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Regulatory Agencies - General (2)
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Regulatory Agencies - General (2)
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Philip W. Buchen Files
Philip Buchen's General Subject Files
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Civil Aeronautics Board. (06/30/1940 - 01/01/1985)
Affirmative action programs
Government regulation
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The original documents are located in Box 59, folder "Regulatory Agencies - General (2)"
of the Philip Buchen Files at the Gerald R. Ford Presidential Library.
Copyright Notice
The copyright law of the United States (Title 17, United States Code) governs the making of
photocopies or other reproductions of copyrighted material. Gerald R. Ford donated to the United
States of America his copyrights in all of his unpublished writings in National Archives collections.
Works prepared by U.S. Government employees as part of their official duties are in the public
domain. The copyrights to materials written by other individuals or organizations are presumed to
remain with them. If you think any of the information displayed in the PDF is subject to a valid
copyright claim, please contact the Gerald R. Ford Presidential Library.
Digitized from Box 59 of the Philip Buchen Files at the Gerald R. Ford Presidential Library
THE WHITE HOUSE
Regulatory
WASHINGTON
January 7, 1975
MEMORANDUM FOR PHILIP W. BUCHEN
FROM:
WILLIAM N. WALKER Jull
SUBJECT:
Announcement of Betty Southard Murphy
as Chairman, NLRB
On January 3, 1975, The President approved the nomination of
Betty Southard Murphy as Chairman of the National Labor
Relations Board.
Betty Murphy's most recent FBI full field investigation was
completed in April 1974; an up date is in process. A
special clearance was ordered on January 6. Her conflicts
of interest clearance is complete.
The decision memorandum to the President proposed prompt
announcement of the intention to nominate Mrs. Murphy in
order to prevent the labor-management consensus on her
nomination from unraveling.
This memorandum requests your approval of a waiver of
pending clearances only for the purpose of an early an-
nouncement of an intention to nominate. All clearances will
be final before the nomination is made.
I grant the waiver of final clearances for purposes of
announcement.
Philip PhilypluBuden W. Buchen
Buchen
R. FORD LIBRARY
BIOGRAPHY
BETTY SOUTHARD MURPHY
ADMINISTRATOR, WAGE AND HOUR DIVISION
DEPARTMENT OF LABOR
Betty Southard Murphy, a labor lawyer with a nationwide
reputation, was sworn in as Administrator of the Wage and
Hour Division, on July 15, 1974.
As Administrator, Mrs. Murphy supervises the Department's
responsibilities under some 70 different labor laws including
the Fair Labor Standards Act, which includes minimum wage
provisions affecting 56 million workers, the Equal Pay Act,
which requires men and women receive equal pay for equal work,
the Age Discrimination in Employment Act, which prohibits
discriminatory employment practices based on age, the Walsh-
Healey Public Contracts Act, the Davis-Bacon Act, the Service
Contract Act, the Farm Labor Contractor Registration Act, and
a number of other labor laws. She oversees a $37 million
budget and over 1,500 employees.
Before accepting this appointment, Mrs. Murphy was a partner
in the Washington, D. C. law firm of Wilson, Woods and Villalon
where she specialized in labor, corporate and administrative
law. She is one of the few lawyers in the United States who
represented both international unions and employers.
In private practice, Mrs. Murphy was an active trial lawyer
and tried cases or appeared in Federal or State Courts in
19 different States and argued in 9 of the 11 United States
Courts of Appeals.
Mrs. Murphy began her career as a reporter--first as corre-
spondent and free lance journalist in Europe and Asia and
later with United Press (now UPI). After graduating from
law school, she was an enforcement attorney with the National
Labor Relations Board during 1958-1959.
Mrs. Murphy--the first woman to be named Administrator--is
a Trustee of the American University, is on the National
Board of the Medical College of Pennsylvania, and is Chair-
man of the Board of Visitors of Mary Baldwin College.
BERALD FORD
2.
Her concern with civil rights and equal employment oppor-
tunity for workers is well established. She has been
active as Chairman of the District of Columbia Bar Associa-
tion's Civil Rights Committee, and the Fair Employment
Practices Committee; the Federal Bar Association's Committee
on Equal Employment Opportunity and Collective Bargaining;
the Women's Bar Association's Committee on the Status of
Women; and is also Vice Chairman of the Labor Law Committee,
Administrative Law Section, American Bar Association.
She received a B.A. degree (oriental studies) from the Ohio
State University and also studied in Paris at the Sorbonne
and the Alliance Francaise. She obtained her J.D. degree
in 1958 from the American University Washington College of
Law.
Mrs. Murphy and her husband, Dr. Cornelius F. Murphy, a
Radiologist, reside in Annandale, Virginia, with their two
children, Ann, 6, and Neil, 5.
SERVICE FORD LIBRARY
Regulatory arms
Control
Desarmont
byency
January 22, 1975
Bob
MEMORANDUM FOR: Bill Walker
FROM:
Phil Buchen
SUBJECT:
Disarmament Agency
I have had an inquiry from a friend of mine who works
there about the appointment of a Director. He
recommends promotion of John Layman, despite his
prior difficulty with Senator Fulbright.
PWBuchen:ed
n FORD LIBRARY
Regulatory
US arms
Controlx
THE WHITE HOUSE
Disarmament
WASHINGTON
Phil A
1/24/95 agency
Would you have
time please to
review of comment
for US.
P.
SERA THE FORD LIBRARY
MEMORANDUM
0483
NATIONAL SECURITY COUNCIL
January 24, 1975
MEMORANDUM FOR:
PHILIP BUCHEN
FROM:
Jeanne W. Davis
SUBJECT:
ACDA's 1974 Annual
Report to Congress
Attached is ACDA's Annual Report to Congress for calendar year
1974, together with a suggested Presidential letter of transmittal.
Section 50 of the Arms Control and Disarmament Act requires the
annual report and also requires that it be transmitted to the
Congress by the President.
The Report is due on the Hill by January 31. In order to allow time
for further processing, may we please have your concurrence
and/or comments by c.o.b. Tuesday, January 28.
Attachment
FORD & LIBRARY SERVICE
UNITED STATES ARMS CONTROL AND DISARMAMENT AGENCY
WASHINGTON
OFFICE OF
January 22, 1975
THE DIRECTOR
Mr. President:
I submit for your transmittal to the Congress,
as required by the Arms Control and Disarmament
Act, as amended, the fourteenth annual report of
the U.S. Arms Control and Disarmament Agency. This
report covers the work of the Agency during calen-
dar year 1974.
