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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 Gerald R. Ford donated to the United States of America his copyrights in all of his unpublished writings in National Archives collections.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

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    "ocrText": "The original documents are located in Box 59, folder \"Regulatory Agencies - General (2)\"\nof the Philip Buchen Files at the Gerald R. Ford Presidential Library.\nCopyright Notice\nThe copyright law of the United States (Title 17, United States Code) governs the making of\nphotocopies or other reproductions of copyrighted material. Gerald R. Ford donated to the United\nStates of America his copyrights in all of his unpublished writings in National Archives collections.\nWorks prepared by U.S. Government employees as part of their official duties are in the public\ndomain. The copyrights to materials written by other individuals or organizations are presumed to\nremain with them. If you think any of the information displayed in the PDF is subject to a valid\ncopyright claim, please contact the Gerald R. Ford Presidential Library.\nDigitized from Box 59 of the Philip Buchen Files at the Gerald R. Ford Presidential Library\nTHE WHITE HOUSE\nRegulatory\nWASHINGTON\nJanuary 7, 1975\nMEMORANDUM FOR PHILIP W. BUCHEN\nFROM:\nWILLIAM N. WALKER Jull\nSUBJECT:\nAnnouncement of Betty Southard Murphy\nas Chairman, NLRB\nOn January 3, 1975, The President approved the nomination of\nBetty Southard Murphy as Chairman of the National Labor\nRelations Board.\nBetty Murphy's most recent FBI full field investigation was\ncompleted in April 1974; an up date is in process. A\nspecial clearance was ordered on January 6. Her conflicts\nof interest clearance is complete.\nThe decision memorandum to the President proposed prompt\nannouncement of the intention to nominate Mrs. Murphy in\norder to prevent the labor-management consensus on her\nnomination from unraveling.\nThis memorandum requests your approval of a waiver of\npending clearances only for the purpose of an early an-\nnouncement of an intention to nominate. All clearances will\nbe final before the nomination is made.\nI grant the waiver of final clearances for purposes of\nannouncement.\nPhilip PhilypluBuden W. Buchen\nBuchen\nR. FORD LIBRARY\nBIOGRAPHY\nBETTY SOUTHARD MURPHY\nADMINISTRATOR, WAGE AND HOUR DIVISION\nDEPARTMENT OF LABOR\nBetty Southard Murphy, a labor lawyer with a nationwide\nreputation, was sworn in as Administrator of the Wage and\nHour Division, on July 15, 1974.\nAs Administrator, Mrs. Murphy supervises the Department's\nresponsibilities under some 70 different labor laws including\nthe Fair Labor Standards Act, which includes minimum wage\nprovisions affecting 56 million workers, the Equal Pay Act,\nwhich requires men and women receive equal pay for equal work,\nthe Age Discrimination in Employment Act, which prohibits\ndiscriminatory employment practices based on age, the Walsh-\nHealey Public Contracts Act, the Davis-Bacon Act, the Service\nContract Act, the Farm Labor Contractor Registration Act, and\na number of other labor laws. She oversees a $37 million\nbudget and over 1,500 employees.\nBefore accepting this appointment, Mrs. Murphy was a partner\nin the Washington, D. C. law firm of Wilson, Woods and Villalon\nwhere she specialized in labor, corporate and administrative\nlaw. She is one of the few lawyers in the United States who\nrepresented both international unions and employers.\nIn private practice, Mrs. Murphy was an active trial lawyer\nand tried cases or appeared in Federal or State Courts in\n19 different States and argued in 9 of the 11 United States\nCourts of Appeals.\nMrs. Murphy began her career as a reporter--first as corre-\nspondent and free lance journalist in Europe and Asia and\nlater with United Press (now UPI). After graduating from\nlaw school, she was an enforcement attorney with the National\nLabor Relations Board during 1958-1959.\nMrs. Murphy--the first woman to be named Administrator--is\na Trustee of the American University, is on the National\nBoard of the Medical College of Pennsylvania, and is Chair-\nman of the Board of Visitors of Mary Baldwin College.\nBERALD FORD\n2.\nHer concern with civil rights and equal employment oppor-\ntunity for workers is well established. She has been\nactive as Chairman of the District of Columbia Bar Associa-\ntion's Civil Rights Committee, and the Fair Employment\nPractices Committee; the Federal Bar Association's Committee\non Equal Employment Opportunity and Collective Bargaining;\nthe Women's Bar Association's Committee on the Status of\nWomen; and is also Vice Chairman of the Labor Law Committee,\nAdministrative Law Section, American Bar Association.\nShe received a B.A. degree (oriental studies) from the Ohio\nState University and also studied in Paris at the Sorbonne\nand the Alliance Francaise. She obtained her J.D. degree\nin 1958 from the American University Washington College of\nLaw.\nMrs. Murphy and her husband, Dr. Cornelius F. Murphy, a\nRadiologist, reside in Annandale, Virginia, with their two\nchildren, Ann, 6, and Neil, 5.\nSERVICE FORD LIBRARY\nRegulatory arms\nControl\nDesarmont\nbyency\nJanuary 22, 1975\nBob\nMEMORANDUM FOR: Bill Walker\nFROM:\nPhil Buchen\nSUBJECT:\nDisarmament Agency\nI have had an inquiry from a friend of mine who works\nthere about the appointment of a Director. He\nrecommends promotion of John Layman, despite his\nprior difficulty with Senator Fulbright.\nPWBuchen:ed\nn FORD LIBRARY\nRegulatory\nUS arms\nControlx\nTHE WHITE HOUSE\nDisarmament\nWASHINGTON\nPhil A\n1/24/95 agency\nWould you have\ntime please to\nreview of comment\nfor US.