded to these suggested approaches? Clearly, operating subsidies are most controversial because of the inherent magnitude of funding involved. But just as much of an issue is the problem of determining state and local vs. federal responsibilities. Here, again, the point of contention is not only financial but philosophical. On the financial side, analyses conducted by DOT concede that there is a "severe problem," that the federal government has some responsibility to help solve it, and that past policies have probably contributed to making it as bad as it is.

One general conclusion reached is that all major urban transit systems are faced with a selfdefeating cycle of increasing costs, spiraling fares, and a huge drop in ridership.12 All lead to a decrease in service which, in turn, perpetuates and intensifies the process. Paradoxically, in spite of the implications of this cycle, there is general agreement that mass transit systems must not be allowed to go out of existence because of the drastic effects this would have on the remainder of the transportation system. Nevertheless, this raises the question about whether operating subsidies treat the symptom or the cause. Then there is the philosophical side of the question. If the New Federalism is to become a reality, what mechanisms should be utilized to transfer not only the power of decision making back to those governmental units closest to the problems but also resources as well? State and local governments already allocate more than $400 million annually for transit operating assistance. Aside from these problems, operating subsidies present other difficulties. Foremost is the challenge of designing an incentive system that would lead to improved service and more efficient operations. How could the allocation of subsidies be effectively controlled so as not simply to intensify demands for higher wages for transit workers? How could increased use of off-peak capacities be related to incentives? How could varying requirements for subsidies be equitably resolved? How could subsidies be allocated effectively between public and private mass transit carriers, particularly in areas in which they compete for ridership?13 It has been proposed that operating subsidies be provided on the basis of passengers carried at, for example, eight cents per trip. But this incentive system, as all others conjured up so far, presents serious problems. In this case, the subsidy would rise as the level of utilization and, presumably, efficiency rose. This would mean that the amount of subsidy would increase when, if anything, the need for it decreased. On the other hand, those operations in difficulty because of decreased ridership would receive less of a subsidy. In some respects, this would be counter to the normal rationale for determining subsidy needs and justifying their continuation. A Single Urban Fund? Another facet of the evolving approaches that could affect both the character and composition

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of urban transportation financing and, consequently, the policy-making framework, is the DOT proposal to establish a single urban fund. This concept grew out of the 1972 Highway Needs Reportl4 and reflects a basic component of the New Federalism-discretionary use of the funds exercised by state and local officials rather than federal authorities. Under its provisions, choices on the allocation of funds between highway and mass transit needs would be made on a decentralized basis. If the proposal were adopted, a single urban fund would be authorized at $1 billion in fiscal 1974 and $1.85 billion in fiscal 1975. Such monies would become available for use on any public capital transportation project. Forty per cent of the fund would be distributed to the nation's standard metropolitan statistical areas on the basis of their share of the total national SMSA population. A second 40 per cent would be allocated to the states on the basis of their share of the national SMSA population. The remaining 20 per cent would be retained for discretionary use by the Secretary of DOT. All funds would be allocated on a 70 per cent federal and 30 per cent state and local matching basis. s One of the primary goals of the proposal would be to force the 268 major urban areas to develop organizational and administrative mechanisms to deal with their total transportation problem on a coordinated basis. This strategy recognizes that most metropolitan areas now lack such consortia. The consortia to be formed would be structured to assure proportional representation, to prepare long-range comprehensive plans, and to take responsibility for the administration of programs. The nature of this proposal again is consistent with other aspects of federal transportation policy now evolving. The aim is to shift responsibilities for initiatives in urban mass transportation away from Washington and to the "scene of action." Impacts of Revenue Sharing Of all the financing measures introduced by the Nixon Administration, revenue sharing represents the most fundamental and sweeping departure from past policies. It would drastically alter the character of federal influence in transportation policy making. Indeed, the impact of "General Revenue Sharing" is already being felt. Under this program,l6 funds amounting to about $30 billion are to be shared with state and local governments over

a five-year period. Made available with few stipulations, some of the money has already been used by localities to bolster existing transit systems. In these circumstances, transportation funding has been placed in the position of competing for priority consideration against other pressing state and local needs. Still pending before Congress is the "Special Revenue Sharing Program For Transportation."17 It was first proposed by President Nixon in March of 1971; this program would be distilled from 23 existing federal grant-in-aid programs in urban mass transit, airport grants, highway construction, safety, and beautification. Funding to support the allocation structure would be drawn from general revenues, the Highway Trust Fund, and the Airport and Airway Trust Fund. The initial annual level of funding would be $2.6 billion. The avowed purpose of the program is to shift downward the focus of transportation policy making. Of course, an important by-product would also be the passing down of the "hassles" that surround mobilization and allocation of federal funds for transportation purposes. Many questions surround the efficacy of the revenue sharing approach. As Congressman John J. McFall has noted, it appears to be a simple answer to a complex problem.18 And he questions the capacity of the states, without direction, to national policy without federal implement leadership. There is also the question of how needs for future development of existing and emerging national systems-highways, aviation, rail, high speed ground transportation-can be met by state and local officials. In addition, concern exists about advancement of the states-of-the-art in transportation. How will advanced technology be fostered and applied under these circumstances? Are traditional political jurisdictions-states, urban areas, counties, towns-capable of dealing with the complexities of transportation policy making in an age characterized by intertwined, interlocked dependencies and relationships? All of these concerns must be traded off against the potential advantages of encouraging decentralization of policy making. Other Interlocking Policy Concerns Closely associated with the content of federal transportation policy making, and often integral