Respectfully,
Feed C. Ikle
Fred C. Ikle
The President
The White House
GERALD R. FORD DEBRARY
Regulatory
againstes
January 24, 1975
Dear Lew:
It was no trouble at all to get this
photograph signed by the President.
I join him in extending very best wishes
to you. I remain very proud of your
accomplishments and of the high regard
in which you are held by people who know
your work.
Sincerely yours,
Philip W. Buchen
Counsel to the President
The Honorable Lewis A. Engman
Chairman
Federal Trade Commission
Washington, D. C.
PWBuchen:ed
BERALD R. FORD
NO RALTRADE-CU UNITED STATE
FEDERAL TRADE COMMISSION
MCMXV*1
WASHINGTON
OFFICE OF
THE CHAIRMAN
January 10, 1975
Dear Phil:
I hate to bother you with extra work, but
I wonder if you would be kind enough to ask
the President to autograph the enclosed
picture sometime at his convenience,
With warmest wishes to you and Bunnie for
a successful and Happy New Year.
Sincerely yours,
Enclosure
Lewis A. Engman
The Honorable
Philip W. Buchen
Counsel to the President
The White House
Washington, D.C. 20500
FORD a LIBRARY 03
Regulatory
agencies
THE WHITE HOUSE
WASHINGTON
SL/E/2
PhilA:
Would oppreciate
your homothing this
P.
FORD as LISA LIBRARY SERVICE ARY
THE WHITE HOUSE
WASHINGTON
February 3, 1975
MEMORANDUM FOR PHIL BUCHEN
SUBJECT:
Letter to Regulatory Agencies
Attached is a proposed draft letter from Ken Cole to the heads of regulatory
agencies mentioned in volumes I and II of the U.S. Commission on Civil Rights
report - "The Federal Civil Rights Enforcement Effort - 1974. If There are three
more volumes yet to be published.
We feel it is important that the President ask for Federal agency responses and
accept regulatory agency comments if they wish to offer them. I'd appreciate
your comments on the course of action and the draft attached. Thank you.
A Lyn Z
F. Lynn May
Attachment
is. FORD LIBRARY
DRAFT
THE WHITE HOUSE
WASHINGTON
Dear Mr. Chairman:
The U.S. Commission on Civil Rights recently transmitted to President
Ford Vol. I of its study, "The Federal Civil Rights Enforcement Effort -
1974. 11 This publication evaluates the civil rights activities of the
following regulatory agencies: the Federal Communications Commission,
the Interstate Commerce Commission, the Civil Aeronautics Board, the
Federal Power Commission and the Securities and Exchange Commission.
In the process of informing the President about the total report, we would
be happy to include your comments, if you wish to submit them.
Sincerely,
Kenneth R. Cole, Jr.
Assistant to the President
for Domestic Affairs
The Honorable George M. Stafford
Chairman
Interstate Commerce Commission
in
TORD
12th & Constitution, N.W.
Washington, D.C. 20423
Regulatory
CAB
THE WHITE HOUSE
WASHINGTON
February 8, 1975
Dear Jim:
This is a belated acknowledgement of your letter
of December 18th.
I very much appreciated hearing from you and
receiving news about your family. I congratulate
you on your service for 35 years in the Presbyterian
pastorate.
I noted your comments about Bob Timm but to the
extent our office has been involved in this matter,
it would be inappropriate for me to comment.
I do send my very best wishes to you and your wife
Janet.
Sincerely,
They Philip W. Buchen
Counsel to the President
Mr. James E. Hanson
1718 Aurora
Tacoma, Washington 98465
BE GERALD
FORD i LIBRARY
REAL ESTATE
MORTGAGE LOANS
APPRAISAL SERVICE
INSURANCE
PROPERTY MANAGEMENT
F.H.A. APPROVED MORTGAGEE
MAIN OFFICE: 1001 PACIFIC AVENUE - TACOMA, WASHINGTON
3
WESTGATE NORTH END BRANCH
SK 2-6696
5738 NORTH 26th STREET
ESTABLISHED 1888
TACOMA, WASHINGTON 98407
December 18, 1974
Mr. Philip Buchen
The White House
Washington, D.C.
GENAL 18. FORD LIBRARY
Dear Philip;
I have intended to write you for some time to express my congratulations
to you in your position of trust and responsibility as Chief White House
Counsel. It has been very interesting to follow your activities in the
news, and especially to catch up on the news concerning your family through
the pictures and write-up in September "Peoples Magazine". It was interest-
ing to see in that feature a number of photos that we have in the faily album.
We have all enjoyed a great deal of pride and satisfaction in your remarkable
attainments and in the very nice things that are said about you. I can
readily understand how this could be, as my dear mother, your late Aunt
Eleanore was a very remarkable and wonderful person.
Perhaps you have heard, but my older brother Lee died in a plane crash in
Texas this past May. He was a pilot and flew for an oil company out of Odessa.
Dave and his family have lived for some years in Kansas City where he is an
official with Camobell Soup Company. Paul is in real estate in Victoria, B.C.
Art has done remarkably well in the grocery business, mostly in the buying
and selling of stores in various parts of the country. I believe he is
presently taking some special courses in merchandising atrthe University of
Michigan. Elizabeth took an early retirement from her work as a public
school teacher due to her arthritis, but remains active and is very precious
to all of us as our only sister. She has lived in Billings Montana for years.
She kept up a correspondence with your mother until shortly before her passing.
In June of this year I completed thirty five years in the Presbyterian past-
orate. I am at present on sabbatical and trying my hand at real estate. If
this works out, I may continue, otherwise our plans are to return to the work
of the church about next June.
I have been particularly interested to note that you have an interest in
theology and that you have been concerned with the theological implications
of the Nixon pardon. It would be very interesting to share our views on this
at some time. It seems that our conclusions in this area are nearly identicle,
though yours appear to have been arrived at from the viewpoint of Humanism and
mine from the viewpoint of Reformed Theology. Perhaps it is that the circle
meets at the top and that the search for a oure humanism arrives ultimately at
the Perfect Human, and then to understand that perfection we are left with no
more plausible explanation then the biblical statement of St. Paul to the
Colossians (2:9-10) that, "In Him dwells all the fulness of the Godhead bodily.'