\nP.\nSERA THE FORD LIBRARY\nMEMORANDUM\n0483\nNATIONAL SECURITY COUNCIL\nJanuary 24, 1975\nMEMORANDUM FOR:\nPHILIP BUCHEN\nFROM:\nJeanne W. Davis\nSUBJECT:\nACDA's 1974 Annual\nReport to Congress\nAttached is ACDA's Annual Report to Congress for calendar year\n1974, together with a suggested Presidential letter of transmittal.\nSection 50 of the Arms Control and Disarmament Act requires the\nannual report and also requires that it be transmitted to the\nCongress by the President.\nThe Report is due on the Hill by January 31. In order to allow time\nfor further processing, may we please have your concurrence\nand/or comments by c.o.b. Tuesday, January 28.\nAttachment\nFORD & LIBRARY SERVICE\nUNITED STATES ARMS CONTROL AND DISARMAMENT AGENCY\nWASHINGTON\nOFFICE OF\nJanuary 22, 1975\nTHE DIRECTOR\nMr. President:\nI submit for your transmittal to the Congress,\nas required by the Arms Control and Disarmament\nAct, as amended, the fourteenth annual report of\nthe U.S. Arms Control and Disarmament Agency. This\nreport covers the work of the Agency during calen-\ndar year 1974.\nRespectfully,\nFeed C. Ikle\nFred C. Ikle\nThe President\nThe White House\nGERALD R. FORD DEBRARY\nRegulatory\nagainstes\nJanuary 24, 1975\nDear Lew:\nIt was no trouble at all to get this\nphotograph signed by the President.\nI join him in extending very best wishes\nto you. I remain very proud of your\naccomplishments and of the high regard\nin which you are held by people who know\nyour work.\nSincerely yours,\nPhilip W. Buchen\nCounsel to the President\nThe Honorable Lewis A. Engman\nChairman\nFederal Trade Commission\nWashington, D. C.\nPWBuchen:ed\nBERALD R. FORD\nNO RALTRADE-CU UNITED STATE\nFEDERAL TRADE COMMISSION\nMCMXV*1\nWASHINGTON\nOFFICE OF\nTHE CHAIRMAN\nJanuary 10, 1975\nDear Phil:\nI hate to bother you with extra work, but\nI wonder if you would be kind enough to ask\nthe President to autograph the enclosed\npicture sometime at his convenience,\nWith warmest wishes to you and Bunnie for\na successful and Happy New Year.\nSincerely yours,\nEnclosure\nLewis A. Engman\nThe Honorable\nPhilip W. Buchen\nCounsel to the President\nThe White House\nWashington, D.C. 20500\nFORD a LIBRARY 03\nRegulatory\nagencies\nTHE WHITE HOUSE\nWASHINGTON\nSL/E/2\nPhilA:\nWould oppreciate\nyour homothing this\nP.\nFORD as LISA LIBRARY SERVICE ARY\nTHE WHITE HOUSE\nWASHINGTON\nFebruary 3, 1975\nMEMORANDUM FOR PHIL BUCHEN\nSUBJECT:\nLetter to Regulatory Agencies\nAttached is a proposed draft letter from Ken Cole to the heads of regulatory\nagencies mentioned in volumes I and II of the U.S. Commission on Civil Rights\nreport - \"The Federal Civil Rights Enforcement Effort - 1974. If There are three\nmore volumes yet to be published.\nWe feel it is important that the President ask for Federal agency responses and\naccept regulatory agency comments if they wish to offer them. I'd appreciate\nyour comments on the course of action and the draft attached. Thank you.\nA Lyn Z\nF. Lynn May\nAttachment\nis. FORD LIBRARY\nDRAFT\nTHE WHITE HOUSE\nWASHINGTON\nDear Mr. Chairman:\nThe U.S. Commission on Civil Rights recently transmitted to President\nFord Vol. I of its study, \"The Federal Civil Rights Enforcement Effort -\n1974. 11 This publication evaluates the civil rights activities of the\nfollowing regulatory agencies: the Federal Communications Commission,\nthe Interstate Commerce Commission, the Civil Aeronautics Board, the\nFederal Power Commission and the Securities and Exchange Commission.\nIn the process of informing the President about the total report, we would\nbe happy to include your comments, if you wish to submit them.\nSincerely,\nKenneth R. Cole, Jr.\nAssistant to the President\nfor Domestic Affairs\nThe Honorable George M. Stafford\nChairman\nInterstate Commerce Commission\nin\nTORD\n12th & Constitution, N.W.\nWashington, D.C. 20423\nRegulatory\nCAB\nTHE WHITE HOUSE\nWASHINGTON\nFebruary 8, 1975\nDear Jim:\nThis is a belated acknowledgement of your letter\nof December 18th.\nI very much appreciated hearing from you and\nreceiving news about your family. I congratulate\nyou on your service for 35 years in the Presbyterian\npastorate.\nI noted your comments about Bob Timm but to the\nextent our office has been involved in this matter,\nit would be inappropriate for me to comment.\nI do send my very best wishes to you and your wife\nJanet.\nSincerely,\nThey Philip W. Buchen\nCounsel to the President\nMr. James E. Hanson\n1718 Aurora\nTacoma, Washington 98465\nBE GERALD\nFORD i LIBRARY\nREAL ESTATE\nMORTGAGE LOANS\nAPPRAISAL SERVICE\nINSURANCE\nPROPERTY MANAGEMENT\nF.H.A. APPROVED MORTGAGEE\nMAIN OFFICE: 1001 PACIFIC AVENUE - TACOMA, WASHINGTON\n3\nWESTGATE NORTH END BRANCH\nSK 2-6696\n5738 NORTH 26th STREET\nESTABLISHED 1888\nTACOMA, WASHINGTON 98407\nDecember 18, 1974\nMr. Philip Buchen\nThe White House\nWashington, D.C.\nGENAL 18. FORD LIBRARY\nDear Philip;\nI have intended to write you for some time to express my congratulations\nto you in your position of trust and responsibility as Chief White House\nCounsel. It has been very interesting to follow your activities in the\nnews, and especially to catch up on the news concerning your family through\nthe pictures and write-up in September \"Peoples Magazine\". It was interest-\ning to see in that feature a number of photos that we have in the faily album.\nWe have all enjoyed a great deal of pride and satisfaction in your remarkable\nattainments and in the very nice things that are said about you. I can\nreadily understand how this could be, as my dear mother, your late Aunt\nEleanore was a very remarkable and wonderful person.