Box 14, Folder 20, Document 6

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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 basic premise it is felt that local government officials and ad-
ministrators should play an active part in the initial formulation of
federal grant-in-aid legislation that affects the growth, development, ad-
ministration, and operation of local government in Georgia. Local govern-
ment officials and administrators should also be consulted in the develop-

ment of implementing administrative regulations for such legislation.

Many federal grant-in-aid programs appear to be founded to a large
degree upon criteria or standards of application as determined almost en-
tirely at the federal level. An example is current legislation in Congress
to establish community development districts, the makeup and composition of
which is proposed to be approved by a cabinet officer based upon predeter-

mined criteria.

Intergovernmental Cooperation
There is strong probability that future urban programs, of even our

larger cities, will as a prerequisite to federal approval, have to be re-

viewed by regional organizations or area planning and development commis-—

sions. The Intergovernmental Cooperation Act of 1965 (S. 561) which passed
the Senate and not the House would have required review by a metropolitan

planning agency before the federal government would act.

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 development that transcend established
political and jurisdictional boundaries and cut across entire regions.

These organizations will play a vital role in total coordinated urban devel-


Only recently were these organizations recognized by the federal gov-
ernment 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 instrumen-
tality, 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 re-
gional 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 per-
sonnel in the development and implementation of federal grant-in-aid pro-
grams. 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
federal rules and regulations which apply to all units of government re-
gardless of size. A good example is the workable program for community
development. This program as a prerequisite to involvement in certain
federal programs is lacking in flexibility, in its application, and im-
poses 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 capital improvements budget is cer-
tainly 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 to ques-—


The arbitrary requirement that the workable program be recertified
each year regardless of size of city results in local administrative falsi-
fying 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 previous year's
commitment. Yet no standards or justification were stated as to why these

requirements were imposed.
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 practi-
tioners. 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 well 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

project. As an alternative, why not allow an overall total grant with
credit given for noncash items in a program sense rather than in specifics
so that the local credit items could be reflected in an overali urban

renewal plan, as opposed to specific items on a project basis.

Specific criteria and prerequisite standards are applied in the devel-
opment of urban renewal projects. Yet similar requirements for streets,
highways, and other physical facilities may be programmed with a total dis-

regard for city's master plan.

Economic Opportunity Program
The following is a discussion of areas where cities (particularly,
mayors) have encountered local problems in administration of the Economic

Opportunity Program.

Many mayors would have liked to have had some say in the initial devel-

opment of VISTA (Volunteers In Service To America), or domestic peace corps

program. Apparently, many mayors were not involved in the initial develop-
ment of this program, and consequently, found it necessary to refuse parti-
cipation in the VISTA program or were required to use their influence to

cancel VISTA programs operating within their communities.

An understanding of the extent of the role of VISTA within the politi-
cal area is a demand the mayors could assert. However, this would be in
opposition to the philosophy of VISTA in granting great flexibility and
freedom. Thus, EOA, bearing in mind the problems which could be created
for the mayor and the city council by completely unhindered volunteers, has
had to demand that VISTA volunteers be tied down to specific assignments.

This has been particularly true of the program in Atlanta.

The question of the mayors veto of OEO projects is continuously raised.
Certainly obstructionist politicians should not be able to deny necessary
and reasonable programs for their citizens, 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 involvement of the poor at the local level
by CAP agencies in planning and in conducting CAP programs. 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 groups 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 actu-

ally designed to be on-going projects.

Recent changes in the requirements of the Small Business Development
Center program under Title IV of the Economic Opportunity Act is an indi-
cation of lack of consideration on the part of local officials in making
sweeping changes in the intent and content of a program. The original
Title IV provision was designed to help increase employment by providing
low interest loans to small businessmen who would guarantee creation of
additional jobs which could be filled by the poor as well as the creation
of new entrepreneurs under low income groups. The initial guidelines have
now been so changed that the program simply is being conducted to see how
many loans can be granted to persons who are not now in business and who
are in poverty. The SBA makes it clear that it is interested in making as

many loans as possible to Negroes to start small businesses.

Recent Congresses of the United States, recognizing the growing demand
by citizens for recreation and parks, have passed considerable legislation
affecting these movements. The recreation profession, although pleased to
see the vast interest in recreation and parks on the Federal level of gov-

ernment, does hold some reservations about it.

Specifically, the Federal government has classified all recreation
and parks under one heading -- "Outdoor Recreation". This fact alone con-
tributes to a narrow view of recreation. Recreation, as it is conducted
in Georgia cities, includes every facet of leisure pursuits for the devel-
opment 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
Bill, the Housing and Urban Development Act of 1965, the Older Americans
Act, the Economic Opportunity Act of 1965, and many others have affected
the growth and development of recreation in the nation. Basically sound
legislation has lost the main emphasis on the programs through guidelines
established by the various Federal departments administering the programs.
Basic programs originally included in the legislation have been given such

low priority that approval of an application is almost impossible.