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parts of it, are plans and programs to govern management of the environment, provide for energy needs, and determine land use. Each of these will be analyzed briefly in terms of implications of the New Federalism and their interfaces with transportation policy. Environmental Policy In general terms, the relationships of environment to transportation have been provided for within the federal transportation policy framework. In DOT, the position of Assistant Secretary for Environment and Urban Systems was established in fiscal 1969 to deal with the problem of achieving a balance between human values and engineering values in the development of transportation systems. Both under the provisions of the Transportation Act of 1966 and the National Environmental Act of 1969, measures have been taken to safeguard parks, recreational facilities and other public lands, public water supplies, urban and rural aesthetics, historical sites, and the like. All projects subject to NEPA must be accompanied by an environmental impact statement. Indeed, numerous projects have been stopped or modified, even retroactively, in the past three years. Energy Policy Unlike the approach taken to deal with environmental problems related to transportation, little has been accomplished to cope with the implications of the "energy crisis" as it affects federal transportation policy making. In part, this is explained by the lack of federal commitment to national planning for energy needs. The result has been a piecemeal focus on the narrow band of needs that affect the immediate future. 19 Within DOT, research has been undertaken on obtaining new sources of petroleum, increasing efficiency of its use, and developing new power sources. However, one senses neither a mood of urgency nor commitment of substantial resources to these endeavors. This, in spite of the fact that national transportation is 98 per cent highway dominated and, therefore, petroleum dominated. Will such systems be able to perform under the conditions and constraints of 1990 and beyond? Can such questions be coped with by state and local government? Land Use Policy The development of a national land use policy

still awaits formulation and implementation sometime far into the future. Indeed, the needs for such policy are only dimly perceived. The most recent, proposed legislation to give serious attention to the problem was the Land Use Policy and Assistance Act of 1972. This legislation was not adopted by Congress. It would have stimulated the first significant federal involvement in land use regulation, emphasizing state programs for areas of critical environmental concern, key facilities, regional and large-scale developments, and coastal zones. According to federal projections, the land use challenges to be met are overwhelming. These include needs to build as many homes, schools, hospitals, and other public facilities before the year 2000 as were built in the past 300 years. The vastness of this problem of appreciating the interaction of transportation policy and land use policy has been recognized, at least in one respect. In a statement submitted to Congress in 1972, DOT called for a redefinition of the role of transportation, particularly in urban areas. It noted that transportation should be viewed as a subsystem within an overall urban system of interrelated parts.20 The suggested DOT strategy called for rational definitions of broad community goals. From these would stem the suggested means for governing orderly growth and the respective roles that the modes of transportation might perform in accomplishing them. Most significant in these pronouncements, as they suggest the silhouettes of future policy, is the view that the substantial responsibility for determining future national land use patterns ought to be lodged with the states and local governments. Again, the dominant theme of the New Federalism is decentralized prerogatives. But one must ask: Are these sufficient? Organizational Change and Federal Policy As part of his State of the Union Message of January 22, 1971, President Nixon called for a sweeping reform of the federal Executive structure, including those elements charged with the responsibility for formulating and implementing federal transportation policies. As Figure 1 demonstrates, one of its effects, if enacted, would be to eliminate the existing Department of Transportation. Of the numerous changes involved, the most significant would be the shearing away of federal highway programs and urban mass transportation MAY/JUNE 1973

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programs, which would be located in the Department of Community Development, from the balance of existing transportation programs, which would shift to the Department of Economic Affairs. While the organizational implications are important, the underlying philosophy is even more so. Essentially, the change would result in approaching the planning of highways and mass transportation not in terms of national sub-systems of transportation but rather as integral parts of community, or local, planning.21 Thus, transportation, as a function, would no longer be considered a viable organizing concept. Numerous concerns have been voiced about the proposal; however, a thorough review of them is beyond the scope of this article. Only several related to transportation policy making can be touched upon here. First, the proposed reshuffling of transportation responsibilities would occur just when DOT, created in 1966, was reaching a reasonable degree of efficiency. In effect, the case for changes that would "put like functions under one roof" follows within only a few years a similar rationale used in the strong case made to create DOT.22 A related point is that the reorganization would once again relocate UMTA; the agency moved from HUD to DOT only four years ago. A second objection centers on its impact on achieving coordinated systems of transportation. How would the new organizations cope with national intermodal planning? A third objection notes that about 80 per cent of the federal-aid highway mileage lies outside of towns and cities and that the programs are predominantly national in impact. It asks: How could such systems be planned and controlled effectively if state and local prerogatives predominate? A fourth objection relates to the organizing concept of the Department of Community Development, particularly its amorphous character. Would not any federal program qualify for inclusion, since all have some direct or indirect bearing on community development? While prospects for approval of this proposal for reorganization appear dim, its contents remain important to understanding emerging emphases of federal transportation policy making. As noted in the analyses of other factors interacting with and reshaping federal transportation policy making, the plan represents yet another of the concerted steps taken to reorient