\nPerhaps you have heard, but my older brother Lee died in a plane crash in\nTexas this past May. He was a pilot and flew for an oil company out of Odessa.\nDave and his family have lived for some years in Kansas City where he is an\nofficial with Camobell Soup Company. Paul is in real estate in Victoria, B.C.\nArt has done remarkably well in the grocery business, mostly in the buying\nand selling of stores in various parts of the country. I believe he is\npresently taking some special courses in merchandising atrthe University of\nMichigan. Elizabeth took an early retirement from her work as a public\nschool teacher due to her arthritis, but remains active and is very precious\nto all of us as our only sister. She has lived in Billings Montana for years.\nShe kept up a correspondence with your mother until shortly before her passing.\nIn June of this year I completed thirty five years in the Presbyterian past-\norate. I am at present on sabbatical and trying my hand at real estate. If\nthis works out, I may continue, otherwise our plans are to return to the work\nof the church about next June.\nI have been particularly interested to note that you have an interest in\ntheology and that you have been concerned with the theological implications\nof the Nixon pardon. It would be very interesting to share our views on this\nat some time. It seems that our conclusions in this area are nearly identicle,\nthough yours appear to have been arrived at from the viewpoint of Humanism and\nmine from the viewpoint of Reformed Theology. Perhaps it is that the circle\nmeets at the top and that the search for a oure humanism arrives ultimately at\nthe Perfect Human, and then to understand that perfection we are left with no\nmore plausible explanation then the biblical statement of St. Paul to the\nColossians (2:9-10) that, \"In Him dwells all the fulness of the Godhead bodily.'\nTo me it is so satisfying to accept the fact that the invisible God should see\nfit to come to His creatures in human form, that we might know exactly what He\nis like, and that any time we wonder what He is like, we may need but look at\nthe magnificent Christ. But enough of this for now! It would be so great to\nshare some of our searching in these areas, and perhaps to find that though per-\npositions. suing different theological routes, we have arrived at very close to the same\nPhilip, there is one matter which I wish to mention that came to my attention\nin the WALL STREET JOURNAL of this Tuesday, December 17 concerning my good friend\nBob Timm, Chairman of the Civil Aeronautics Board. (Clipping enclosed). Bob is\na great and wonderful guy and one of the bright hopes for our Republican Party\nhere in the State of Washington. Though I realize you may have no contact what-\nsoever with this situation, I am hoping that he will not be relieved of the CAB\nchairmanship under the inuendos of the Nadar attack as this would seem to confirm\nin the minds of many that there was actual wrong-doing. I hate to see opposition\npolicies eliminating good men from our ranks by placing us on the defensive\nregarding them. I am hoping that the same compassion that ruled in regard to\nthe Nixon pardon will rule in the preserving of the reputation of a solid and\ngood man like Mr. Timm. If it takes \"guts\" for Mr. Ford to reappoint him, I\nhave every assurance that Mr. Timm will be reappointed.\nIf the course of your responsibilities ever brings you out this way, we would be\nholiday season.\nso happy to meet you. My wife Janet and I join in wishing you and Bunny a happy\nYour Jim Cousin,\nJames E. Hanson\n1718 Aurora\nTacoma, Washington 98455\nR. FORD LIBRARY\nyouck\nTHE WHITE HOUSE\nWASHINGTON\nFebruary 14, 1975\nMEMORANDUM FOR:\nJACK MARSH\nRUSS ROURKE\nFROM:\nPHILIP BUCHEN T.W.B\nIn response to the request by the Robert Taft\nInstitute of Government that you contact\nDr. Ron Berman, Chairman of the Council for the\nNational Endowment for the Humanities, I recom-\nmend against your doing so. The Endowment is\nsupplied with Federal funds and we have a policy\nin the White House against contacts with procure-\nment agencies in regard to the award of contracts.\nThe situation in the present case is akin to an\nopinion. award of contract for procurement purposes in my\nFORD of LIBRARY\nTHE WHITE HOUSE\nWASHINGTON\nFebruary 3, 1975\nMEMORANDUM TO:\nJACK MARSH\nFROM:\nRUSS ROURKE R\nJack, Art Peterson is asking for your assistance in connection\nwith a financial assistance proposal that the Robert Taft Institute\nof Government has submitted to the Education Division of the\nNational Endowment for the Humanities. Specifically, he is\nsuggesting that you write directly to Dr. Ron Berman, Chairman\nof the Endowment's Council in support of their proposal. Please\nadvise whether you think such a letter from the White House is\nappropriate. Even though this organization is non-partisan, it\nis in competition with many other similar organizations for funding\nassistance.\nR-\nI Ques whether such a\nis againsticate, are wanted this\nth is what I thought he from\nthere same policy can cite\nIs Coursel of in down? we a. FORD\nGen to Apt. a turn m\nSEAL LIBRARY\nTHE ROBERT A. TAFT\nInstitute of Government\nTRUSTEES\nMrs. Preston Davie\nChairman\n420 Lexington Avenue, New York, New York 10017\n212 MU 4-0877\nLowell Wadmond\nVice Chairman\nJeremiah Milbank\nTreasurer\nJanuary 23, 1975\nRoss Reid\nJAN 24 1975\nSecretary\nMr. John Marsh\nHon. George Bush\nCouncilor to the President\nErwin D. Canham\nReed Coleman\nThe White House\nSERIAL FORD LIBRARY\nMarion J. Epley, III\nDr. Alexander Heard\nWashington, D. C. 20500\nHon. Frank Pace, Jr.