To me it is so satisfying to accept the fact that the invisible God should see
fit to come to His creatures in human form, that we might know exactly what He
is like, and that any time we wonder what He is like, we may need but look at
the magnificent Christ. But enough of this for now! It would be so great to
share some of our searching in these areas, and perhaps to find that though per-
positions. suing different theological routes, we have arrived at very close to the same
Philip, there is one matter which I wish to mention that came to my attention
in the WALL STREET JOURNAL of this Tuesday, December 17 concerning my good friend
Bob Timm, Chairman of the Civil Aeronautics Board. (Clipping enclosed). Bob is
a great and wonderful guy and one of the bright hopes for our Republican Party
here in the State of Washington. Though I realize you may have no contact what-
soever with this situation, I am hoping that he will not be relieved of the CAB
chairmanship under the inuendos of the Nadar attack as this would seem to confirm
in the minds of many that there was actual wrong-doing. I hate to see opposition
policies eliminating good men from our ranks by placing us on the defensive
regarding them. I am hoping that the same compassion that ruled in regard to
the Nixon pardon will rule in the preserving of the reputation of a solid and
good man like Mr. Timm. If it takes "guts" for Mr. Ford to reappoint him, I
have every assurance that Mr. Timm will be reappointed.
If the course of your responsibilities ever brings you out this way, we would be
holiday season.
so happy to meet you. My wife Janet and I join in wishing you and Bunny a happy
Your Jim Cousin,
James E. Hanson
1718 Aurora
Tacoma, Washington 98455
R. FORD LIBRARY
youck
THE WHITE HOUSE
WASHINGTON
February 14, 1975
MEMORANDUM FOR:
JACK MARSH
RUSS ROURKE
FROM:
PHILIP BUCHEN T.W.B
In response to the request by the Robert Taft
Institute of Government that you contact
Dr. Ron Berman, Chairman of the Council for the
National Endowment for the Humanities, I recom-
mend against your doing so. The Endowment is
supplied with Federal funds and we have a policy
in the White House against contacts with procure-
ment agencies in regard to the award of contracts.
The situation in the present case is akin to an
opinion. award of contract for procurement purposes in my
FORD of LIBRARY
THE WHITE HOUSE
WASHINGTON
February 3, 1975
MEMORANDUM TO:
JACK MARSH
FROM:
RUSS ROURKE R
Jack, Art Peterson is asking for your assistance in connection
with a financial assistance proposal that the Robert Taft Institute
of Government has submitted to the Education Division of the
National Endowment for the Humanities. Specifically, he is
suggesting that you write directly to Dr. Ron Berman, Chairman
of the Endowment's Council in support of their proposal. Please
advise whether you think such a letter from the White House is
appropriate. Even though this organization is non-partisan, it
is in competition with many other similar organizations for funding
assistance.
R-
I Ques whether such a
is againsticate, are wanted this
th is what I thought he from
there same policy can cite
Is Coursel of in down? we a. FORD
Gen to Apt. a turn m
SEAL LIBRARY
THE ROBERT A. TAFT
Institute of Government
TRUSTEES
Mrs. Preston Davie
Chairman
420 Lexington Avenue, New York, New York 10017
212 MU 4-0877
Lowell Wadmond
Vice Chairman
Jeremiah Milbank
Treasurer
January 23, 1975
Ross Reid
JAN 24 1975
Secretary
Mr. John Marsh
Hon. George Bush
Councilor to the President
Erwin D. Canham
Reed Coleman
The White House
SERIAL FORD LIBRARY
Marion J. Epley, III
Dr. Alexander Heard
Washington, D. C. 20500
Hon. Frank Pace, Jr.
Dr. Arthur L. Peterson
Dear Jack:
William Wood Prince
Dr. Louis T. Rader
Richard M. Scaife
W. Clement Stone
I appreciated very much your kind help in getting some Ohio business-
Hon. Robert S. Strauss
men involved in "The Economic Conference" some months ago. Now
W. Allen Wallis
comes another request for help, this time on an educational matter.
David K. Wilson
Honorary
Mrs. Helen Taft Manning
You may recall much of our discussion at Doc Head's "retreat"
EXECUTIVE DIRECTOR
turned on the question of a declining political trust and sense of
Marilyn Chelstrom
political efficacy in America. Discussions at any local barber
EDUCATION COMMITTEE
shop, as well as all the popular polls, tell us that in both in-
W. Allen Wallis
stances (trust and efficacy) we have suffered serious erosion in
Chairman
the past two years. I know you and the President share my concern
ARTS AND SCIENCES
here.
COMMITTEE
Felix W. de Weldon
Chairman
One organization which has a uniformly excellent track record over
ADVISORY COUNCIL
the past decade in raising the level of political trust and the sense
Dr. Albert L. Ayars
of efficacy is the Robert A. Taft Institute of Government Seminars.
Dr. George C. S. Benson
Dr. Earl L. Butz
Briefly, these two to six week graduate level institutes for elemen-
Hon. Harry F. Byrd, Jr.
tary and high school teachers bring together twenty to thirty political
Hon. Henry E. Catto, Jr.
Hon. Francis L. Dale
and governmental leaders with thirty teachers for the purpose of
Justin Dart
creating a more sophisticated and more positive view toward the Amer-
Mrs. Walter B. Driscoll
Richard Eells
ican political system and its leaders. Evaluations of the Seminars
Walter Evers
by participants and outside educators are extremely high and suggest
Hon. James A. Farley
Rev. Robert I. Gannon
that in terms of a cost/budget analysis they are perhaps the best
Robert L. Garner
educational "buy" in the summer institute market today.
E. J. Gerrity, Jr.
Dr. Frank Glenn
Mortimor S. Gordon
Now the point of this letter. Currently, the Robert Taft Institute
Bryce N. Harlow
of Government has before the Education Division of the National
Hon. John H. Haugh
Allan Hoover
Endowment for the Humanities a proposal to assist with the support
Hon. Hubert H. Humphrey
Hon. David S. Ingalls
and expansion of their program. Because I am a member of both
Dr. Walter H. Judd
governing bodies (Taft Institute and Council on the Humanities) it
Hon. Richard G. Lugar
John P. McGrath
is illegal and improper for me to involve myself in discussion of
Gilbert S. Merritt, Jr.
this matter when it comes to the Council floor in late February.
