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DRA F T M EMO RA NDUM URB A N P OL I CY COUN CI L �MEMORANDUM URBAN POLICY COUNCIL The purpose of this memorandum is to present a statement of the need for establishing a steering committee or Council on Urban Policy in this state to consider formulation of policy recommendations with regard to local government involvement in the development of federal grant-in-aid legislation as affecting urban program development in Georgia . As a bas i c premise it is felt that local government off icials and administrators should play an active part in the initial formulation of federal grant-in-aid legislation that affects the growth, development, administration, and operation of local gover nment in Georg i a. Local govern- ment off icial s and administrator s should also b e cons u lted in the dev e lopment of implementing administrative regulations for such l e gislation . Many fe deral grant- in- aid programs app ear to be f ounded to a l a r ge degree upon criter i a or standards of app lication as de t e r mined almost ent i rely a t the federal leve l . An example is curr ent leg islation in Congress to es t ablish communi ty development dis tr i c ts, the make up and c omposit ion of which is proposed to be approv ed by a cabinet officer based upon prede t ermined criter ia . Intergovernmen tal Cooperation There is strong proba bility that future urban programs, of even our larger c ities , wil l as a p rerequisi t e to fe deral a pp rova l , have t o be reviewed by regional organizations or area p fanning and development commissions. The Intergovernmental Coop eration Act of 1965 (S . 561) which passed the Senate and not the Hou se would have required review by a metropolitan planning agency before the federal government would act. �-2- Regional organizations composed of public officials are now recognized by federal law. These organizations have come into being to meet the need for dealing with problems of urban develop~ent that transcend established political and jurisdictional boundaries and cut across entire regions. These organizations will play a vital role in total coordinated urban development. Only recently were these organizations recognized by the federal government to be more than mere planning agencies. Future federal policy con- templates grants to these agencies conditioned upon mandatory not voluntary membership. Also being considered in some quarters is the evolvement of this regional voluntary association of local governments into an instrumentality, either operating regional type functions or serving as the control center over other regional, functional units. Thus, our traditional gen- eral purpose cities and counties of today may be defining tomorrow's regional general purpose network of government. It should be apparent that these developments are restructuring our intergovernmental relationships in the urban area. Workable Program Part of the problem of local inflexibility and lack of administrative coordination perhaps lies with the over involvement of federal staff personnel in the development and implementation of federal grant-in-aid programs. There has not been enough involvement by local administrators and decision-makers in federal aid program development and implementation . There are many examples of past legislative grant-in-aid enactments by the Congress that often hamstring local government administrative machinery because of the inflexibility of black and white implementing �-3- federal rules and regulations which apply to all units of government regardless of size. development. A good example is the workable program for community This program as a prerequisite to involvement in certain federal programs is lacking in flexibility, in its application, and imposes standards laid down without regard to the fact that local ability to implement and execute programs varies between large and small cities . The requirement of a long range capjtal improvements budget is certainly desirable as a basis for scheduling of projects. However, many local units of government do not even have annual operating budgets. Con- sequently, the reality of a blanket requirement of a long range capital improvements program without requiring operating budgets is open toquestion. The arbitrary requirement that the workable program be recertified each year regardless of size of city results in local administrative falsifying each year. There is a real question of whether the large city should be required to recertify the workable program each year -- why not every five years or every ten years? One large city produced a model workable program and was so claimed by the federal administrator to be one of the best workable programs in the nation. The next year the workable program of that city was not recerti- fied because the federal administrator had said that it had not changed enough over the previous year as reflected by the city's progress reports . Another city was refused recertification because the administrator said the city needed four additional housing inspectors over the previo us