\nDr. Arthur L. Peterson\nDear Jack:\nWilliam Wood Prince\nDr. Louis T. Rader\nRichard M. Scaife\nW. Clement Stone\nI appreciated very much your kind help in getting some Ohio business-\nHon. Robert S. Strauss\nmen involved in \"The Economic Conference\" some months ago. Now\nW. Allen Wallis\ncomes another request for help, this time on an educational matter.\nDavid K. Wilson\nHonorary\nMrs. Helen Taft Manning\nYou may recall much of our discussion at Doc Head's \"retreat\"\nEXECUTIVE DIRECTOR\nturned on the question of a declining political trust and sense of\nMarilyn Chelstrom\npolitical efficacy in America. Discussions at any local barber\nEDUCATION COMMITTEE\nshop, as well as all the popular polls, tell us that in both in-\nW. Allen Wallis\nstances (trust and efficacy) we have suffered serious erosion in\nChairman\nthe past two years. I know you and the President share my concern\nARTS AND SCIENCES\nhere.\nCOMMITTEE\nFelix W. de Weldon\nChairman\nOne organization which has a uniformly excellent track record over\nADVISORY COUNCIL\nthe past decade in raising the level of political trust and the sense\nDr. Albert L. Ayars\nof efficacy is the Robert A. Taft Institute of Government Seminars.\nDr. George C. S. Benson\nDr. Earl L. Butz\nBriefly, these two to six week graduate level institutes for elemen-\nHon. Harry F. Byrd, Jr.\ntary and high school teachers bring together twenty to thirty political\nHon. Henry E. Catto, Jr.\nHon. Francis L. Dale\nand governmental leaders with thirty teachers for the purpose of\nJustin Dart\ncreating a more sophisticated and more positive view toward the Amer-\nMrs. Walter B. Driscoll\nRichard Eells\nican political system and its leaders. Evaluations of the Seminars\nWalter Evers\nby participants and outside educators are extremely high and suggest\nHon. James A. Farley\nRev. Robert I. Gannon\nthat in terms of a cost/budget analysis they are perhaps the best\nRobert L. Garner\neducational \"buy\" in the summer institute market today.\nE. J. Gerrity, Jr.\nDr. Frank Glenn\nMortimor S. Gordon\nNow the point of this letter. Currently, the Robert Taft Institute\nBryce N. Harlow\nof Government has before the Education Division of the National\nHon. John H. Haugh\nAllan Hoover\nEndowment for the Humanities a proposal to assist with the support\nHon. Hubert H. Humphrey\nHon. David S. Ingalls\nand expansion of their program. Because I am a member of both\nDr. Walter H. Judd\ngoverning bodies (Taft Institute and Council on the Humanities) it\nHon. Richard G. Lugar\nJohn P. McGrath\nis illegal and improper for me to involve myself in discussion of\nGilbert S. Merritt, Jr.\nthis matter when it comes to the Council floor in late February.\nE. Frederic Morrow\nC. S. Harding Mott\nHon. Richard M. Nixon\nIt is proper to bring to your attention the fact that the President\nCharles S. Payson\nDr. Alan C. Rankin\nhas participated in these Seminars and to the best of my knowledge\nWilliam W. Reese\nis a very strong supporter of them. In addition, scores of Con-\nHoward J. Samuels\nHon. Caroline K. Simon\ngressional leaders are equally convinced that the Taft program is an\nDr. Robert H. Spiro\nLloyd B. Taft\nHon. Robert Taft, Jr.\nFrancis Thalheimer\nMrs. G. M. Trammell, Jr.\nHon. Joseph D. Tydings\nHon. Cecil H. Underwood\nDr. Paul A. Wagner\nFrederick K. Weyerhaeuser\nHon. Kevin H. White\nCote J. Younger\nTHE ROBERT A. TAFT\nMr. John Marsh\nInstitute of Government\nJanuary 23, 1975\nPage Two\nextremely important, well conceived, ably conducted, fair and timely\ncontribution to elementary and secondary teachers involved in teach-\ning about government and politics. You may hear from several of them.\nIn any case, Jack, I did want you to know of the Taft proposal, of the\nPresident's past involvement and great interest. It may be he would\nlike you to reflect this evaluation to Dr. Ron Berman, Chairman of the\nEndowment's Council. If you have a moment to peruse the project pro-\nposal, which is enclosed, I am certain you will be fascinated with the\nprogram. In fact, should your schedule allow, I would love to have you\nparticipate in our Seminar this summer at Ohio Wesleyan on Friday morning\nthe 27th of June at either 9:00 or 10:30. It would be a high point of\na very exciting Seminar. I hope you can join us.\nAll the best.\nSincerely,\nart\nArthur L. Peterson\nTrustee\nSEALE W. FORD LIBRARY\nALP:hb\nenclosure\nI don't know who in handling liainon between the which to\nP.S. and educations, initude, to agencies, Garment used much be\nHour Vu contact. Incidentally if 2 can be of any assistance I (in would be\na shand post yr to in help conguissional - I even interviewed lisiner at by Departments Dent for his level liannon part but 2 have hand\nnothing.\nare\nSBA\nTHE WHITE HOUSE\nWASHINGTON\nMarch 5, 1975\nDear Bob:\nAfter receiving your letter of February 19, I reviewed\nthe materials you transmitted which had been prepared\nby an attorney for the mushroom industry.\nMy previous acquaintance with this problem involved\nonly the question of whether Small Business Adminis-\ntration disaster loans were properly available to the\nmushroom processors as a result of the effect on their\nbusiness of the botulism bacteria. I now see that the\nproblem also arises from the effect on the domestic\nbusiness of mushrooms imported from Korea.\nI have discussed this matter with Bill Seidman and at\nhis suggestion I am sending the material from attorney\nRini to Mr. Ken Gunther at the Office of the Special\nTrade Representative.\nBest personal regards.\nSincerely yours,\nThil\nPhilip W. Buchen\nCounsel to the President\nHonorable Robert VanderLaan\n4745 Curwood, S. E.\nBERALD FORD UNITED\nGrand Rapids, Michigan 49508\ncc: Mr. Ken Gunther\nOffice of the Special Trade Representative\nTHE WHITE HOUSE\nwashington\nMarch 5, 1975\nMEMORANDUM FOR:\nKEN GUNTHER\nFROM:\nPHIL BUCHEN T.W.B.\nFor your appropriate handling.