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including the Model Cities program, neighborhood health centers, and other Leighborhood services. The Department is coordinating its efforts with other Federal agencies to assure that the planning and service programs in the Partnership for Health contribute to meeting national health needs as identified through comprehensive State and local planning.

In summary, it is our judgment that the experience we have had with the Partnership for Health authority-formula and project grants-appears to be highly effective and, we believe, holds great promise for the strengthening of State and Federal relations and for the improvement of the Nation's health.

A second step we are proposing to reduce the number of grant programs in the Department is the Administration's 1968 proposals now under Congressional review for amending the Higher Education Act to include the modification and consolidation of the college-based student financial aid programs into the Educational Opportunity Act. Under these proposals there would be a single appropriation item for Federal capital for the National Defense Student Loan fund and the College Work-Study Program, with a 90-10 Federal institutional matching ratio, and a single appropriation for the Educational Opportunity Grant Program which would not require program matching funds. The fund distribution pattern would be altered from the three separate allotment formulas, which differ, to one not tied to a specific formula, subject only to the limitation that institutions within any one State could not receive more than 12% percent of available funds.

This proposal, if enacted, would give institutions much greater flexibility in the use of the student aid programs and would eliminate unnecessary diversity among the requirements of the programs. Moreover, the advance funding and leadtime amendments proposed in our bill would provide the Nation's colleges and universities with a firm, operating base for planning their programs. Title II of the Partnership for Learning and Earning Act of 1968 deals with the consolidation and improvement of existing vocational education programs. The proposed legislation would consolidate existing authority for vocational education programs under the Smith-Hughes and George-Barden Acts, and Vocational Education Act of 1963. The consolidation is proposed in response to the first recommendation of the 1968 Advisory Council on Vocational Education which stated, "Administrative complexities should be reduced by combining all vocational education legislation into one act."

Another significant provision of the Partnership for Learning and Earning Act of 1968 is the removal of the requirement for separate matching purpose-bypurpose under the Vocational Education Act of 1963. The bill would provide instead for overall statewide matching which would allow more flexibility in that varying proportions of Federal funds could be used in matching State and local funds.

Under present law, (The Smith-Hughes Act, the George-Barden Act, and the Vocational Education Act of 1963) 23 purposes are specified, each requiring separate accounting and matching. In addition, within those 23 categories, there are State percentage expenditure requirements for three of the six purposes in section 4(a) of the Vocational Education Act of 1963. These would be abolished. Finally, we should like to refer again to S. 2981, the "Joint Funding Simplification Act of 1968". This bill would provide for procedures which would expedite consideration and approval of projects drawing upon more than one Federal assistance program and would simplify requirements for the operation of those projects. We believe that S. 2981 will make a significant contribution to the improvement and simplification of our grant mechanism, and that S. 2981 is a more appropriate vehicle than title VI of S. 698 for administrative consolidations for the purpose of improving the use of Federal assistance by States, local governments, and other public and private organizations and agencies.

TITLE VII

This title would amend the Federal Property and Administrative Services Act of 1949 by adding a new title VIII, Urban Land Utilization. The Department of Health. Education, and Welfare agrees with the objective of this title, which is to facilitate coordination between the Federal Government and local governments and planning bodies (including zoning authorities), in the acquisition, use, and disposition of land for Federal purposes. However, on the method and details of this title, we defer to the Administrator of General Services to whom the primary responsibility would be assigned by this title.

TITLE VIII

Title VIII would provide for relocation payments and other assistance to displaced persons (defined, in section 113, to include owners of businesses, farmers, families, and others), on a uniform basis, in Federal and Federally-assisted programs under which real property is acquired. In the case of direct Federal acquisition of real property for public use (part A of Title VIII), section 802 would require heads of Federal agencies to make fair and reasonable payments, pursuant to regulations established by the President, to reimburse displaced persons for their actual moving and related expenses or, if any displaced person so elects, to make optional fixed payments to such person according to a formula. Relocation assistance programs (i.e), counseling, information, planning, and coordinating activities) would also be made available. While we endorse the objectives of this part, on its details we defer to other agencies which would be more directly involved in the detailed program features.