E. Frederic Morrow
C. S. Harding Mott
Hon. Richard M. Nixon
It is proper to bring to your attention the fact that the President
Charles S. Payson
Dr. Alan C. Rankin
has participated in these Seminars and to the best of my knowledge
William W. Reese
is a very strong supporter of them. In addition, scores of Con-
Howard J. Samuels
Hon. Caroline K. Simon
gressional leaders are equally convinced that the Taft program is an
Dr. Robert H. Spiro
Lloyd B. Taft
Hon. Robert Taft, Jr.
Francis Thalheimer
Mrs. G. M. Trammell, Jr.
Hon. Joseph D. Tydings
Hon. Cecil H. Underwood
Dr. Paul A. Wagner
Frederick K. Weyerhaeuser
Hon. Kevin H. White
Cote J. Younger
THE ROBERT A. TAFT
Mr. John Marsh
Institute of Government
January 23, 1975
Page Two
extremely important, well conceived, ably conducted, fair and timely
contribution to elementary and secondary teachers involved in teach-
ing about government and politics. You may hear from several of them.
In any case, Jack, I did want you to know of the Taft proposal, of the
President's past involvement and great interest. It may be he would
like you to reflect this evaluation to Dr. Ron Berman, Chairman of the
Endowment's Council. If you have a moment to peruse the project pro-
posal, which is enclosed, I am certain you will be fascinated with the
program. In fact, should your schedule allow, I would love to have you
participate in our Seminar this summer at Ohio Wesleyan on Friday morning
the 27th of June at either 9:00 or 10:30. It would be a high point of
a very exciting Seminar. I hope you can join us.
All the best.
Sincerely,
art
Arthur L. Peterson
Trustee
SEALE W. FORD LIBRARY
ALP:hb
enclosure
I don't know who in handling liainon between the which to
P.S. and educations, initude, to agencies, Garment used much be
Hour Vu contact. Incidentally if 2 can be of any assistance I (in would be
a shand post yr to in help conguissional - I even interviewed lisiner at by Departments Dent for his level liannon part but 2 have hand
nothing.
are
SBA
THE WHITE HOUSE
WASHINGTON
March 5, 1975
Dear Bob:
After receiving your letter of February 19, I reviewed
the materials you transmitted which had been prepared
by an attorney for the mushroom industry.
My previous acquaintance with this problem involved
only the question of whether Small Business Adminis-
tration disaster loans were properly available to the
mushroom processors as a result of the effect on their
business of the botulism bacteria. I now see that the
problem also arises from the effect on the domestic
business of mushrooms imported from Korea.
I have discussed this matter with Bill Seidman and at
his suggestion I am sending the material from attorney
Rini to Mr. Ken Gunther at the Office of the Special
Trade Representative.
Best personal regards.
Sincerely yours,
Thil
Philip W. Buchen
Counsel to the President
Honorable Robert VanderLaan
4745 Curwood, S. E.
BERALD FORD UNITED
Grand Rapids, Michigan 49508
cc: Mr. Ken Gunther
Office of the Special Trade Representative
THE WHITE HOUSE
washington
March 5, 1975
MEMORANDUM FOR:
KEN GUNTHER
FROM:
PHIL BUCHEN T.W.B.
For your appropriate handling.
SERVICE E. FORD LIBRARY
Regulatory
THE WHITE HOUSE
WASHINGTON
March 6, 1975
Dear Mr. Hock:
On behalf of the President, I would like to thank you
for your letter of February 13, 1975, concerning a
proposed requirement of the Securities and Exchange
Commission.
It is not proper for the President to intervene in a
matter that comes within the jurisdiction of an
independent regulatory agency and of the Federal
courts. However, you may be assured that your
views have been noted. The fact that you have
taken time to share your thoughts with the President
is appreciated.
Sincerely,
Philip W. Buchen
Counsel to the President
Mr. Roy E. Hock
President
Technitnol, Inc.
1952 East Allegheny Avenue
Philadelphia, Pennsylvania 19134
FORD LIBRARY
Jj.1
Technitrol, Inc.
February 13, 1975
The President
The White House
Washington, D. C. 20500
Dear Mr. President:
I feel compelled to write you again and make you aware of another
proposed requirement imposed upon our business by the Federal Govern-
ment.
This requirement, in simple terms, would require corporations falling
under the regulation of the Security and Exchange Commission to file
additional information on a quarterly basis with the Commission and
to its shareholders of record. This requirement will impose another
additional cost to our Company with no legitimate benefit to the
shareholders. It will consume the time and energies of management,
will require our consulting with our attorneys and public accountants
and will diminish the possibility of our earning a fair return on
our shareholders investment.
I have enclosed a copy of my letter to the Secretary of the Securities
and Exchange Commission in which I share my adverse opinion of such
new proposed regulation.
I am writing you to ask your support in minimizing and diminishing the
amount of paper work required of business of our type which is un-
necessary and unproductive. I believe the energy of management and
labor in the United States should be directed toward increasing produc-
tion rather than the creation of statistics, numbers and reports that
have no true value.
Sincerely,
Roy 6 Hock
Roy E. Hock
TORD & LIBRARY
President
jw
enc.
Technitrol, Inc.
February 3, 1975
Secretary
Securities and Exchange Commission
Washington, D. C. 20549
C
Reference: File No. S7-542
Dear Mr. Secretary:
I have read and studied your "proposal to increase disclosure of interim
results" and feel obligated to write you the following comments.
First, I believe your purpose in proposing an increase in disclosure is legiti-
mate and sound. However, I do not believe that disclosure to the extent you
have proposed, nor possibly disclosure in utmost detail will accomplish the
purpose "to enable users of reports to understand and evaluate business opera-
tions so that they can make rational investment decisions".
The ability to fairly analyze trends in a business in order to infer future
performance is predicated on the data being complete and accurate. On a
quarterly basis the ability to provide complete and accurate data is made
difficult by the following factors:
1. The inventory used in the calculation of cost of sales is a
book value inventory since a physical inventory is taken and priced
only annually. To switch to taking a quarterly inventory would create
on additional cost and would cause at least a thirty day delay in
reporting results.
2. Some costs of operations are seasonal or sporadic in nature through-
out the year. In some cases these costs are expensed as they occur and
in other cases they are expensed on an accrual basis with a year end
adjustment for the difference between the accrual and the actual. The
following are examples:
A. Advertising
BERAID FORD LIBRARY
B. Heat and electricity
C. Vacations and holidays
D. Sales and performance bonuses
E. Workmens compensation, medical and disability insurance
premiums.