\nSERVICE E. FORD LIBRARY\nRegulatory\nTHE WHITE HOUSE\nWASHINGTON\nMarch 6, 1975\nDear Mr. Hock:\nOn behalf of the President, I would like to thank you\nfor your letter of February 13, 1975, concerning a\nproposed requirement of the Securities and Exchange\nCommission.\nIt is not proper for the President to intervene in a\nmatter that comes within the jurisdiction of an\nindependent regulatory agency and of the Federal\ncourts. However, you may be assured that your\nviews have been noted. The fact that you have\ntaken time to share your thoughts with the President\nis appreciated.\nSincerely,\nPhilip W. Buchen\nCounsel to the President\nMr. Roy E. Hock\nPresident\nTechnitnol, Inc.\n1952 East Allegheny Avenue\nPhiladelphia, Pennsylvania 19134\nFORD LIBRARY\nJj.1\nTechnitrol, Inc.\nFebruary 13, 1975\nThe President\nThe White House\nWashington, D. C. 20500\nDear Mr. President:\nI feel compelled to write you again and make you aware of another\nproposed requirement imposed upon our business by the Federal Govern-\nment.\nThis requirement, in simple terms, would require corporations falling\nunder the regulation of the Security and Exchange Commission to file\nadditional information on a quarterly basis with the Commission and\nto its shareholders of record. This requirement will impose another\nadditional cost to our Company with no legitimate benefit to the\nshareholders. It will consume the time and energies of management,\nwill require our consulting with our attorneys and public accountants\nand will diminish the possibility of our earning a fair return on\nour shareholders investment.\nI have enclosed a copy of my letter to the Secretary of the Securities\nand Exchange Commission in which I share my adverse opinion of such\nnew proposed regulation.\nI am writing you to ask your support in minimizing and diminishing the\namount of paper work required of business of our type which is un-\nnecessary and unproductive. I believe the energy of management and\nlabor in the United States should be directed toward increasing produc-\ntion rather than the creation of statistics, numbers and reports that\nhave no true value.\nSincerely,\nRoy 6 Hock\nRoy E. Hock\nTORD & LIBRARY\nPresident\njw\nenc.\nTechnitrol, Inc.\nFebruary 3, 1975\nSecretary\nSecurities and Exchange Commission\nWashington, D. C. 20549\nC\nReference: File No. S7-542\nDear Mr. Secretary:\nI have read and studied your \"proposal to increase disclosure of interim\nresults\" and feel obligated to write you the following comments.\nFirst, I believe your purpose in proposing an increase in disclosure is legiti-\nmate and sound. However, I do not believe that disclosure to the extent you\nhave proposed, nor possibly disclosure in utmost detail will accomplish the\npurpose \"to enable users of reports to understand and evaluate business opera-\ntions so that they can make rational investment decisions\".\nThe ability to fairly analyze trends in a business in order to infer future\nperformance is predicated on the data being complete and accurate. On a\nquarterly basis the ability to provide complete and accurate data is made\ndifficult by the following factors:\n1. The inventory used in the calculation of cost of sales is a\nbook value inventory since a physical inventory is taken and priced\nonly annually. To switch to taking a quarterly inventory would create\non additional cost and would cause at least a thirty day delay in\nreporting results.\n2. Some costs of operations are seasonal or sporadic in nature through-\nout the year. In some cases these costs are expensed as they occur and\nin other cases they are expensed on an accrual basis with a year end\nadjustment for the difference between the accrual and the actual. The\nfollowing are examples:\nA. Advertising\nBERAID FORD LIBRARY\nB. Heat and electricity\nC. Vacations and holidays\nD. Sales and performance bonuses\nE. Workmens compensation, medical and disability insurance\npremiums.\n3. The operating results can vary from quarter to quarter as a result\nof scheduled deliveries to our customer being uneven from quarter to\nquarter even though the work flow or manufacturing effort is on a level\nbusis. The result is that profits during the quarters when work-in-\nprocess is increasing (shipments are low) are decreased while profits\nduring those quarters when shipments are high are increased.\nTechnitrol. Inc.\nSecretary\nSecurities and Exchange Commission\n(Continued)\nFebruary 3, 1975\nThe ability of management to make an intelligent and meaningful analysis of\nthe results of operations on a quarterly basis is made difficult by the above\nfactors. It is only at a latter time and over a longer period, such as\nannually, that one can intelligently analyze the results of operations.\nSecondly, I believe the implementation of your proposal will cost our\ncompany at least 50% more in accounting and legal fees and in management time\nand effort over what we are presently expending under the current requirements\nfor reporting to our shareholders. I do not object to this increased cost if\nI believed it would give the shareholder and the financial investor better in-\nformation. However, I do not believe the increased disclosure is of increased\nvalue and, therefore, the net effect of this disclosure would be to decrease\nthe profits of the corporation and thus decrease the net worth to our present\nshareholders and our attractiveness to other financial investors.\nIn conclusion, I believe your proposed increased disclosure requirements are\nunsound and that they should not be adopted.\nSincerely,\nRoy E. Hock\nPresident\njw\nSENTA n. FORD LIBRARY\nRegulatory\nTuesday 3/11/75\n12:20 Steve Aug of the Star would like to talk with you\n484-4290\n(will be back in his office in about 20 minutes).