year's commitment . Yet no standards or justification were stated as to why these requirements were imposed . �-4- In large cities, specific programs do not necessarily reflect dramatic changes on a yearly basis . Thus, recertification of the workable program for many cities is certainly jeopardized unless that city can "pad" its progress reports in order to convince the federal administrator of progress (not given units of progress but progress) and thus secure recertification. There is involvement in the initial drafting and development of federal legislation because of NLC, USCM, and NACO activities, committee hearings, etc. Yet it appears that broad discretion is given to federal administra- tors with regard to program implementation of legislation . This can be seen in the writing and drafting of agency regulations for implementation. The preparation of such regulations should involve the local public official or administrator in order to bridge the gulf between policy makers and practitioners. Quite often the administrative regulations seem to go much further than the intent of legislation. Urban Renewal In the case of urban renewal, real estate acquisition is supposed to be based upon a program of local determination. The criteria on rehabili- tation are extremely rigid on what a city is allowed to do . The same cri- teria apply to a large agency with large projects as we ll as to a small agency working on a single project. The large agency with the larger pro- jects need more flexibility in the planning, direction , and execution of such projects than would be the case of a small agency . Urban renewal regulations make reference to specific noncash credit items such as a 100% credit for a street serving the project, 50% for a boundary street, 25% for sewer line, etc. However, specific noncash items cannot always be apportioned in specific terms to a given urban renewal �-5- project . As an al t ernative, why not allow an over all total grant with credit given fo r noncash items i n a prog r am sense rathe r t han i n specifics so that the local credit items could be reflected in an overall urban renewal plan, as opposed to spe cific items on a project basis . Specific criteria and prerequisite standards are a pplied in the development of urban renewal projects . Yet similar requirements for streets, highways, and other physical facilities _may be programmed with a total disregard for city 's master plan . Economic Opportunity Program The followi ng is a discussion of areas where cit i es (particularly, mayors) have encountered local problems i n a dmin is t r a tion of the Economic Opportunity Program . Ma ny ma yors would have l iked to have ha d some say in t he initial developme nt of VI STA (Vo lunteers In Se rvic e To Ame rica ), or dome st ic peace corp s program. Apparent ly, many mayor s we r e not i nvolved in the i n i t i al devel op- ment of t his p r ogram , a nd consequent l y, fo und i t ne ces s a ry to refuse part i cipat i on in the VISTA program or were re quired t o use their influence to cancel VISTA pr ograms op erating within t h eir communities . An understanding of the extent of the role of VISTA with in the political area is a demand the mayors could assert . However, this would be in opposition t o the philosophy of VI STA in gra nt ing great flexib ility and freed om. Thu s, EOA, b earing in mind th e problems wh ich could be created for the mayor and the city council by completely unhindered volunteers, has had to demand that VISTA volunte e r s be tie d down to s pec i f i c a ssignments . This has been par ticularly true of the program in Atlanta . �-6- The question of the mayors veto of OEO projects is continuously raised. Certainly obstructionist politicians should not be able to deny necessary and reasonable prog r ams for their citizens o Yet, neither the federal gov- ernment nor any other agency should be in a position to institute programs utilizing tax resources in a political subdivision with complete disregard of the elected leaders of that subdivision . The OEO philosophy demands involv~ment of the poor at the local level by CAP agencies in planning and in conducting CAP programs o However, this philosophy of involvement does not apparently apply at the Washington level. Many programs have originated from Washington with fairly stringent guidelines in which there have been no participation by municipal officials or other interested gro ups at the local level . Many of these programs are under the guise of demonstration programs such as the Foster Grandparents Demonstration project (as conducted in Atlanta) and many of them are actually designed to be on-going projects . Recent changes in the requ irements of the Small Business Development Center program under Ti tle IV of the Economic Opportunity Act is an indication of lack of consideration on the part of local officials in making sweeping changes in the intent and content of a prog r am . The or iginal Title IV p r ovis i on was des i gned to help increase employment by p roviding low inter est loans to small businessmen who would gua r an t ee