3. The operating results can vary from quarter to quarter as a result
of scheduled deliveries to our customer being uneven from quarter to
quarter even though the work flow or manufacturing effort is on a level
busis. The result is that profits during the quarters when work-in-
process is increasing (shipments are low) are decreased while profits
during those quarters when shipments are high are increased.
Technitrol. Inc.
Secretary
Securities and Exchange Commission
(Continued)
February 3, 1975
The ability of management to make an intelligent and meaningful analysis of
the results of operations on a quarterly basis is made difficult by the above
factors. It is only at a latter time and over a longer period, such as
annually, that one can intelligently analyze the results of operations.
Secondly, I believe the implementation of your proposal will cost our
company at least 50% more in accounting and legal fees and in management time
and effort over what we are presently expending under the current requirements
for reporting to our shareholders. I do not object to this increased cost if
I believed it would give the shareholder and the financial investor better in-
formation. However, I do not believe the increased disclosure is of increased
value and, therefore, the net effect of this disclosure would be to decrease
the profits of the corporation and thus decrease the net worth to our present
shareholders and our attractiveness to other financial investors.
In conclusion, I believe your proposed increased disclosure requirements are
unsound and that they should not be adopted.
Sincerely,
Roy E. Hock
President
jw
SENTA n. FORD LIBRARY
Regulatory
Tuesday 3/11/75
12:20 Steve Aug of the Star would like to talk with you
484-4290
(will be back in his office in about 20 minutes).
He had talked with Richard Berg, Exec. Secy.
254-7020
in the Administrative Conference, concerning a
letter which Mr. Areeda wrote to them concerning
guidelines for the regulatory commissions, and
Mr. Berg suggested he call you.
I checked with Jane and she had no such letter in
her files. Mr. Areeda apparently took the whole
chron file.
I called Mr. Berg's office to talk with him and he
said that you had talked with Robert Anthony about
it.
Said it is an innocuous memo Mr. Areeda
sent to Chairman Anthony on December 9, 1974.
Mr. Berg said he sees nothing in it that couldn't
stand the light of day -- but thought it should be
checked with you.
12:50 I have sent a messenger over to the Administrative
Conference to pick up a copy for us.
4:30 read
4:55 they talked
GERALD FORD
BE
Shaw
THE WHITE HOUSE
FAA work
WASHINGTON
Nc'd
December 9, 1974
i)
Dear Bob:
I appreciate your willingness to assist in the formulation of an
"anecdotal primer" for the guidance of Regulatory Commissioners.
I agree that the standards of the statutes, executive orders, and
regulations are comprehensive. Without having thought the matter
through, I am not aware of any need to rewrite the standards themselves.
What is needed is a more concrete statement. The need for it is
revealed by the repeated missteps actually made by Commissioners of
the Regulatory Agencies.
On one recent occasion, for example, a Commissioner accepted a "social"
invitation from an "industry member" to holiday at a resort. Private
transportation was provided, as were accommodations and entertainment.
The latter were, I understand, later reimbursed by the Commissioner.
Other "industry members" were present. It was said that no "pending
matters" before the Commission were discussed.
In another instance, a Commission member travelling on official business
found himself accompanied over the course of a week or so by an official
of a major regulated company which had recently had or was about to
have a case before the Commission. It was said that no case was then
pending, however.
More generally, Commission members regularly find themselves at
industry meetings or otherwise in non-formal contacts with members of
the industry they regulate. Obviously, a Commission member cannot
live in a cocoon. Indeed, in developing the expertness they are meant
to seek, contacts cannot and perhaps should not be limited to formal
proceedings before the Regulatory Agencies.
PORD . LIBRARY
- 2 -
The problem of contacts becomes especially acute when the Commission
member has "friends" who are officials or representatives of the
regulated firms. These friends will include not only those known to the
Commissioner from his days in private life; they will also include those
who make the acquaintance of the Commissioner after he assumes his
public office.
Again, without having thought the matter through, I have trouble with
distinctions that rest on the existence of a pending case. Major members
of an industry always have or are about to have a case pending before
an Agency. The appearance of impropriety in social contact is always
troubling--especially where the "friends" in question are not those of
long standing. Furthermore, I doubt that holidays or the intimate
company of sustained travel are the appropriate vehicles for
familiarizing oneself with industry problems. Perhaps one could
distinguish undesirable socializing involving relatively few industry
members from a more acceptable participation at a trade association
meeting (even at holiday resorts).
These observations and examples merely scratch the surface. I am
sure that we can find other examples in the experience of the Office of
the Legal Counsel or through hypotheticals that we can readily dream
up.
Of one thing I am sure, the proper kind of primer dealing with concrete
examples can serve a useful educational function and will unquestionably
keep some future Commissioners out of trouble that they otherwise might
get into.
Sincerely,
Phil
Phillip Areeda
Counsel to the President
Honorable Robert Anthony
Chairman
Administrative Conference of
the United States
Washington, D. C. 20037
SEAL R. FORD LIBRARY
Rod -
Let's talk
about this
with Bill
Walker
Regulatory
agencies
THE WHITE HOUSE
WASHINGTON
MARCH 24, 1975
MEMORANDUM FOR:
PHIL BUCHEN
ROD HILLS
BILL WALKER
FROM:
PHIL AREEDA PA
I enclose a memorandum from Dudley Chapman about
Robert Timm. I agree with his recommendation.
FORD LIBRARY A
THE WHITE HOUSE
WASHINGTON
March 24, 1975
MEMORANDUM FOR:
PHIL AREEDA
FROM:
DUDLEY CHAPMAN
DC
SUBJECT:
Robert Timm - - New Allegations
1. The President is empowered by 49 U.S.C. 1321(a)(2) to remove
members of the CAB "for inefficiency, neglect of duty, or mal-
feasance in office. " Newspaper reports of current hearings before
the Senate Judiciary Subcommittee on Administrative Practice and
Procedure raise a serious question as to whether Timm's handling
of an investigation into alleged illegal corporate contributions
amounted to neglect of duty, inefficiency, or even misconduct.
2. The allegations are that:
(a) CAB investigators were limited to interviews with the chief
executive officer only of each airline involved, could ask only six
prescribed questions and were not permitted to ask follow-up questions.
