(3) give critical attention to the conditions and controls involved in the administration of Federal grant programs;

(4) make available technical assistance to the executive and legislative branches of the Federal Government in the review of proposed legislation to determine its overall effect on the Federal system;

(5) encourage discussion and study at an early state of emerging public problems that are likely to require intergovernmental cooperation;

(6) recommend, within the framework of the Constitution, the most desirable allocation of governmental functions, responsibilities, and revenues among the several levels of governments; and

(7) recommend methods of coordinating and simplifying tax laws and administrative practices to achieve a more orderly and less competitive fiscal relationship between the levels of government and to reduce the burden of compliance for taxpayers.

The law also spells out the following "Duties of the Commission": (1) to engage in such activities and to make such studies and investigations as are necessary or desirable in the accomplishment of the purpose set forth in section 2 of this Act;

(2) to consider, on its own initiative, ways and means for fostering better relations between the levels of government;

(3) to submit an annual report to the President and the Congress on or before January 31 of each year. The Commission may also submit such additional reports to the President, to the Congress or any committee of the Congress, and to any units of government or organization as the Commission may deem appropriate.

THE COMPOSITION OF THE COMMISSION

The Commission is a 26-member, bipartisan body. To assure political balance and wide representation, the Act mandates that nine of the 26 Commission members represent the Federal Government, seven represent State government, seven represent local government, and three the public-at-large.

Six Commissioners are Members of Congress:

Three U.S. Senators appointed by the President of the Senate; and

Three U.S. Representatives appointed by the Speaker of the House.

The President appoints 20 members:

Three private citizens;

Three officers of the Federal Executive Branch;

Four governors appointed from a list of nominees recommended by the National Governors' Conference;

Three State legislators appointed from a list of nominees recommended by the Council of State Governments;

Four mayors appointed from a list of nominees recommended by the National League of Cities and the U.S. Conference of Mayors; and

Three elected county officials appointed from a list of nominees recommended by the National Association of Counties.

Of the Members of Congress, two from each House must be of the majority party. Of the State and local officials, no more than two of each category may be from the same party. The private citizens are appointed without regard to political affiliation. Commission members serve for two years and may be reappointed. However, a member who is a public official can serve only as long as he holds the office from which he was appointed to the Commission. (Attachment A lists present members of the Commission.)

Since its establishment 15 years ago a total of 118 individuals from 42 states have served on the Commission. The eight states that have not been represented to date are Alaska, Mississippi, Montana, New Hampshire, North Dakota, Oklahoma, West Virginia and Wyoming. Overall, there has been fairly even geographical distribution among the several sections of the country. (Attachment B lists all persons who have served as members.)

The Commission has operated with a small staff throughout its 15year history. Attachment C lists the present members of the Commission staff and Attachment D shows the number of permanent positions authorized by fiscal year. Since fiscal year 1973, 37 permanent staff positions have been authorized. These include two special programs: interns and senior residents. Since fiscal year 1970, three interns have been chosen each year to work on the Commission staff for one year, to learn about intergovernmental relations while helping the staff on regular Commission projects. In fiscal year 1973, the senior resident program was added, enabling experienced university faculty and State government professionals to spend a year with the Commission, contributing their expertise as well as gaining a better understanding of the federal system.

FINANCIAL SUPPORT

From its inception, the Commission has relied primarily on congressional appropriations for its support. In fact, until 1966, the law did not permit the Commission to receive funds from non-Federal sources. In that year, following the first 5-year review the Act was amended to authorize ACIR to accept contributions from State and local governments and from nonprofit organizations.

Attachment D is a consolidated statement of obligations incurred by ACIR for fiscal years 1960 through 1974. It will be noted that funds appropriated to ACIR by Congress total $7,640,000 for the entire period. During the same 15 fiscal years ACIR has spent $744,000 that it received from other Federal agencies. These funds were made availa

ble to ACIR for specific projects and were obligated for those purposes. Attachment F lists the amounts received and describes the purposes for which they were used.

Starting in fiscal year 1968, the Commission began inviting State governments to make annual token contributions. Nine States made such contributions for 1968, 11 for fiscal year 1969, 33 for fiscal year 1970, 29 for fiscal year 1971, 24 for fiscal year 1972, and 16 for fiscal year 1973. Attachment G lists the participating States and the amounts contributed by fiscal year.

Two years later, in fiscal year 1970 the Commission invited the largest cities to make annual token contributions of $500 each. The response from the cities has been less encouraging. Attachment H lists contributing cities and the amounts received by fiscal year.

Beginning in 1974 the Commission has sought contributions from the Public Interest Groups representing states, cities and counties as an alternative to the direct solicitation on individual governments. Thus far, this approach has not yielded any income. But ACIR's requests are still under active consideration.

The Commission also receives modest amounts each year from a variety of nonprofit organizations. For the most part, this money represents contributions to ACIR in lieu of honoraria and expenses for staff members who address or participate in conferences sponsored by these organizations. Attachment I lists the amounts received from this source by fiscal year.

From October 1968, through June 1974, the Commission received a total of $266,600 from foundations in support of specific projects. Attachment J lists these grants and describes the purposes for which the funds were made available.

Contributions from State and local governments, grants from foundations, and contributions from miscellaneous nonprofit organizations are deposited in the Commission's trust fund account. During fiscal years 1968 through 1974 a total of $478,000 received from these sources had been obligated by ACIR.