With respect to Federally-assisted programs (part B), section 807 would require, as a condition to the approval of any grant, contract, or agreement with a State agency for Federal financial assistance to pay the cost in connection with the acquisition of real property, or of a public improvement for which real property is to be acquired or as the result of which displacement will otherwise occur, that the State agency has agreed to provide to displayed persons for moves from such real property-(a) relocation payments on the same basis as those provided in the case of direct Federal acquisition of real property; (b) relocation assistance programs; and (c) a feasible method for the temporary relocation of displaced families and individuals, and an assurance that decent and sanitary dwellings are available and reasonably accessible to displaced families and individuals. Cost to State agencies providing relocation payments and services would be included as part of the costs of the project for which Federal financial assistance is otherwise available. The State agencies would be eligible for Federal financial assistance with respect to such payments and services in the same manner and to the same extent as with respect to other eligible project costs, except that the Federal agency providing assistance would contribute (up to) the first $25,000 of any relocation payment to a displaced person, and no State agency would be required to make a relocation payment to any displaced person of more than $25,000 in order to receive Federal assistance for relocation payments, or to meet requirements of section 807. (For purposes of Title VIII, the term "State" would include the political subdivisions of a State.)

We agree with the Bureau of the Budget that insofar as real property acquisition is concerned, the costs of displacement caused in whole or in part by Government action are, in a very real sense, costs of property acquisition and should be financed in the same manner as the other costs of property acquisition. We also believe that, as a matter of policy, all these costs and assistance should be as uniform as possible. It seems to us desirable that in all direct Federal programs, as well as in State or local programs carried on with the assistance of Federal funds, this principle should be applied. The Department of Health, Education, and Welfare fully supports the principle of (1) making fair and reasonable relocation payments to persons displaced by the acquisition of real property under direct Federal programs, (2) provision of a complete range of relocation services and other assistance for program displacees consistent with need, (3) requiring State and local governments to assume responsibility for relocation payments and services as a condition of participation in federally assisted programs, and (4) contributing to the costs of relocation payments a Federal share proportionate to the percentage of Federal participation in other eligible project costs. Title VIII, in our view, would meet these overall objectives if it were amended to provide (as the Bureau of the Budget has suggested), in the case of federally assisted programs, that the Federal Government share in the cost of relocation payments made by State agencies only to the same extent as other project costs.

In reaching the above conclusion, we are not unmindful of the fact that in certain federally assisted programs, e.g., urban renewal, the Federal Government now assumes a higher share of relocation costs than its percentage of participation in the project. On balance, however, recognizing that uniformity is desirable in relocation assistance programs, and on the basis of our experience in the many and varied grant-in-aid programs of this Department, we believe that through the utilization of the particular project formula in relocation costs. the common program goals at the Federal, State, and local levels can be reached

while at the same time strengthening what we regard as a basically effective and purposeful working relationship.

TITLE IX

Part A of this title (Federal Programs) sets forth certain policies vis-a-vis property owners that are to be followed by Federal agencies in acquiring real property from such owners by purchase or condemnation. For the most part, these policies seem designed to assure fair treatment to the owner and to others in possession of the real property.

Part B would provide that financial assistance to a State agency, or to an agency of a political subdivision of a State, shall not be available to pay for the cost of acquisition of real property, or the cost of a public improvement for which real property is to be acquired, unless such agency agrees to follow certain rules (set forth in part B) that, as in the case of part A, seem designed to assure fair treatment to the owner (and others in possession) of the property to be acquired by such agency by purchase or condemnation. Some of these rules would take effect on January 1, 1970. In part, these provisions are patterned after the land acquisition policy provisions contained in Section 402 of the Housing and Urban Development Act of 1965 (P.L. 89-117) which applies to certain programs administered by the Department of Housing and Urban Development. That section, together with certain related sections (Sections 401, 403) of P.L. 89-117, would be repealed effective January 1, 1970.

While we endorse the objectives of this title, on its details we defer, particularly in the case of direct acquisitions, to the General Services Administration and other agencies more frequently involved in such acquisitions.

TITLE X

The purpose of title X is to encourage simplification and improve coordination of accounting, auditing, and financial reporting requirements of Federal assistance programs, and to provide for a survey of the adequacy and effectiveness of the accounting and auditing systems of recipient jurisdictions. This title would authorize the Comptroller General to prescribe rules and regulations for using State and political subdivision accounting and auditing in meeting financial management requirements of such programs. The Comptroller General, the Secretary of the Treasury, and the Director of the Bureau of the Budget would be required to conduct a joint study of the principles, standards, and related requirements of Executive agencies for accounting and auditing of Federal assistance programs, with a view to developing improved Government-wide accounting and auditing procedures.