creation of additional jobs wh i ch co ul d be filled by the poor as well as the creation of new entrepreneurs under low i ncome groups o The initial guidelines have now been so changed that the program simply i s be ing conducted to see how many loans can be g r an ted t o persons who are no t now in business and who are in poverty o The SBA makes it clea r that it is inter ested in making a s many loans as poss i ble to Negroes t o start small businesses . �-7- Recreat i on Rec ent Congre ss e s of t h e Uni ted States, recogn i z i ng the growing demand by citizens for recreation and parks, have passed considerable legislation affecting these movements . The recreation profess i on, although pleased to see the vast interest in recreation and parks on the Federal level of government, does hold some reservations about it . Specifically, the Federal governm~nt has classified all recreation and parks under one heading -- "Outdoor Recreation" . tributes to a narrow view of recreation . This fact alone con- Recreation, as it is conducted in Georgia cities, includes every facet of leisure pursuits for the development of the citizenry . The area of "Outdoor" recreation is only one com- ponent of the field of recreation . It is the feeling of many persons in the field that future wording in Federal legislation should state plainly -- "Recreation" in its broadest sense and not "Outdoor Recreation" . Current Federal laws , such as the Land and Water Conservation Fund Bi ll, th e Housing and Ur ba n Dev e lopment Act of 1965, t he Older Ame r i cans Act , the Economic Oppo r tun ity Ac t of 1965, and many o the r s hav e aff ec ted the gr owth and development of r e c rea tion i n the nation . Bas i c ally sound legislation h a s los t t he ma i n emphas i s on t he p ro gr ams t h r ough gui delines e stabl i shed by t he various Fede ral de partmen t s admini s tering t he p ro g r ams < Bas ic p r og r ams orig i n a l ly i n c l ude d in t h e leg i sla tio n have be en g iven s uch low prior ity t h a t app r oval of a n a ppl ic a t ion i s almo s t i mp oss i bl e . Rec ent Fede r al legis l ation re lating t o recrea t i on and pa r ks wi l l have a g re a t i mpact upo n the r e c r ea tion an d pa r ks moveme n t in t h e Uni t e d States . The r e a r e, however, many a r eas of t h e pr esent l egi slat i on which cou ld be i mp r oved t o b etter s erve t h e communit i e s . �-8- These are : 1. The Feder al government or t he Federal departments administer i ng the legislation has plac ed guidelines on the prog r ams which mak e them quite diffi cult fo r many communi t i e s to take advantage . (a) Practically all the curr ent programs require deta i led communitywide planni ng o Although this requirement is bas ically good, it makes many of our smaller communities inelig i ble from lack of proper finances fo r planning . Federal agencies admi n i stering the programs should be giv en leadway in approving applications from small communities who do not fully meet the guideli nes established by the Federal departme nt . (b) The community leader shi p should be permitted to bes t determine the mo r e sui table locat i on fo r a ny program or facil i ty . It should not be r est ric ted en t ire l y to poverty areas . (c) St ate governments s hould be given the authority to r enew, recomme nd, and approv e appl i cations pr i or to submiss i on t o the Fe deral government . St ate ag en cies are awa r e of th e needs of commun i t ies in t heir res pective s tate s and wi ll a c t wi th sp e e d and e f fi ciency . Cur rently many pr ograms by-pass the stat e al t og e ther . I n suc h i n- s tance s th i s rend er s the a r ea planning and dev elopme n t commi ss i ons and similar groups less effective in guid ing orderly planning a nd deve l opment . By t h e same token, s t a te agencie s c ap a b le of a ssis t - i ng communities with v arious deve lopme n ts, are seldom consul t ed. ( d) Pr e sent p rogr am app lications are by far too difficul t for t he a verage community t o comp l ete and fi le with the proper agency . Pres ent methods almost requ i re the full-time services of a person trained for this pur pose . Many of our smal ler communities cannot aff ord to employ such a person . �-9- (e) Guidelines should be set forth in common terms understandable by all communities o Presently, it is the case where some of the fed- eral employees with the a dministering department s do not agree on t he requirements o This simply causes confusion and misunderstand- ing on the part of local gov e r nments o (f) Federal employees should be qualified to interpret and supervise Federal programs in which they work o It is inconceivable that a person trained in forestry, agriculture, and hort iculture can do the total job necessary for recreation and parks o Recreation is a new profession with personnel trained in this field . Personnel possessing the b ro ad concept of recreation and parks should administer Federal programs o The Land and Water Conser v ation Fund Bill is designed to provide matching funds up to 50 % to states and their political