\nHe had talked with Richard Berg, Exec. Secy.\n254-7020\nin the Administrative Conference, concerning a\nletter which Mr. Areeda wrote to them concerning\nguidelines for the regulatory commissions, and\nMr. Berg suggested he call you.\nI checked with Jane and she had no such letter in\nher files. Mr. Areeda apparently took the whole\nchron file.\nI called Mr. Berg's office to talk with him and he\nsaid that you had talked with Robert Anthony about\nit.\nSaid it is an innocuous memo Mr. Areeda\nsent to Chairman Anthony on December 9, 1974.\nMr. Berg said he sees nothing in it that couldn't\nstand the light of day -- but thought it should be\nchecked with you.\n12:50 I have sent a messenger over to the Administrative\nConference to pick up a copy for us.\n4:30 read\n4:55 they talked\nGERALD FORD\nBE\nShaw\nTHE WHITE HOUSE\nFAA work\nWASHINGTON\nNc'd\nDecember 9, 1974\ni)\nDear Bob:\nI appreciate your willingness to assist in the formulation of an\n\"anecdotal primer\" for the guidance of Regulatory Commissioners.\nI agree that the standards of the statutes, executive orders, and\nregulations are comprehensive. Without having thought the matter\nthrough, I am not aware of any need to rewrite the standards themselves.\nWhat is needed is a more concrete statement. The need for it is\nrevealed by the repeated missteps actually made by Commissioners of\nthe Regulatory Agencies.\nOn one recent occasion, for example, a Commissioner accepted a \"social\"\ninvitation from an \"industry member\" to holiday at a resort. Private\ntransportation was provided, as were accommodations and entertainment.\nThe latter were, I understand, later reimbursed by the Commissioner.\nOther \"industry members\" were present. It was said that no \"pending\nmatters\" before the Commission were discussed.\nIn another instance, a Commission member travelling on official business\nfound himself accompanied over the course of a week or so by an official\nof a major regulated company which had recently had or was about to\nhave a case before the Commission. It was said that no case was then\npending, however.\nMore generally, Commission members regularly find themselves at\nindustry meetings or otherwise in non-formal contacts with members of\nthe industry they regulate. Obviously, a Commission member cannot\nlive in a cocoon. Indeed, in developing the expertness they are meant\nto seek, contacts cannot and perhaps should not be limited to formal\nproceedings before the Regulatory Agencies.\nPORD . LIBRARY\n- 2 -\nThe problem of contacts becomes especially acute when the Commission\nmember has \"friends\" who are officials or representatives of the\nregulated firms. These friends will include not only those known to the\nCommissioner from his days in private life; they will also include those\nwho make the acquaintance of the Commissioner after he assumes his\npublic office.\nAgain, without having thought the matter through, I have trouble with\ndistinctions that rest on the existence of a pending case. Major members\nof an industry always have or are about to have a case pending before\nan Agency. The appearance of impropriety in social contact is always\ntroubling--especially where the \"friends\" in question are not those of\nlong standing. Furthermore, I doubt that holidays or the intimate\ncompany of sustained travel are the appropriate vehicles for\nfamiliarizing oneself with industry problems. Perhaps one could\ndistinguish undesirable socializing involving relatively few industry\nmembers from a more acceptable participation at a trade association\nmeeting (even at holiday resorts).\nThese observations and examples merely scratch the surface. I am\nsure that we can find other examples in the experience of the Office of\nthe Legal Counsel or through hypotheticals that we can readily dream\nup.\nOf one thing I am sure, the proper kind of primer dealing with concrete\nexamples can serve a useful educational function and will unquestionably\nkeep some future Commissioners out of trouble that they otherwise might\nget into.\nSincerely,\nPhil\nPhillip Areeda\nCounsel to the President\nHonorable Robert Anthony\nChairman\nAdministrative Conference of\nthe United States\nWashington, D. C. 20037\nSEAL R. FORD LIBRARY\nRod -\nLet's talk\nabout this\nwith Bill\nWalker\nRegulatory\nagencies\nTHE WHITE HOUSE\nWASHINGTON\nMARCH 24, 1975\nMEMORANDUM FOR:\nPHIL BUCHEN\nROD HILLS\nBILL WALKER\nFROM:\nPHIL AREEDA PA\nI enclose a memorandum from Dudley Chapman about\nRobert Timm. I agree with his recommendation.\nFORD LIBRARY A\nTHE WHITE HOUSE\nWASHINGTON\nMarch 24, 1975\nMEMORANDUM FOR:\nPHIL AREEDA\nFROM:\nDUDLEY CHAPMAN\nDC\nSUBJECT:\nRobert Timm - - New Allegations\n1. The President is empowered by 49 U.S.C. 1321(a)(2) to remove\nmembers of the CAB \"for inefficiency, neglect of duty, or mal-\nfeasance in office. \" Newspaper reports of current hearings before\nthe Senate Judiciary Subcommittee on Administrative Practice and\nProcedure raise a serious question as to whether Timm's handling\nof an investigation into alleged illegal corporate contributions\namounted to neglect of duty, inefficiency, or even misconduct.\n2. The allegations are that:\n(a) CAB investigators were limited to interviews with the chief\nexecutive officer only of each airline involved, could ask only six\nprescribed questions and were not permitted to ask follow-up questions.\nTimm admits wanting the investigation limited for the sake of speed\nbecause he anticipated Congressional inquiries, but denies prohibiting\nfollow-up questions. The testimony of two lawyers at the CAB Bureau\nof Enforcement, Stephen A. Alterman and James L. Weldon, Jr.,\nwas that they received their orders from their Chief, Gerald F.