Within the last month the Comptroller General, the Secretary of the Treasury, and the Director of the Bureau of the Budget have agreed to initiate an interagency study in this area. Consequently, we recommend deferral of legislative action of title X pending completion of this study.

We are advised by the Bureau of the Budget that there is no objection to the presentation of this report from the standpoint of the Administration's program. Sincerely,

WILBUR J. COHEN,

Secretary.

OFFICE OF THE SECRETARY OF TRANSPORTATION,
Washington, D.C., June 12, 1968.

Hon. EDMUND S. MUSKIE,
(kairman, Subcommittee on Intergovernmental Relations, Committee on Govern-
ment Operations, U.S. Senate, Washington, D.C.

DEAR MR. CHAIRMAN: This is in response to your request for our views on S. 698, a bill "To achieve the fullest cooperation and coordination of activities among the levels of government in order to improve the operation of our federal system in an increasingly complex society, to improve the administration of grantsin-aid to the States, to provide for periodic congressional review of Federal grants-in-aid, to permit provision of reimbursable technical services to State and local government, to establish coordinated intergovernmental policy and administration of grants and loans for urban development, to authorize the consolidation of certain grant-in-aid programs, to provide for the acquisition, use, and disposition of land within urban areas by Federal agencies in conformity with local government programs, to establish a uniform relocation assistance policy, to establish a uniform land acquisition policy for Federal and federally aided programs, and for other purposes."

The substance of Title V of this bill, relating to periodic Congressional review of grants-in-aid programs, is also treated in S. 458 and S. 735. We have sent a separate letter on those bills and those comments constitute our comments on Title V of S. 698.

Title XIII of S. 698 relates to relocation assistance to displacees of Federal and federally-assisted programs. We want to make a special plea for enactment of legislation to provide this assistance. We have in the past been unable to adequately and meaningfully assure that persons displaced by our highway programs are treated justly. The truth is that inadequate provision of relocation assistance has worked a severe hardship on many families and businesses displaced, particularly on the poor. Our detailed views on Title XIII have been submitted in testimony.

Subject to the above views, the Department of Transportation favors enactment of this legislation.

The Bureau of the Budget advises that from the standpoint of the Administration's program, there is no objection to the submission of this report for the consideration of the Committee.

Sincerely,

JOHN L. SWEENEY, Assistant Secretary for Public Affairs.

GENERAL SERVICES ADMINISTRATION,
Washington, D.C. June 14, 1968.

Hon. EDMUND S. MUSKIE,

Chairman, Subcommittee on Intergovernmental Relations, Committee on Government Operations, U.S. Senate, Washington, D.C.

DEAR SENATOR MUSKIE: Your letter of February 28, 1967, requested the views of the General Services Administration on S. 698, 90th Congress, the short title of which is the "Intergovernmental Cooperation Act of 1967."

The bill is subdivided into nine titles. GSA's comments are confined to the provisions of titles VII, VIII, and IX, which relate to the acquisition, use, and disposal of land by Federal agencies, as these are the only portions of the bill which would appreciably affect the responsibilities of GSA. We are in accord with the over-all purposes of these titles.

Title VII amends the Federal Property and Administrative Services Act, 63 Stat. 377, as amended, by adding at the end thereof a new title VIII which would require the Administrator of General Services to give advance notice to local governments prior to offering for sale any Federal real property located within an urban area. The Administrator also would be required to provide available zoning information to prospective purchasers. In connection with the acquisition or change in use of real property, the Administrator would be required to comply to the extent practicable with local zoning requirements, give advance notice of plans to acquire additional property, and to consider objections by local governments to proposed Federal acquisition or use of real property in urban areas. The primary objectives of title VII are consistent with GSA's policy to give advance consideration of local comprehensive planning and land-use regulations in formulating specific acquisition and disposal plans.