the federal role in transportation policy making. It reflects the movement toward increasing state and local prerogatives in the planning process, setting goals and relative priorities, and securing and determining the disposition of federal funding. Assertiveness and leadership in federal transportation policy making are being systematically de-emphasized. In their place, roles emphasizing technical assistance, facilitation, and low-key influence appear to be emerging. The nature of the New Federalism is not necessarily to withdraw from the many battles of forging viable policies; however, movement of the federal forces out of the "front lines" has become increasingly evident. The question remains whether other governmental jurisdictions will have the human, financial, and technical capacities, as well as the political courage, to cope successfully with the challenges now being shifted to them. An equally basic question is whether successful approaches to national transportation problems can be formulated by the individual or confederated actions of state and local government.

Concluding Comments As this brief examination of federal transportation policy making concludes, I should note that the definition of a comprehensive national transportation policy has been an elusive goal pursued by both the Executive Branch and Congress over the past five decades. The present Administration, following past practice, has avoided formulating such a policy statement, although voluminous data bearing on it have been collected. Of course, the real possibility exists that such a policy statement is not desired. Certainly the formality of a plan or compendium of guides is not a prerequisite of policy. Future federal transportation policy may well continue to eschew formal statements and elaborations in favor of specific actions within substantive program fields. Moreover, during the remainder of the Nixon Administration, policy'will probably be elaborated in terms of the desires and requirements of state and local governments. This would represent the New Federalism in action. Presumably, the strategy would be to somehow amalgamate these into a coherent national tapestry. If such indeed becomes the goal, it remains to be seen how the design is chosen and who performs the weaving. MAY/JUNE 1973

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Notes 1. Herman Mertins, Jr., National Transportation Policy in Transition (Lexington, Mass.: D.C. Heath and Company, 1972), pp. 3-20. 2. Ibid., pp. 77-103. 3. Ibid., pp. 91-103. 4. "The Transportation System of Our Nation," Message from the President of the United States, House of Representatives, Document No. 384, 87th Congress, 2nd Session, April 5, 1962. 5. Public Law 91-453. 6. Department of Transportation and Related Agencies Appropriations for 1973, Hearings Before a Subcommittee of the Committee on Appropriations, House of Representatives, 92nd Congress, 2nd Session, Part 2 (Washington, D.C.: U.S. Government Printing Office, 1972), pp. 751-752. 7. Urban Mass Transportation, Hearing Before the Subcommittee on Housing of the Committee on Banking and Currency, House of Representatives, 92nd Congress, 2nd Session (Washington, D.C.: U.S. Government Printing Office, February 23, 1972), p. 44. 8. 31 U.S. Code 665. 9. Department of Transportation and Related Appropriations for 1973, op. cit., Part 1, pp. 74-75. 10. The one-third cutback is also justified by the Nixon Administration on the grounds that even though "reserve limits" have been imposed, the amount of federal spending devoted to capital grants is greater than ever before. See the testimony of then Secretary of Transportation John A. Volpe, ibid., p. 72. Mertins,op. cit., p. 170. Urban Mass Transportation, op. cit., p. 79. Department of Transportation and Related Appropriations for 1973, op. cit., Part 2, pp. 613-614; Part 3, pp. 12-13. 1972 National Highway Needs Report, Federal Highway Administration, U.S. Department of Transportation (Washington, D.C., March 1972). Department of Transportation and Related Appropriations for 1973, op. cit., Part 2, pp. 647-648. The program was established by Public Law 92-000. "Revenue Sharing for Transportation," Message from the President of the United States, House of Representatives, Document No. 71, 92nd Congress, 1st Session, March 18, 1971. Department of Transportation and Related Appropriations for 1973, op. cit., Part 3, p. 277. Ibid., p. 11. Ibid., p. 115. Department of Community Development Act, Report of the Committee on Government Operations, No. 92-1096, House of Representatives, 92nd Congress, 2nd Session (Washington, D.C.: U.S. Government Printing Office, May 25, 1972), pp. 2-65. Mertins, op. cit., pp. 77-80.

11. 12. 13.

14.

15. 16. 17.

18. 19. 20. 21.

22.

Available from a
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MAY/JUNE 1973