Recent Federal legislation relating to recreation and parks will have
a great impact upon the recreation and parks movement in the United States.
There are, however, many areas of the present legislation which could be

improved to better serve the communities,

These are:


The Federal government or the Federal departments administering the

legislation has placed guidelines on the programs which make them quite

difficult for many communities to take advantage.





Practically all the current programs require detailed community-
wide planning. Although this requirement is basically good, it
makes many of our smaller communities ineligible from lack of
proper finances for planning. Federal agencies administering the
programs should be given leadway in approving applications from
small communities who do not fully meet the guidelines established
by the Federal department.

The community leadership should be permitted to best determine the
more suitable location for any program or facility. It should not
be restricted entirely to poverty areas.

State governments should be given the authority to renew, recommend,
and approve applications prior to submission to the Federal govern-
ment. State agencies are aware of the needs of communities in
their respective states and will act with speed and efficiency,
Currently many programs by-pass the state altogether. In such in-
stances this renders the area planning and development commissions
and similar groups less effective in guiding orderly planning and
development. By the same token, state agencies capable of assist-
ing communities with various developments, are seldom consulted.
Present program applications are by far too difficult for the aver-
age community to complete and file with the proper agency. Present
methods almost require the full-time services of a person trained
for this purpose. Many of our smaller communities cannot afford

to employ such a person.

(e) Guidelines should be set forth in common terms understandable by
all communities, Presently, it is the case where some of the fed-
eral employees with the administering departments do not agree on
the requirements. This simply causes confusion and misunderstand-
ing on the part of local governments.

(f) Federal employees should be qualified to interpret and supervise
Federal programs in which they work. It is inconceivable that a
person trained in forestry, agriculture, and horticulture can do
the total job necessary for recreation and parks. Recreation is
a new profession with personnel trained in this field. Personnel
possessing the broad concept of recreation and parks should admin-

ister Federal programs.

The Land and Water Conservation Fund Bill is designed to provide match-
ing funds up to 504 to states and their political subdivisions for planning,

acquisition and development of outdoor recreation areas.

State planning is essential. Each state, in order to be eligible
(Georgia could receive up to $2 million annually in this 25-year program)
must prepare a state plan which must be approved by the Bureau of Outdoor
Recreation. As of May 1, 1966, comprehensive statewide outdoor recreation
plans have been approved except Georgia, Iowa, North Carolina, Utah, and

Wyoming. Projects will not be approved until the state plan is approved.

This law states specifically that matching funds "may be made avail-

able to political subdivisions".

Upon making further inquiries as to how the communities actually fit
into the plan and how they will participate in the program, no clear cut

answers were available. Actually, local communities do not now know to


what extent they will be included in the program.

The contention of many is that a state plan cannot be a comprehensive
one unless it includes the needs and capabilities of communities. After
all, the masses of the people are located 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


This piece of legislation is vital to all cities and consequently,

they should have a voice in the make-up of the program in Georgia,

In other states attempts have been made to remove the L&WFB from poli-
tics and to insure that projects are considered on the basis of need. In
one state, for example, over 100 carefully selected leaders were brought
together in the forming of a council for the purpose of establishing guide-
lines for the program. It was their responsibility to determine a real
basic point -- what percentage of the funds would be allocated to local

communities, state parks, and federal agencies within the state.

A lay group, representing various interests, should be appointed for
the purpose of making these same decisions in Georgia. Additionally, this
same group or a similar one should be appointed and authorized to review
each piece of federal legislation prior to its implementation in Georgia,

and make certain procedural recommendations.

Without positive action there is a possibility that Land and Water
funds will completely elude the cities of Georgia. This situation requires

immediate positive steps.



The broad shopping 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. In many cases, the emphasis on specific programs
and projects is determined nationally not locally, 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. If such were the case, a city could submit a comprehensive state-
ment of its needs in terms of priority and emphasis on local programs and
be given a grant with the necessary flexibility for implementation in accord-

ance to priorities as determined locally by that city.

Urban Policy Council

In conclusion it is felt that this state could take a very positive
step toward harmonious coordination of federal grant-in-aid programs and
urban development by establishing a steering committee or council on urban
policy charged with the responsibility of developing a statement of policy
for coordination, development and administration programs dealing with the
total growth and development of our communities. Such a committee should
be composed of the following: representatives of municipal government
through the Georgia Municipal Association; representatives of county gov-
ernment through the Association of County Commissioners of Georgia, repre-
sentatives of state government through the Executive Office; and represent-

atives of Georgia's Congressional Delegation.

This committee could have the given responsibility for the performance

of the following basic functions:


To analyze the trends, conditions, needs, and problems affecting
local government in Georgia's rapidly urbanizing state;

To define the complimentary and cooperative roles of local, state,
and federal agencies with respect to the development and implemen-
tation of urban programs;

To recommend appropriate policies that would govern the working
relationships between local, state and federal agencies in the
development, implementation, and coordination of programs to cope

with urban growth.
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