Section 2 of the act of Congress known as the Reorganization Act of 1945 (known as Public Law 263, 79th Cong.) requires the President from time to time to reexamine the organization of all agencies of the Government and to determine what changes therein are necessary to accomplish the six purposes stated in the act which included, inter alia, to reduce expenditures and to promote economy to the fullest extent consistent with the efficient operation of the Government and to increase the efficiency of the operations of the Government to the fullest extent practicable within the revenues.

It is evident from a reading of the act that Congress intended that the President should reexamine the organization of all the executive agencies of the Government so that the expenses of administration should be reduced without affecting the administrative efficiency of such agencies, and as stated in 4 (c) of section 2 of the act, it was the expectation of Congress that the transfers, consolidations, coordinations, and abolitions made by the President under this act should accomplish an over-all reduction of at least 25 percent in the administrative cost of the agency or agencies affected.

This brief is to be restricted to that part of plans 1, 2, and 3 which suggest the permanent transfer of the administration of the functions of the Bureau of Marine Inspection and Navigation of merchant vessels to the United States Coast Guard.

Under plan 3, page 2, of the President's message under the heading "United States Coast Guard," the plan is to transfer permanently the functions of this Bureau, including inspection of vessels and their equipment, the licensing and certificating of officers and seamen, and related functions designed to safeguard life and property at sea to the Coast Guard. Furthermore, page 8, part I, section 101, it is planned to transfer permanently to the Coast Guard the functions of the Bureau now in the Commerce Department in connection with the construction, repair and alteration of vessels, approval of material, equipment, appliances, classification of vessels, and inspection of vessels and their equipment together with licensing and certification of officers and crew, suspension and revocation of such licenses, and investigation of marine casualties including the promulgation and enforcement of rules as to lights, signals, speed, steering, sailing, passing, anchorage, movement, and towlines of vessels and lights and signals on bridges.

This brief is directed in objection to such a plan of transfer for the following

reasons:

The purpose of the Reorganization Act is to reduce the expenses of administration of governmental agencies by at least 25 percent has not been and cannot be promoted by having the foregoing functions administered by the Coast Guard, nor is the efficient administration of such functions promoted by such transfer. 1. Since this Bureau has been under the Coast Guard its personnel has been greatly increased in number so that the number of personnel is much greater in all the local offices of the Bureau than there was in peacetime, there being about 20 additional persons in the Philadelphia office, approximately 25 additional in Baltimore, 15 in Norfolk. 34 in Mobile, where they have 34 inspectors and 12 clerks when in peacetime there were 16 inspectors and 4 or 5 clerks; in New Orleans there are 43 inspectors and 18 clerks; in Port Arthur there are 14 inspectors and 8 clerks, where they formerly had 6 inspectors and 3 clerks; in Houston, Tex., there are now 14 inspectors and 10 clerks. In Galveston there are 22 inspectors and 14 clerks, whereas in peacetime under the Department of Commerce from Lake Charles, La., to the Rio Grande district there were 8 inspectors and 4 clerks.

Furthermore, under the Coast Guard the Bureau has been loaded up with a lot of inexperienced personnel, many of them graduates of the United States Coast Guard Academy, who had no experience whatsoever on merchant-marine vessels. An inspection of the personnel would also show that the present personnel of this Bureau now under the Coast Guard, if it were returned to the Department of Commerce and made a civilian bureau, could be reduced approximately 30 percent in number and its duties properly performed by experienced personnel. Prior to February 28, 1942, when the Bureau was under the Department of Commerce, the inspectors of the Bureau were experienced masters and chief engineers of merchant vessels who were thoroughly acquainted with the requirements of vessels for their safe operation, but since the Coast Guard has taken over the Bureau many of these inspectors are absolutely unqualified either by experience or knowledge.

2. While the Bureau was a civilian agency under the Department of Commerce, the various local inspectors were not only required to have had long experience at sea on merchant vessels in order to qualify themselves to even take a civil-service examination, but in order to make themselves eligible for appointment as inspectors they were required to pass a strict civil-service examination. These absolutely necessary requirements have been abolished since the United States Coast Guard took over the Bureau.