Timm admits wanting the investigation limited for the sake of speed
because he anticipated Congressional inquiries, but denies prohibiting
follow-up questions. The testimony of two lawyers at the CAB Bureau
of Enforcement, Stephen A. Alterman and James L. Weldon, Jr.,
was that they received their orders from their Chief, Gerald F.
Hadlock, then Deputy Director of the Bureau, and Hadlock could not
recall what orders he had given. Hadlock would not challenge the
testimony of the other CAB lawyers that the decision had come from
Timm or "the 10th floor", referring to the Chairman's office.
Thomas J. Heye, now General Counsel of the CAB, was then Special
Assistant to Timm and may have relayed the order.
(b) Richard J. O'Melia, an FCC Commissioner and formeı head
of the Board's Enforcement Bureau, alleged in sworn testimony that
BERALD FORD LIBRARY
2
Timm had sent him a memorandum handcarried by Heye that
instructed him to stop investigating political contribution cases.
O'Melia testified that he was shocked and refused to accept the
memo. Timm flatly denies the report. Heye, who was taken
suddendly ill during the hearings, has not yet testified. Timm
suggested that a memo he did send O'Melia at that time contained
a double negative that O'Melia may have overlooked in a rapid
reading.
3. Even accepting Timm's accountat face value, it appears
undisputed that (i) the investigation was limited in the manner alleged,
and as the result of some kind of instructions received from Timm's
office; (ii) whatever validity there may have been in limiting the
investigation initially for speed, there is no indication that Timm
authorized or desired a more complete investigation later; and
(iii) an adequate investigation was not made. Given the seriousness
of the allegations, this lack of vigilance in pursuing them could be
deemed a neglect of duty and inefficiency in a matter of great
importance to public confidence in the CAB.
4. Timm's conduct in this matter recalls his refusal to heed the
warnings of a lawyer acquaintance that airline executives would
be present on his notorious Bermuda trip. When added to his
insensitivity in traveling extensively with a TWA executive who had
business before the CAB, public confidence in Timm's integrity
appears damaged beyond repair.
5. Timm should be given a chance to tell his side of the story,
preferably in a person-to-person interview here. This does not
appear to be a problem of verifying detailed allegations. The
enforcement responsibilities of the Board require that there be
public confidence in the rhembers' competence and sincerity. If
the facts bear out the appearance that he did not pursue the
political contributions investigation conscientiously, he should be
asked to resign, and if he refuses, dismissed for neglect of duty.
and inefficiency.
FORD LIBRANIA
Some items in this folder were not digitized because it contains copyrighted
materials. Please contact the Gerald R. Ford Presidential Library for access to
these materials.
Regulations
THE WHITE HOUSE
WASHINGTON
March 24, 1975
Dear Abbott:
Thank you for forwarding the news clipping
from the Washington Star concerning guide-
lines for the behavior of regulatory agency
members.
With appreciation,
Sincerely,
Thil
Philip W. Buchen
Counsel to the President
The Honorable Abbott Washburn
Commissioner
Federal Communications Commission
Washington, D.C. 20554
GERALD FORD LIBRARY
HON, PHILIP BUCHEN
FEDERAL COMMUNICATIONS COMMISSION
Washington, D. C. 20554
OFFICE OF COMMISSIONER ABBOTT WASHBURN
3/14/75
Phil,
T R. FORD LIBEARY
This in h good idea,
wen for people with con-
siderable expirience in
Government. It in different
when you take on regulatory
my observation here in that
The Commissioners are super-
cantions about These contacts.
- Abbott Form A-28 7/74
The Washington Star March 12, 1975
Regulators to Get/Guidelines on
By Stephen M. Aug
Washington Star Staff Writer
The White House, con-
Proper Behavior
cerned that regulatory
company, and more gener-
primer dealing with con-
that we have any superior
agency members have been
getting into compromising
ally the problems faced by
crete examples can serve a
wisdom or knowledge that
commissioners who find
useful educational function
positions, has called for
we ought .to pass on to
themselves in social or
and will keep some future
them. I wouldn't want to of-
development of guidelines
to help the regulators avoid
semiformal contacts with
commissioners out of trouble
fend the entire regulatory
publicly embarrassing
representatives of indus-
that they otherwise might
community by suggesting
themselves.
tries they regulate.
get into," it says.
that we distrust them as a
Officials at both the
No names were mention-
group or think they don't
ed in the letter, nor were
Philip W. Buchen, coun-
know how to behave."
White House and the
any agencies singled out by
sel to Ford, said the White
Administrative Conference
title.
House hopes to use the
Richard Berg, executive
-which is working on the
guidelines as a briefing
secretary of the Adminis-
guidelines--confirmed yes-
The letter pointed out
trative Conference, said the
paper for new appointees to
terday that the request had
that while every agency has
come in Desember
agencies. He explained that
agency still is collecting
material for the primer. He
Tuesday 3/11/75
12:20 Steve Aug of the Star would like to talk with you
484-4290
(will be back in his office in about 20 minutes).
He had talked with Richard Berg, Exec. Secy.
254-7020
in the Administrative Conference, concerning a
letter which Mr. Areeda wrote to them concerning
guidelines for the regulatory commissions, and
Mr. Berg suggested he call you.
I checked with Jane and she had no such letter in
her files. Mr. Areeda apparently took the whole
chron file.
I called Mr. Berg's office to talk with him and he
said that you had talked with Robert Anthony about
it.
Said it is an innocuous memo Mr. Areeda
sent to Chairman Anthony on December 9, 1974.
Mr. Berg said he sees nothing in it that couldn't
stand the light of day -- but thought it should be
checked with you.
12:50 I have sent a messenger over to the Administrative
Conference to pick up a copy for us.
Dalbed to aug on March 11, if 1975.
Would you like bappen to spot item than
to All story he runs the
FORD of LIBRARY GREATE
Cutheran
Shaw
THE WHITE HOUSE
A
WASHINGTON
used
December 9, 1974
Dec
14
Dear Bob:
I appreciate your willingness to assist in the formulation of an
"anecdotal primer" for the guidance of Regulatory Commissioners.
I agree that the standards of the statutes, executive orders, and
regulations are comprehensive. Without having thought the matter
through, I am not aware of any need to rewrite the standards themselves.