We would recommend, however, that the last sentence of the proposed section 804 (a) of the Property Act, which begins on line 7 and ends on line 12, page 30 of S. 698, be deleted. The sentence implies that potential adverse impact resulting from advance notice of proposed land acquisitions is the exception rather than the rule. Our experience shows that this is not the case, but that advance public notice of proposed acquisitions of real property by the Federal Government more often than not precipitates land speculation and inflationary real estate prices in the vicinity. With this recommended change, GSA would have no objection to the enactment of title VII.

The purpose of title VIII is to establish a uniform policy for the fair and equitable treatment of owners, tenants, and other persons displaced by the acquisition of real property in Federal and federally assisted programs. This policy is to be as uniform as practicable as to (1) relocation payments, (2) advisory assistance, (3) assurance of availability of standard housing, and (4) Federal reimbursements for relocation payments under federally assisted programs.

GSA has long recognized the need for uniform and equitable practices in the treatment of persons displaced by the acquisition of real property by the Federal

Government. Except for the acquisition by the Department of Defense or any military department thereof, the Department of the Interior, the National Aeronautics and Space Administration, the Tennessee Valley Authority, and the Department of Housing and Urban Development, displaced owners or tenants of federally acquired property may be paid only the fair market value of the property acquired. Expenses, losses and damages incurred by owners or tenants as a direct result of moving themselves, their families and possessions are not compensable.

Reports issued by the Select Subcommittee on Real Property Acquisition of the House Committee on Public Works and the Advisory Commission on Intergovernmental Relations clearly indicate that the Federal, State, and local governments are falling far short of equity in their treatment of those persons who are displaced as a result of the programs of such governments. GSA has long advocated the enactment of legislation which would minimize inequities existing in the present state of law when property is acquired in Federal programs.

Generally, we believe that enactment of title VIII of S. 698 would establish a workable, uniform system for fair and equitable treatment of individuals displaced by Federal land acquisitions. However, in the interest of clarifying some of its provisions we offer the following comments and amendments for consideration by your Committee.

Section 803 (a) provides for a relocation assistance program for individuals who occupy property adjacent to the acquired property and to those displaced from the acquired property. We recommend that the bill not provide assistance to occupants of adjacent property on the grounds of impracticability, the impossibility of factually ascribing claimed losses to the Federal acquisition, and the availability of aid in such situations from other Federal sources such as the Small Business Administration.

We are in accord with the objectives of section 803 (c) (2) which would require Federal agencies to assure the availability of adequate substitute dwellings within a reasonable period of time prior to displacement. However, the effect of this provision on GSA's public buildings program is a matter of some concern. This program requires the acquisition of sites generally located in highly populated areas. The mandatory requirement that the acquiring agency be required to obtain assurance of substitute dwellings for the displaced prior to displacement would in many cases cause interminable delay in the construction of the project. Further, the delays encountered would not be controllable by GSA since the availability of adequate substitute housing is dependent upon local housing conditions. The question whether the Federal Government should assure adequate substitute housing prior to displacement must of course be resolved in the light of the over-all Federal program. However, your Committee should be aware of the effect of section 803 (c) (2) on the activities of acquiring agencies whose programs are confined largely to urban areas.

We would suggest that the Committee give serious consideration to amending section 803 (c) (2) by granting broader authority to Executive agencies to waive the requirements in unusual situations such as where immediate action might be required to protect individuals or property because of natural or unnatural disasters. The present waiver provision of the bill is applicable only during a period of national emergency proclaimed by the President. We recommend that the section be amended to provide that the President by regulation may prescribe situations when such assurances may be waived.

The suggested amendment will not greatly affect the operations of our site acquisition program although it will permit expeditious action when emergency situations warrant. However, the additional costs which will be incurred in other acquisitions as a result of the assurance provision of section 803 (c) (2) will be substantial because of anticipated delays in commencement of construction and increases in other administrative expenses. Because of the many unknown factors, it is not possible to estimate the extent of the additional costs. With respect to section 805(a) (2) (A), which limits entitlement to actual and reasonable expenses of searching for replacement locations to farm operations, we suggest that the Committee consider, in furtherance of the stated purpose of uniformity of treatment of all persons displaced by Federal acquisitions, whether entitlement to such expenses should also be extended to dwellings and businesses, taking into account also the administrative burden incident to determining the nature and reasonableness of such items of expenses which should be reimbursed.

We suggest that the Committee also consider whether the payment provided for in section 805(a)(2) (B), which section authorizes the payment of an ex

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