3. As a civilian agency under the Department of Commerce, this Bureau intelligently and efficiently investigated marine accidents and disasters but under the Coast Guard such is not true. Under the Department of Commerce the same was true of the trials of licensed officers for violation of their licenses but now these trials are conducted by Coast Guard officers with no proper experience to act as quasi-judicial bodies; the hearings are conducted by young officers with practically no sea experience and none whatever on merchant vessels, and such Coast Guard officers act not only as prosecutor but as judges with the unfortunate but natural result that a great number of petty charges are preferred against licensed officers and unjust and unreasonable punishment inflicted upon them. The further result is a large and unnecessary expense to the

United States Government in the waste of time of its personnel.

4. While this agency was a civilian Bureau under the Department of Commerce, the examinations of the officers of vessels for licenses or increase of their licenses were conducted by experienced local inspectors. Under the Coast Guard both the questions and answers submitted to the candidates for examination are prepared in Washington and sent to the various Bureau officers and where it formerly took two inspectors with experience in each local office to conduct such examinations, it now takes five to six men in these offices to do the same work. This necessarily results in a waste of time and a waste of the Government's money.

Under plan 3, part I, Department of the Treasury, section 101, it is planned to give the Coast Guard the functions of approval of plans for construction, repair, and alteration of vessels; approval of materials, equipment, and appliances, including classification of vessels; issuance of certificates of inspection and permits for vessels for operations which may be hazardous to life and property. Some months ago the United States Coast Guard announced that it was its intention to transfer these functions to the American Bureau of Shipping which is a classification society similar to British Lloyd's. This in itself was a confession that United States Coast Guard did not have sufficient competent, experienced merchant-vessel officers in its personnel who were qualified for such duties. And yet, although the Coast Guard admitted that it could not for that reason perform these functions, it planned to transfer them to this private corporation, American Bureau of Shipping, retaining supervision. Surely, if the Coast Guard did not have enough competent men in its personnel to perform the duties, it did not have enough competent men to supervise the work of this private corporation. Furthermore, many of these vessels to which these functions apply, were not classified vessels. Many of them were tugs, barges, and other small nondescript water craft. This American Bureau of Shipping, being a private corporation, was conducted for the purpose of making a profit and the expense of the services rendered by it must be borne by the United States Government since the Coast Guard plan to delegate the performance of its duty to that corporation. This, of course, results in further needless expense to the United States Government and in turn defeats the purpose of the Reorganization Act.

5. Our merchant marine has always been civilian owned, navigated, and operated, but since the Bureau of Marine Inspection and Navigation has been under the Coast Guard, every effort has been made to make our merchant marine a military or naval organization. The result has been a consistent friction between American vessel owners and American ship officers, who naturally resent being ordered and directed by inexperienced and unqualified Coast Guard personnel and in having their vessels inspected by Coast Guard personnel who are not qualified for that duty because of their lack of experience in navigation and operation of vessels. As a civilian agency under the Department of Commerce, these inspectors because of their wide experience, knew what was required to be done to make our merchant marine fit and seaworthy, and used sound, intelligent judgment. The Coast Guard personnel having no such qualifications are unable to do so.

6. From an economical viewpoint, and that is one of the important viewpoints to be taken under this Reorganization Act, the expense of the administration of this, Bureau by the Coast Guard since February 28, 1942, has been much greater than in the administration of the Bureau under the Department of Commerce. Surely, under the provisions of the Reorganization Act of 1945, it is in itself convincing that the Bureau should be a civilian agency under the Department of Commerce.

In this connection, attention is called to the fact that prior to World War II the United States Coast Guard had one rear admiral. Now they require a full admiral, a number of other admirals, a number of commodores; and where they had 26 captains before World War II, they now have over 100 captains.

7. Since it has been demonstrated that the Coast Guard has not and cannot properly administer the functions of this Bureau, the question naturally arises Why does the Coast Guard want this power of administration? Is it anything more than a grab or reaching out for more power on the part of the United States Coast Guard? Of course, these questions are immaterial in that it has been demonstrated that the transfer of the functions of this Bureau of Marine Inspection and Navigation to the Coast Guard means vastly increased expenses and therefore defeats the whole purpose announced by Congress for the passage of the Reorganization Act of 1945.