What is needed is a more concrete statement. The need for it is
revealed by the repeated missteps actually made by Commissioners of
the Regulatory Agencies.
On one recent occasion, for example, a Commissioner accepted a "social"
invitation from an "industry member" to holiday at a resort. Private
transportation was provided, as were accommodations and entertainment.
The latter were, I understand, later reimbursed by the Commissioner.
Other "industry members" were present. It was said that no "pending
matters" before the Commission were discussed.
In another instance, a Commission member travelling on official business
found himself accompanied over the course of a week or so by an official
of a major regulated company which had recently had or was about to
have a case before the Commission. It was said that no case was then
pending, however.
More generally, Commission members regularly find themselves at
industry meetings or otherwise in non-formal contacts with members of
the industry they regulate. Obviously, a Commission member cannot
live in a cocoon. Indeed, in developing the expertness they are meant
to seek, contacts cannot and perhaps should not be limited to formal
proceedings before the Regulatory Agencies.
FORD JOHN
- 2 -
The problem of contacts becomes especially acute when the Commission
member has "friends" who are officials or representatives of the
regulated firms. These friends will include not only those known to the
Commissioner from his days in private life; they will also include those
who make the acquaintance of the Commissioner after he assumes his
public office.
Again, without having thought the matter through, I have trouble with
distinctions that rest on the existence of a pending case. Major members
of an industry always have or are about to have a case pending before
an Agency. The appearance of impropriety in social contact is always
troubling--especially where the "friends" in question are not those of
long standing. Furthermore, I doubt that holidays or the intimate
company of sustained travel are the appropriate vehicles for
familiarizing oneself with industry problems. Perhaps one could
distinguish undesirable socializing involving relatively few industry
members from a more acceptable participation at a trade association
meeting (even at holiday resorts).
These observations and examples merely scratch the surface. I am
sure that we can find other examples in the experience of the Office of
the Legal Counsel or through hypotheticals that we can readily dream
up.
Of one thing I am sure, the proper kind of primer dealing with concrete
examples can serve a useful educational function and will unquestionably
keep some future Commissioners out of trouble that they otherwise might
get into.
Sincerely,
Phil
Phillip Areeda
Counsel to the President
Honorable Robert Anthony
Chairman
Administrative Conference of
the United States
Washington, D. C. 20037
SEC
Monday 5/5/75
Meeting
5/14/75
2 p.m.
5:00 Ted Darreaux called to say they have an appointment
with Don Rumsfeld at 2:00 p.m. on Wednesday 5/14
to discuss SEC personnel matters.
Wondered if you might be free at 2:45 that day so
they cuuld bring you up to date.
He will let us know later who will be coming.
FORD LIBRARY 07VU38
EPS FORM 25
(03/75)
EXECUTIVE PROTECTIVE SERVICE
To:
Officer-in-charge
Appointments Center
Room 060, OEOB
Please admit the following appointments on Saturday, June 21
, 1975
8:30 AM
for Roderick Hills (Roosevelt Room)
of
White House
:
(Name of person to be visited)
(Agency)
Michael Pertschuk
Mr. Lynn Sutcliffe
Edward Cohen
Thomas Susman
Arthur Pankopf
Michael Lemov
Paul Hoff
Jonathan Rose
Paul MacAvoy
Sidney Jones
Cal Collier
Paul Leach
Dudley Chapman
Lynn May
Seorge Eads
FORD in LIBRARY
Sandy Serson
Jordan Lewis
Don Baker
MEETING LOCATION
Roosevelt Room
Building
Requested by
Eva Daughtrey
West Wing
X 6611
Room No. West Wing
Room No.
Telephone
Time of Meeting
8:30 AM
Date of request
6/20/75
Additions and/or changes made by telephone should be limited to three (3) names or less.
DO NOT DUPLICATE THIS FORM.
APPOINTMENTS CENTER: SIG/OEOB - 395-6046 or WHITE HOUSE - 456-6742
6/21/95
Michael Pertschuk
Mr. Lynn Sutcliffe
Edward Cohen
Thomas Susman
Arthur Pankopf
Michael Lemov
Paul Hoff
Jay Cutler
Harrison Loesh
David Stang
Bailey Guard
Jonathan Rose
Paul MacAvoy
Sidney Jones
Cal Collier
Stan Morris
Paul Leach
Dudley Chapman
Lynn May
George Eads
Jordan Lewis
Sandy Gerson
Donald Baker
FORD - LIBRARY 07VU38
THE WHITE HOUSE
Regulatory
WASHINGTON
July 25, 1975
Dear Mr. Harrington:
On May 9, 1975, you replied directly at the request of the
White House to a letter by David L. Herndon, of the firm of
Davies, Richberg, Tydings, Landa and Duff, concerning some
alleged restrictive effects of the Federal Home Loan Mortgage
Corporation requirements.
On May 14, 1975, Mr. Herndon again wrote the President
enclosing an analysis of the effects of Federal regulation in
this field. The White House has no familiarity with the substance
of the matters Mr. Herndon has rais ed. The tone of his arguments,
however, suggests that there may be a problem of excessive
Federal regulation that would merit re-examination to evaluate
its usefulness and the possible desirability of changes. Since
the substance of your reply of May 9, 1975, indicated that the
specific action Mr. Herndon complained of was mandated by
statute, it may be appropriate to consider whether changes in
the legislation would be appropriate. Such an examination would
be in line both with the Presidential statements referred to in
Mr. Herndon's original letter and, especially, of the comprehensive
drive for a review and re-evaluation of the effect of Federal
regulations on the economy, which is a key point in the President's
domestic program. A transcript of the President's recent meeting
with the heads of the ten principal independent regulatory agencies
is enclosed and should give you a clear sense of the breadth and
conviction of the President's thinking in this area.
BERALD FORD
-2-
I would appreciate having your thoughts on this. Copies of the
referenced correspondence are attached.
Sincerely,
Thily W.Buclen
Philip W. Buchen
Counsel to the President
Mr. Philip N. Harrington
Federal Home Loan Mortgage Corporation
311 First Street, N.W.
Washington, D. C. 20001
THE WHITE HOUSE
WASHINGTON
May 30, 1975
MEMORANDUM FOR:
DUDLEY CHAPMAN
FROM:
PHILIP BUCHEN T.W.B.
Kindly review the attached file submitted
to me by Tod Hullin and recommend an
appropriate response for my signature.