\nHadlock, then Deputy Director of the Bureau, and Hadlock could not\nrecall what orders he had given. Hadlock would not challenge the\ntestimony of the other CAB lawyers that the decision had come from\nTimm or \"the 10th floor\", referring to the Chairman's office.\nThomas J. Heye, now General Counsel of the CAB, was then Special\nAssistant to Timm and may have relayed the order.\n(b) Richard J. O'Melia, an FCC Commissioner and formeı head\nof the Board's Enforcement Bureau, alleged in sworn testimony that\nBERALD FORD LIBRARY\n2\nTimm had sent him a memorandum handcarried by Heye that\ninstructed him to stop investigating political contribution cases.\nO'Melia testified that he was shocked and refused to accept the\nmemo. Timm flatly denies the report. Heye, who was taken\nsuddendly ill during the hearings, has not yet testified. Timm\nsuggested that a memo he did send O'Melia at that time contained\na double negative that O'Melia may have overlooked in a rapid\nreading.\n3. Even accepting Timm's accountat face value, it appears\nundisputed that (i) the investigation was limited in the manner alleged,\nand as the result of some kind of instructions received from Timm's\noffice; (ii) whatever validity there may have been in limiting the\ninvestigation initially for speed, there is no indication that Timm\nauthorized or desired a more complete investigation later; and\n(iii) an adequate investigation was not made. Given the seriousness\nof the allegations, this lack of vigilance in pursuing them could be\ndeemed a neglect of duty and inefficiency in a matter of great\nimportance to public confidence in the CAB.\n4. Timm's conduct in this matter recalls his refusal to heed the\nwarnings of a lawyer acquaintance that airline executives would\nbe present on his notorious Bermuda trip. When added to his\ninsensitivity in traveling extensively with a TWA executive who had\nbusiness before the CAB, public confidence in Timm's integrity\nappears damaged beyond repair.\n5. Timm should be given a chance to tell his side of the story,\npreferably in a person-to-person interview here. This does not\nappear to be a problem of verifying detailed allegations. The\nenforcement responsibilities of the Board require that there be\npublic confidence in the rhembers' competence and sincerity. If\nthe facts bear out the appearance that he did not pursue the\npolitical contributions investigation conscientiously, he should be\nasked to resign, and if he refuses, dismissed for neglect of duty.\nand inefficiency.\nFORD LIBRANIA\nSome items in this folder were not digitized because it contains copyrighted\nmaterials. Please contact the Gerald R. Ford Presidential Library for access to\nthese materials.\nRegulations\nTHE WHITE HOUSE\nWASHINGTON\nMarch 24, 1975\nDear Abbott:\nThank you for forwarding the news clipping\nfrom the Washington Star concerning guide-\nlines for the behavior of regulatory agency\nmembers.\nWith appreciation,\nSincerely,\nThil\nPhilip W. Buchen\nCounsel to the President\nThe Honorable Abbott Washburn\nCommissioner\nFederal Communications Commission\nWashington, D.C. 20554\nGERALD FORD LIBRARY\nHON, PHILIP BUCHEN\nFEDERAL COMMUNICATIONS COMMISSION\nWashington, D. C. 20554\nOFFICE OF COMMISSIONER ABBOTT WASHBURN\n3/14/75\nPhil,\nT R. FORD LIBEARY\nThis in h good idea,\nwen for people with con-\nsiderable expirience in\nGovernment. It in different\nwhen you take on regulatory\nmy observation here in that\nThe Commissioners are super-\ncantions about These contacts.\n- Abbott Form A-28 7/74\nThe Washington Star March 12, 1975\nRegulators to Get/Guidelines on\nBy Stephen M. Aug\nWashington Star Staff Writer\nThe White House, con-\nProper Behavior\ncerned that regulatory\ncompany, and more gener-\nprimer dealing with con-\nthat we have any superior\nagency members have been\ngetting into compromising\nally the problems faced by\ncrete examples can serve a\nwisdom or knowledge that\ncommissioners who find\nuseful educational function\npositions, has called for\nwe ought .to pass on to\nthemselves in social or\nand will keep some future\nthem. I wouldn't want to of-\ndevelopment of guidelines\nto help the regulators avoid\nsemiformal contacts with\ncommissioners out of trouble\nfend the entire regulatory\npublicly embarrassing\nrepresentatives of indus-\nthat they otherwise might\ncommunity by suggesting\nthemselves.\ntries they regulate.\nget into,\" it says.\nthat we distrust them as a\nOfficials at both the\nNo names were mention-\ngroup or think they don't\ned in the letter, nor were\nPhilip W. Buchen, coun-\nknow how to behave.\"\nWhite House and the\nany agencies singled out by\nsel to Ford, said the White\nAdministrative Conference\ntitle.\nHouse hopes to use the\nRichard Berg, executive\n-which is working on the\nguidelines as a briefing\nsecretary of the Adminis-\nguidelines--confirmed yes-\nThe letter pointed out\ntrative Conference, said the\npaper for new appointees to\nterday that the request had\nthat while every agency has\ncome in Desember\nagencies. He explained that\nagency still is collecting\nmaterial for the primer. He\nTuesday 3/11/75\n12:20 Steve Aug of the Star would like to talk with you\n484-4290\n(will be back in his office in about 20 minutes).\nHe had talked with Richard Berg, Exec. Secy.\n254-7020\nin the Administrative Conference, concerning a\nletter which Mr. Areeda wrote to them concerning\nguidelines for the regulatory commissions, and\nMr. Berg suggested he call you.\nI checked with Jane and she had no such letter in\nher files. Mr. Areeda apparently took the whole\nchron file.\nI called Mr. Berg's office to talk with him and he\nsaid that you had talked with Robert Anthony about\nit.