One additional clerical position is requested in 1972 to cover additional workload associated with the expansion in Administration program activity.

OFFICE OF THE CHIEF COUNSEL

The Chief Counsel's staff provides legal advice and support to the Administrator including legal advice and service concerning all aspects of the motor vehicle safety enforcement programs, and directs and administers all legal services required in the operation of the National Highway Traffic Safety Administration headquarters and field offices.

Two additional professional and one clerical support position is requested in 1972 to cover anticipated increased enforcement activities including litigation relating to manufacturer defect notification and civil penalties.

OFFICE OF CIVIL RIGHTS

The Director of this Office serves as principal staff advisor to the Administrator on civil rights and equal opportunity matters, and with staff personnel, assures full and affirmative implementation of civil rights and equal opportunity precepts within the National Highway Traffic Safety Administration. The Office is also responsible for assuring that these policies are carried out by recipients of Federal assistance programs administered by NHTSA.

In addition, the Office of Civil Rights evaluates implementation by headquarters and field elements of approved policies, programs, standards and procedures.

One additional professional is requested in 1972 to manage additional contract compliance workload projected to result from the expansion in the Administration's contract compliance program to implement and enforce NHTSA's responsiblities under Title VI of the Civil Rights Act of 1964.

OFFICE OF CONSUMER AFFAIRS AND PUBLIC INFORMATION

This Office was established to advise the Administrator in the designated functional areas. The office will maintain a consumer affairs program, designed to provide information of particular interest to special consumer groups and the public at large, as well as a public information program which seeks to promote a public awareness of the importance of the Administration's highway safety programs to the United States, stressing the Nation's stake in this effort. The new office will encompass the function of the former Public Information staff. In addition, the

responsibility for preparation of the Administration's Annual Reports has been reassigned to this Office from the Associate Administrator for Planning and Programming.

In executing assigned responsibilities in the area of consumer affairs, the office will maintain liaison with Federal and State Government agencies and private consumer organizations to assure proper coordination of program undertakings with affected entities, collect and disseminate consumer information, and advise consumers of the impact of existing or proposed motor vehicle standards or other imposed highway safety policies. In the realm of public information, the Office will direct a program geared to illustrate Administration objectives and accomplishments dedicated to achieving the stated goal of improving traffic and highway safety.

One additional clerical position is requested in 1972 to correct the existing imbalance between professional and clerical positions.

ASSOCIATE ADMINISTRATOR FOR PLANNING AND PROGRAMMING

The Associate Administrator is responsible for formulation of policy and the development of long-range plans, goals, and programs for traffic and motor vehicle safety. He coordinates programs and relates them to operating requirements. He develops data and conducts analyses for decisions with respect to legislative recommendations and program planning action. He conducts program reviews and appraisals, and operates a management information center. These functions are carried out by the following program offices:

The Office of Program Planning, which is responsible for review,
analysis and evaluation of new program proposals or objectives
assigned to the Administration by the Secretary or Congress, and
development of detailed program plans for implementation.

The Office of Systems Analysis, which conducts studies to define
Administration objectives and develop broad, long-range programs
to achieve these objectives.

The Office of Program Evaluation, which provides leadership
in developing appraisals of program effectiveness and main-
tains a management information center.

Changes in requirements for personnel compensation and benefits relate directly to the proposed addition of new positions previously justified. Additional travel funds are requested to support the addition of new professional positions.

Reductions are being made in 1972 in the various contractual items included in the Executive Direction activity in order to help finance increases proposed in other areas of the budget.

COMMITTEE ON CHALLENGES OF MODERN SOCIETY (CCMS) $300

$200

Decrease -$100

NHTSA provides, in cooperation with member nations of the North Atlantic Council (NATO), a pilot study on highway safety to: exchange information on highway safety decision-making practices and experiences; to further the application of modern technology to selected areas of road safety and to aid each member nation to upgrade its road safety program with optimum use of available resources.

CENSUS CODING GUIDE

1971
$50

1972

-0

Decrease -$50

Provides Administration participation in a Bureau of Census Coding Improving Guide Program which by use of a geo-coding method, enhances the flexibility in geographic aggregations of data and ensure geographic compatibility in Federal-State-local data through use of standard address coding methods.

COST AND COST EFFECTIVENESS

1971
$130

1972
$100

Decrease -$30

The objective of cost effectiveness studies is to quantify the relative costs and benefits attributable to motor vehicle and highway safety programs.

ALLOCATION OF 1971 POSITIONS

Mr. McFALL. The committee reduced your total fiscal 1971 requests for new personnel by about 50 percent. It appears, however, that none of the reduction was applied to program direction and coordination. What was the basis for this determination?