subd ivisions for planning, acquisition and deve lopment of out door recreation areas o State pla nn i ng is essential . Each state, in order to be eligible (Georgia could receive up t o $2 million annually in th i s 25-year program) must prepare a state plan wh i c h must be approved by t he Bureau of Outdoor Recreation " As of May 1 , 1966, comprehensive statewide out doo r re reation plans have been a pp r ov ed exc ept Georg i a, Iowa, North Caro lina, Ut ah , and Wyoming . Proje c ts will no t be approv ed unt i l the s t a t e plan i s app r oved . This law stat es spec if ically that matching funds "may be made available to political subdivi s i ons" o Upon maki ng furth er inquiries as to how the communities a c tually fit int o the plan and how t hey will parti cipa t e in the prog r am , no clear cut answers were a vailable o Actually, local communities do no t now know t o �-10- what ex tent they will be i ncluded in the program . The contention of ma ny i s t hat a state plan canno t be a comprehensive one unless it i nclude s the needs and capabil i t i es of communitie s . After all, the masses of the people are loc ated largely in the urban areas . Al- though the Georgia plan now being developed might include the communities, this does not seem to be the case since inquiries point to the fact that no community has been requested to participate in the planning . It seems, in this light, plans cannot be made for communities without the communities' assistanc e . This piec e of legislat i on is vital to all c i ties and consequently, they should hav e a v o ice i n the make-up of the program in Georgia . In other s t a t es a tt emp t s hav e been made to remove the L&WFB from politics and t o i nsure that project s are considered on the basis of need . In one st_a te, fo r ex ample, ov e r 100 car efully selected leaders were b r ought t og ethe r i n t he form i ng of a c ouncil fo r th e purpose of es tabl i shi ng guidelines fo r t h e prog r am . It wa s t heir r esponsib i l i ty to determ i ne a r eal basi c point -- what percent a ge of the funds would be al l o ca t ed t o l ocal communit i e s, s tate parks, and f ed eral agenci e s wi t hin the s tate . A l ay group , rep resent i ng v a r i ou s i n teres ts, should b e a pp oin ted f o r t he pur pos e of maki ng t h ese s ame deci s i on s i n Ge or g i a . Additionally, t h i s same gr oup or a similar one should b e app oint ed and authorized to rev iew e a ch p iece of fed era l leg islation p ri or t o its i mp l eme n tation i n Ge or g i a, and make certa in procedural recommenda tions . Without positive action t he r e is a po s sib i l ity that Land a nd Water funds will comp letely elude the c ities of Georgia . immediate positive s teps . This situation r e quires �-11- Conclusion The broad shopp i ng market of federal programs portrays a gross amount of money for use locally as the federal government sees fit, and according to its program emphasis o In many cases, the emphas i s on specific prog r ams and projects is determi ned nationally not locally o However, it is believed that many of our cities , large and small, do have the capability of making such determinations and should be allowed the administrative flexibility to determine the level of emphasis that should be placed on specific local programs o If such were the case, a city could submit a comprehensive state- ment of its needs in terms of pri ority and emphasis on local programs and be given a grant with the nec essary flexibility for implementation in accordance to priorities as determi ned locally by that city o Urban Policy Council In conclusion it is fe l t t ha t this state could take a very pos i tive step toward harmonious coord i nation of federal grant-in-aid p r ograms and urban development by e s tab lish ing a s t eering committee or council on urban policy char ged with t he res ponsibility of dev eloping a statement of pol icy for coord i nat i on, dev elopment and administration prog r ams deal ing wit h the total grow t h and development of our communities o be composed of the f ollowing : Such a commi t tee should r e p resentatives of municipal gov ernment t hrough t he Georg i a Municipal Association; r ep r esentatives of county government t h r ough the As so c iation of County Commissioners of Geor gia, rep r e sentatives of stat e gov ernment t h r ough the Executive Off ic e; and r ep r es ent atives of Georgia ' s Congressional Delegation o This commi ttee could hav e t he g iven responsibility for the performance of the fol lowing basic functions: �-12- 1. To analyz e the t r ends , condi tions , needs, and problems affecting local government in Geo r gia ' s rapidly urbaniz i ng s t ate; 2. To def i ne the compl i mentary and cooperative roles of local, state, and federal agenc ies with respe c t to the development and implementation of urban programs; 3. To re commend appropriate policies that would govern the working relationsh i ps bet ween local, state and federal agenc ies in the development, implementation, and coordination of programs to cope with urban growth . �