Borrowing a suggestion from Representative William A. Pittenger made to your committee at the hearing on June 6, 1946, it is suggested that your committee summon before it the experienced local inspectors of the various local inspection districts, who have done the work of administration of this Bureau during the regime of the Department of Commerce and also that of the Coast Guard, and the true facts as stated in this brief will be fully demonstrated to your committee.

For the foregoing reasons it is therefore respectfully suggested to the committee that the transfer of the administration of the Bureau of Marine Inspection and Navigation should not be given to the United States Coast Guard, but, on the contrary, it should be returned to the Department of Commerce where for so many years it was economically, efficiently and satisfactorily admiinstered.

Respectfully submitted.

VESSEL OWNERS' AND CAPTAINS' ASSOCIATION
OF PHILADELPHIA,

By HERMAN M. LONG, Solicitor.

STATEMENT SUBMITTED BY LEAGUE OF WOMEN VOTERS, WASHINGTON, D. C., To THE HOUSE COMMITTEE ON EXPENDITURES IN THE EXECUTIVE DEPARTMENTS ON THE PRESIDENT'S REORGANIZATION PLAN I

The League of Women Voters has for many years been concerned with government in the public interest. We are perhaps the only one of the national women's organizations which has studied and become familiar with principles of public administration, and we have followed with special interest the field of housing and its adminstration.

We believe that the National Housing Agency created in February 1942 was absolutely essential in order to coordinate the activities of the 17 different agencies which had been dealing with housing problems at the start of the war. Up to this time there had been frictions and competition which seriously weakened the effectiveness of the total program. Housing is a national problem, and it is important that a unified approach be made to its solution. Each of the functions of the 17 agencies, while varying in their emphasis, had as their objective the improvement of the American housing situation. The coordination made it possible for all the housing policies of the Federal Government to form a pattern for the orderly achievement of this objective. The National Housing Agency exists for the duration of the emergency only. Unless legislation makes it permanent, the gains which unification has made possible will be discontinued.

Opponents of Federal housing functions have opposed the establishment of NHA as a single housing agency because they fear it will strengthen public housing at the expense of private housing. This issue should not be confused with the administration of housing.

It is the Congress which determines the decisive policies about housing through the enactment of legislation and the appropriation of money. It is the Housing Agency which should carry out and administer those policies. The advantage both to Congress and to the Executive of having one agency which can be held responsible is very great. One agency is also more comprehensible to the citizen than an assortment of agencies. The League believes the administration of housing should not be returned to the confusion, overlapping, and antagonisms which result from competing agencies.

Hon. CARTER MANASCO,

AMERICAN FEDERATION OF LABOR,
Washington 1, D. C., May 23, 1946.

Chairman, Committee on Expenditures in the Executive Departments,

House of Representatives, Washington, D. C.

MY DEAR CONGRESSMAN: The executive council of the American Federation of Labor considered Reorganization Plan No. 2, and expressed disappointment and great regret that the recommendations continue the dismemberment of the Department of Labor begun by the reorganization plan of 1939. We had sincerely hoped that instead of dismembering the Department of Labor, that it would be strengthened and expanded and made a basic Government service paralleling the service given to farmers and employers by their respective departments.

The Department of Labor should, in fact, be broad enough to promote the welfare of all citizens, directly and indirectly. Wage earners, with their dependents, as you know, constitute at least 80 percent of the population. The Children's Bureau and the Office of Education primarily serve the wage earners of the country and other citizens only indirectly. It would be well if, instead of building up a welfare department, all of these labor and welfare services were integrated in the Department of Labor, with policies formulated to improve the economic and social environment of wage earners and their families.

The executive council adopted a statement proposing that present agencies be retained within the Department of Labor and to add social insurance and all other Government services which are the immediate concern of wage earners, making possible integrated administration to improve labor conditions and relations as well as the welfare of wage earners and small salaried persons. Copy of these recommendations are enclosed herein.

Sincerely yours,

WM. GREEN,

President, American Federation of Labor.