Mr. Toмs. Mr. Chairman, one of the constant problems is attempting to reorganize people into line functions. The Deputy Administrator and I have always felt there were too many people reporting directly to the Administrator's office. We are constantly trying to decrease this and get these people better organized or located within the agency. I think that on some of these things, such as civil rights, we have no choice. Of course Chief Counsel too. But there are other activities that take place within the Office of Administrator where we feel perhaps we can better locate them within the line programs. Mr. McFALL. How many of your presently authorized 88 positions are filled in this section?

Mr. SCOTT. Seventy seven.

JUSTIFICATION OF 1972 INCREASE

Mr. McFALL. What is the basis for your requested increase of six positions for this activity?

Mr. Toмs. One of them is in the executive secretariat. One of our big problems is like the 20,000 letters that came in on speed controls, attempting to handle these letters. The more we do in the consumer field the more mail we get. This has been a big problem to us. So we feel that we need an extra person there just to physically route these letters for answering.

We are asking for three people in the Office of the Chief Counsel. The more we do in regulating the automobile industry the more actions are brought to bear. We have litigation underway all over the country. For example, if this passive restraint rule goes into effect, we will be pursuing litigation in most of the district courts in the United States perhaps. There has been a tremendous increase in this amount of business, trying to enforce the motor vehicle laws. We feel that we need at least three people in the Chief Counsel's office.

This increased activity has caused us to have a greater need in the civil rights area, particularly to monitor the contracts and make sure the contractors are hiring minorities as they should and that there is no discrimination in these contract fields.

In the Office of Consumer Affairs and Public Information again we keep one man busy just answering Ralph Nader's question. As more and more consumer groups are getting into this field, we are just finding it more and more difficult to be responsive to them. So that accounts for your six positions, Mr. Chairman.

Mr. McFALL. One of these additional positions, as you have outlined, is for the Office of Consumer Affairs and Public Information? Mr. Toмs. Yes.

SIMILAR FUNCTION IN OST

Mr. McFALL. Last year the Secretary established an Assistant Secretary for Safety and Consumer Affairs.

Mr. Toмs. That is correct.

Mr. McFALL. Why do you need a separate office for this function? Mr. Toмs. I think I can provide a good reason for this. Will Smith. who is our Assistant Secretary for Consumer Affairs, runs the broad gamut for airplanes, cars, railroads, boats and everything that relates to the consumer in the agency or in the DOT. He attempts to make sure that the consumers' interest is represented among all the operating modes. But when you get into our agency, the National Highway Traffic Safety Administration, we deal specifically in the details of cars. Most of our inquiries are about wheels and brake hoses and muffler systems and air bags and this sort of thing. The people up in Will Smith's office haven't this technical exposure. Our areas have shown a great increase in interest.

Mr. McFALL. That is an illuminating answer, because it would appear that each one of these divisions is going to have an Office of Consumer Affairs as well as an Assistant Secretary for Consumer Affairs. It seems to me there is some duplication here.

SPECIAL CONSUMER NEEDS

Mr. Toмs. I think that the real explanation is that this whole consumerism as a move has really expanded and put unusual pressures on us. I can say categorically that 2 years ago, when I first came here, there was nowheres near the interest in consumerism that there is today.

For example, 2 years ago, Walker Sandbach's organization, Consumers Union, really didn't monitor what we were doing very much. Now, not only do they monitor what we are doing by sending their engineers in to see our people, but they are actually writing about us on literally every issue. They make referrals to us, and they are encouraging people to write in for information. We are just very severely burdened in trying to respond. There are a lot of letters to answer and a lot of telephone calls to take and a lot of people who are coming into the building with consumer type questions. Somebody has to sit down and talk to them.

In the railroad field, since Railpax and Amtrak, I know my colleague, Carl Lyons, is under some of these same kinds of pressures. I know the same is also true in the aviation industry.

I guess we have to recognize that there is a consumerism movement nationwide, and we are feeling the pinch from it.

Whether it will taper off in the years to come, I don't know. I know right now it poses a real burden to us.

Mr. CONTE. Mr. Chairman, speaking of consumerism, do you think the consumer is going to buy that tank you showed us in the moving pictures?

Mr. Toмs. I think that in the actual analysis, Mr. Conte, that the auto industry will probably style it more effectively after the experimental phase has been completed.

Mr. CONTE. It will have to, because it is an ugly looking car. You mentioned this morning about Chrysler coming out with that rolled front. That was in the thirties, I believe.

Mr. Toмs. Yes.

Mr. CONTE. That was dropped like a hot potato. Would you summarize what the increased executive coordination requirements are that necessitate the moderate staff increase you are requesting?