Attachment
Eva,
Do NOT Send.
We have m. Bucher's
original memo on our backeys
over here.
STATE E. FORD
ns.
THE WHITE HOUSE
WASHINGTON
May 29, 1975
MEMORANDUM FOR
PHIL BUCHEN
FROM
TOD HULLIN
r
SUBJECT
ALLEGED DE FACTO INDUSTRY REGULATION
BY FEDERAL HOME LOAN MORTGAGE
CORPORATION
The initial letter in the attached package complains of
slow approval eligibility by the FHLMC of a particular
mortgage company. On the recommendation of HUD, this
correspondence was referred to FHLMC for routine reply.
On May 14, another letter was forwarded to the President
indicating a continued broader interest in FHLMC's
de facto regulation of mortgage companies.
Accordingly, I am forwarding this file to your office
for consideration and appropriate handling.
Many thanks.
DO NOT Send
Regulatory
THE WHITE HOUSE
WASHINGTON
July 25, 1975
Dear Mr. Herndon:
This will acknowledge your second letter to the President
of May 14, 1975, concerning what you assert to be restrictive
effects of the Federal Home Loan Mortgage Corporation (FHLMC)
standards on the availability of mortgage funds. Your letter has
been referred to the FHLMC with a request for an analysis and
recommendations concerning the material you submitted. You
may be assured that the results of that analysis will receive
full consideration within the Administration.
Sincerely,
Philip W. Buchen
Counsel to the President
Mr. David L. Herndon
Davies, Richberg, Tydings,
Landa & Duff
1125 - 15th Street, N.W.
Washington, D.C. 20005
bcc: Philip N. Harrington
OF
DEPARTMENT THE 1789 TREASURY
THE
Regulatory
THE DEPUTY SECRETARY OF THE TREASURY
agency
WASHINGTON, D.C. 20220
August 5, 1975
MEMORANDUM FOR THE HONORABLE PHILIP W. BUCHEN
COUNSEL TO THE PRESIDENT
We have a verbatim tape of the news conference
which contained the Secretary's remarks about the
slowness of the regulatory process in the Star News
television station matter.
That was reproduced literally in the body of the
attached article in the Star News and we have agreed
that this is a correct reproduction.
Bill Simon's position is clear. He was complaining
about the delay of the regulatory process.
The comments we have received since the article
were generally favorable press queries. We have not
had to frame a letter answer to people criticizing the
comment as yet.
If you want anything else, please call.
Stephen Atror S. Gardner
Attachment
BERALD FORD
Washington Star-News
FRONT PAGE
JUL 31 1975
Simon Assails FCC on Star Case
Treasury Secretary William E.
wrong, or favorable or un-
Allbritton applied to the
Simon has assailed as "a coward's
favorable. We're not talking
FCC for a waiver eight
way out" the Federal Communica-
about the substance. I just
consider it absolutely
months ago. The FCC voted
tions Commission's decision to delay
action on Washington Star publisher
unconscionable for them to
6-1 Monday to hold public
Joe L. Allbritton's request for a waiv-
wash their hands.
hearings for more informa-
"And if it's true that this
tion before ruling on the
er that would allow him to gain effec-
application, a decision
tive control of both the newspaper
newspaper is in financial
which could delay the out-
and its broadcast stations here.
difficulties, (and) I have to
come for more than a year,
In answer to a question on whether
believe it is true, do they go
according to communica-
the White House should apply "heat"
out of business in a year as
tions lawyers.
THE WHITE HOUSE
Regulatory
WASHINGTON
August 26, 1975
MEMORANDUM FOR PHILIP BUCHEN
FROM:
DOUGLAS P. BENNETT
DPB
SUBJECT:
Vacancies on Regulatory Boards
and Commissions
As you know, during the next few months there will be
vacancies on several regulatory boards and commissions--
specifically, the Interstate Commerce Commission, the
National Labor Relations Board, the Federal Trade Com-
mission and the Consumer Product Safety Commission.
I would like to call on you from time to time to talk
personally with our candidates for these appointments.
The President feels strongly about regulatory reform and
your insight and reaction to these candidates will be
very important and helpful to us in our staffing process.
Rather than ask you to simply review a resume, I feel
that a personal interview would be far more beneficial
to all.
As candidates are identified by our office, I shall call
you to arrange a convenient time for you to meet with them.
I appreciate your assistance.
GERALD FORD LIBRARY
THE WHITE HOUSE
WASHINGTON
August 26, 1975
MEMORANDUM FOR PHILIP BUCHEN
FROM:
DOUGLAS P. BENNETT
SUBJECT:
Vacancies on Regulatory Boards
and Commissions
As you know, during the next few months there will be
vacancies on several regulatory boards and commissions--
specifically, the Interstate Commerce Commission, the
National Labor Relations Board, the Federal Trade Com-
mission and the Consumer Product Safety Commission.
I would like to call on you from time to time to talk
personally with our candidates for these appointments.
The President feels strongly about regulatory reform and
your insight and reaction to these candidates will be
very important and helpful to us in our staffing process.
Rather than ask you to simply review a resume, I feel
that a personal interview would be far more beneficial
to all.
As candidates are identified by our office, I shall call
you to arrange a convenient time for you to meet with them.
I appreciate your assistance.
Regulatory
THE WHITE HOUSE
WASHINGTON
October 10, 1975
MEMORANDUM FOR:
JON ROSE
THROUGH:
PHIL BUCHEN P.W.B.
FROM:
DUDLEY CHAPMAN D.C.
SUBJECT:
Participation by Antitrust Consumer
Unit in Regulatory Proceedings
At the last meeting of the DCRG, you asked for comment on the
Attorney General's interest in having the Antitrust Division
participate in rate-making proceedings through its Consumer
Unit.
I have discussed this with Rod Hills and Ken Lazarus. We all
agree that: (1) successful opposition to a new consumer agency
will require that we have a credible alternative, (2) it is good
government policy to represent the interests of consumers in
regulatory proceedings, and (3) Justice is the logical agency to
do it. There is some overlap with COWPS, but we see your
respective functions as complimentary. COWPS is a White House
level, policy-making unit, while Justice has a litigating function.
This is a logical and promising area for regulatory reform, and
should be promoted as such. I would appreciate your keeping us
the DCRG.
informed of your plans and progress, both directly and through
CC: Rod Hills
Ken Lazarus
FORD LIBRARY