STATEMENT ADOPTED BY THE EXECUTIVE COUNCIL OF THE AMERICAN FEDERATION OF LABOR, WASHINGTON, D. C., MAY 22, 1946

REORGANIZATION PLAN NO. 2 OF 1946

This plan makes the Federal Security Agency an executive department. It is understood the Agency will be headed by a Cabinet member. The basic purpose of the Agency is the conservation and development of the human resources of the Nation, with these principal functions: child care and development, education, health, social insurance, welfare (care for the needy and defective) and recreation.

The Federal Security Agency created in 1939 includes:

United States Public Health Service

Office of Education

Social Security Board

Federal Advisory Board for Vocational Education

Office of Vocational Rehabilitation

Food and Drug Administration

Columbia Institute for the Deaf

American Printing House for the Blind

Freedmen's Hospital

St. Elizabeths Hospital

Howard University

6. From an economical viewpoint, and that is one of the important viewpoints to be taken under this Reorganization Act, the expense of the administration of this, Bureau by the Coast Guard since February 28, 1942, has been much greater than in the administration of the Bureau under the Department of Commerce. Surely, under the provisions of the Reorganization Act of 1945, it is in itself convincing that the Bureau should be a civilian agency under the Department of Commerce.

In this connection, attention is called to the fact that prior to World War II the United States Coast Guard had one rear admiral. Now they require a full admiral, a number of other admirals, a number of commodores; and where they had 26 captains before World War II, they now have over 100 captains.

7. Since it has been demonstrated that the Coast Guard has not and cannot properly administer the functions of this Bureau, the question naturally arises Why does the Coast Guard want this power of administration? Is it anything more than a grab or reaching out for more power on the part of the United States Coast Guard? Of course, these questions are immaterial in that it has been demonstrated that the transfer of the functions of this Bureau of Marine Inspection and Navigation to the Coast Guard means vastly increased expenses and therefore defeats the whole purpose announced by Congress for the passage of the Reorganization Act of 1945.

Borrowing a suggestion from Representative William A. Pittenger made to your committee at the hearing on June 6, 1946, it is suggested that your committee summon before it the experienced local inspectors of the various local inspection districts, who have done the work of administration of this Bureau during the regime of the Department of Commerce and also that of the Coast Guard, and the true facts as stated in this brief will be fully demonstrated to your committee.

For the foregoing reasons it is therefore respectfully suggested to the committee that the transfer of the administration of the Bureau of Marine Inspection and Navigation should not be given to the United States Coast Guard, but, on the contrary, it should be returned to the Department of Commerce where for so many years it was economically, efficiently and satisfactorily admiinstered.

Respectfully submitted.

VESSEL OWNERS' AND CAPTAINS' ASSOCIATION

OF PHILADELPHIA,

By HERMAN M. LONG, Solicitor.

STATEMENT SUBMITTED BY LEAGUE OF WOMEN VOTERS, WASHINGTON, D. C., ΤΟ THE HOUSE COMMITTEE ON EXPENDITURES IN THE EXECUTIVE DEPARTMENTS ON THE PRESIDENT'S REORGANIZATION PLAN I

The League of Women Voters has for many years been concerned with government in the public interest. We are perhaps the only one of the national women's organizations which has studied and become familiar with principles of public administration, and we have followed with special interest the field of housing and its adminstration.

We believe that the National Housing Agency created in February 1942 was absolutely essential in order to coordinate the activities of the 17 different agencies which had been dealing with housing problems at the start of the war. Up to this time there had been frictions and competition which seriously weakened the effectiveness of the total program. Housing is a national problem, and it is important that a unified approach be made to its solution. Each of the functions of the 17 agencies, while varying in their emphasis, had as their objective the improvement of the American housing situation. The coordination made it possible for all the housing policies of the Federal Government to form a pattern for the orderly achievement of this objective. The National Housing Agency exists for the duration of the emergency only. Unless legislation makes it permanent, the gains which unification has made possible will be discontinued.

Opponents of Federal housing functions have opposed the establishment of NHA as a single housing agency because they fear it will strengthen public housing at the expense of private housing. This issue should not be confused with the administration of housing.