For the current fiscal year, 1975, Congress has appropriated $1,075,000 for the support of the Commission's activities.

THE COMMISSION'S WORKING PROCEDURES

The Commission addresses itself to specific issues and problems, the resolution of which would produce improved cooperation among the levels of government and more effective functioning of the federal system. The Commission focuses its attention upon relationships among State governments and between States and their counties, cities, and other units of local government as well as problems of Federal-State, Federal-State-local and Federal-local relations.

Many of the studies undertaken by the Commission deal with problems resulting from rapid growth and rapid urbanization of our nation with particular attention given to identifying the proper responsibilities of each level of government and the role of new mechanisms created at regional and areawide levels; recommending the most effective use of the resources available to each level of government; and improving coordination among the levels of government. ACIR often has probed these vital structural problems by studying the functioning of specific programs and services. For example,

Commission studies over the past several years have dealt with intergovernmental problems and impact in relocation, the Office of Economic Opportunity, the operation of Medicare and Medicaid, the implementation of the Safe Streets and Crime Control Act, and the functioning of State and local criminal justice systems.

Attention also is given to the critical stresses currently being placed on traditional governmental taxing practices. Ways are sought to improve Federal, State and local coordination of tax and fiscal practices and policies to achieve equitable allocation of resources, increased efficiency in collection and administration, and reduced compliance burdens upon the taxpayers.

The Commission approaches its work pragmatically. As it considers present functions and responsibilities in light of emerging problems, the Commission attempts to frame recommendations on the merits of each case as it sees it. Depending on the circumstances, it may recommend expansion or contraction or transfer or elimination of particular functions and responsibilities among the levels of government.

The Commission also approaches its work selectively. To prevent duplication, it does not involve itself in areas presently the responsibility of other governmental commissions and advisory bodies.

The Commission works with governmental agencies, associations of public officials, the higher education community, and with private research organizations which are studying problems of intergovernmental relations. The Commission attempts to encourage and stimulate these groups to make sure that all available resources, public and private, will be effectively deployed for the solution of intergovernmental problems.

In selecting items for its work program, the Commission considers the relative importance and urgency of the problem, its manageability from the point of view of finances and staff available to ACIR, and the extent to which the Commission can make a fruitful contribution toward the solution of the problem.

Once a subject has been selected by the Commission and placed on the work program, members of the staff are assigned to the project. In a few cases, an outside expert in the field or a research organization may be retained to do some of the research. The staff's job is to assemble and analyze the facts, identify the differing points of view and develop a range of alternative policy recommendations for the Commission to consider. All of this material is developed and set forth in a preliminary draft report containing historical and factual background, analyses of the issues, and alternative solutions.

The preliminary draft is reviewed within the staff of the Commission and after revision is placed before an informal group of outside "critics" for searching review and criticism. In assembling these reviewers, care is taken to secure expert knowledge and a diversity of substantive and philosophical viewpoints. Normally, representatives of the Council of State Governments, the International City Management Association, the National Association of Counties, the National Governors' Conference, the National League of Cities, the U.S. Conference of Mayors, the Office of Management and Budget, and any other Federal agencies directly concerned with the subject matter participate along with other critics in reviewing the draft.

The draft report is then revised by the staff in light of the comments made at the critics session and is transmitted to members of

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the Commission at least three weeks in advance of the meeting at which it is to be considered. (Attachment K is a summary of actions taken by the Commission at its 50 meetings.)

Completed Studies

THE COMMISSION'S "PRODUCT"

Following the procedure outlined above, the Commission has produced a total of 47 policy reports dealing with a wide variety of intergovernmental issues ranging in scope from some more narrowly focused early studies such as "Investment of Idle Cash Balances by State and Local Governments," and "State-Federal Overlapping in Cigarette Taxes," to more recent panoramic studies such as "Substate Regionalism and the Federal System," and "Local Revenue Diversification". (Attachment L lists all ACIR publications issued to date.)

These 47 policy reports contain 366 recommendations for action divided among suggestions for Federal, State and local government. (Attachment M is a consolidated summary of Commission recommendations and actions taken on them throughout ACIR's history.) Studies in Progress

The Commission currently has five studies underway. Each is expected to yield policy positions.

Staff is presently readying two studies for submission to the Commission. They are a study on metropolitan transportation and an evaluation of Federal general revenue sharing. The transportation study probes the requirements for balanced transportation in metropolitan areas and the means to achieve it through improved intergovernmental arrangements for planning, financing, and implementation.

The evaluation of general revenue sharing looks at both funding and structure of the Federal act, as it comes up for renewal in Congress. It addresses such questions as whether revenue sharing should be renewed and on what terms; whether Congress should provide additional support for big cities; whether the State-local funding division should be modified; whether Congress should do away with the "priority expenditure areas" for which cities must use the funds; or whether it should build in a specific incentive for more intensive use of the income tax and whether the civil rights provisions of the Revnue Sharing Act should be strengthened.

The ACIR staff is in an earlier stage of research on two other studies. ACIR is investigating areas for Federal-State-local tax coordination; studying trends in Federal, State and local fiscal aids looking at the tax burden on low and middle income people resulting from the rise in social security taxes. Another research project is examining Federal grant-in-aid processes and their impact on State and local governments developing approaches to achieve better intergovernmental management of categorical and block grants.

A fifth study, conducted at the specific request of Congress concerns the application of State and local income-type taxes on out-ofState commercial banks, mutual savings banks and savings and loan associations.