\nSaid it is an innocuous memo Mr. Areeda\nsent to Chairman Anthony on December 9, 1974.\nMr. Berg said he sees nothing in it that couldn't\nstand the light of day -- but thought it should be\nchecked with you.\n12:50 I have sent a messenger over to the Administrative\nConference to pick up a copy for us.\nDalbed to aug on March 11, if 1975.\nWould you like bappen to spot item than\nto All story he runs the\nFORD of LIBRARY GREATE\nCutheran\nShaw\nTHE WHITE HOUSE\nA\nWASHINGTON\nused\nDecember 9, 1974\nDec\n14\nDear Bob:\nI appreciate your willingness to assist in the formulation of an\n\"anecdotal primer\" for the guidance of Regulatory Commissioners.\nI agree that the standards of the statutes, executive orders, and\nregulations are comprehensive. Without having thought the matter\nthrough, I am not aware of any need to rewrite the standards themselves.\nWhat is needed is a more concrete statement. The need for it is\nrevealed by the repeated missteps actually made by Commissioners of\nthe Regulatory Agencies.\nOn one recent occasion, for example, a Commissioner accepted a \"social\"\ninvitation from an \"industry member\" to holiday at a resort. Private\ntransportation was provided, as were accommodations and entertainment.\nThe latter were, I understand, later reimbursed by the Commissioner.\nOther \"industry members\" were present. It was said that no \"pending\nmatters\" before the Commission were discussed.\nIn another instance, a Commission member travelling on official business\nfound himself accompanied over the course of a week or so by an official\nof a major regulated company which had recently had or was about to\nhave a case before the Commission. It was said that no case was then\npending, however.\nMore generally, Commission members regularly find themselves at\nindustry meetings or otherwise in non-formal contacts with members of\nthe industry they regulate. Obviously, a Commission member cannot\nlive in a cocoon. Indeed, in developing the expertness they are meant\nto seek, contacts cannot and perhaps should not be limited to formal\nproceedings before the Regulatory Agencies.\nFORD JOHN\n- 2 -\nThe problem of contacts becomes especially acute when the Commission\nmember has \"friends\" who are officials or representatives of the\nregulated firms. These friends will include not only those known to the\nCommissioner from his days in private life; they will also include those\nwho make the acquaintance of the Commissioner after he assumes his\npublic office.\nAgain, without having thought the matter through, I have trouble with\ndistinctions that rest on the existence of a pending case. Major members\nof an industry always have or are about to have a case pending before\nan Agency. The appearance of impropriety in social contact is always\ntroubling--especially where the \"friends\" in question are not those of\nlong standing. Furthermore, I doubt that holidays or the intimate\ncompany of sustained travel are the appropriate vehicles for\nfamiliarizing oneself with industry problems. Perhaps one could\ndistinguish undesirable socializing involving relatively few industry\nmembers from a more acceptable participation at a trade association\nmeeting (even at holiday resorts).\nThese observations and examples merely scratch the surface. I am\nsure that we can find other examples in the experience of the Office of\nthe Legal Counsel or through hypotheticals that we can readily dream\nup.\nOf one thing I am sure, the proper kind of primer dealing with concrete\nexamples can serve a useful educational function and will unquestionably\nkeep some future Commissioners out of trouble that they otherwise might\nget into.\nSincerely,\nPhil\nPhillip Areeda\nCounsel to the President\nHonorable Robert Anthony\nChairman\nAdministrative Conference of\nthe United States\nWashington, D. C. 20037\nSEC\nMonday 5/5/75\nMeeting\n5/14/75\n2 p.m.\n5:00 Ted Darreaux called to say they have an appointment\nwith Don Rumsfeld at 2:00 p.m. on Wednesday 5/14\nto discuss SEC personnel matters.\nWondered if you might be free at 2:45 that day so\nthey cuuld bring you up to date.\nHe will let us know later who will be coming.\nFORD LIBRARY 07VU38\nEPS FORM 25\n(03/75)\nEXECUTIVE PROTECTIVE SERVICE\nTo:\nOfficer-in-charge\nAppointments Center\nRoom 060, OEOB\nPlease admit the following appointments on Saturday, June 21\n, 1975\n8:30 AM\nfor Roderick Hills (Roosevelt Room)\nof\nWhite House\n:\n(Name of person to be visited)\n(Agency)\nMichael Pertschuk\nMr. Lynn Sutcliffe\nEdward Cohen\nThomas Susman\nArthur Pankopf\nMichael Lemov\nPaul Hoff\nJonathan Rose\nPaul MacAvoy\nSidney Jones\nCal Collier\nPaul Leach\nDudley Chapman\nLynn May\nSeorge Eads\nFORD in LIBRARY\nSandy Serson\nJordan Lewis\nDon Baker\nMEETING LOCATION\nRoosevelt Room\nBuilding\nRequested by\nEva Daughtrey\nWest Wing\nX 6611\nRoom No. West Wing\nRoom No.\nTelephone\nTime of Meeting\n8:30 AM\nDate of request\n6/20/75\nAdditions and/or changes made by telephone should be limited to three (3) names or less.\nDO NOT DUPLICATE THIS FORM.\nAPPOINTMENTS CENTER: SIG/OEOB - 395-6046 or WHITE HOUSE - 456-6742\n6/21/95\nMichael Pertschuk\nMr. Lynn Sutcliffe\nEdward Cohen\nThomas Susman\nArthur Pankopf\nMichael Lemov\nPaul Hoff\nJay Cutler\nHarrison Loesh\nDavid Stang\nBailey Guard\nJonathan Rose\nPaul MacAvoy\nSidney Jones\nCal Collier\nStan Morris\nPaul Leach\nDudley Chapman\nLynn May\nGeorge Eads\nJordan Lewis\nSandy Gerson\nDonald Baker\nFORD - LIBRARY 07VU38\nTHE WHITE HOUSE\nRegulatory\nWASHINGTON\nJuly 25, 1975\nDear Mr. Harrington:\nOn May 9, 1975, you replied directly at the request of the\nWhite House to a letter by David L. Herndon, of the firm of\nDavies, Richberg, Tydings, Landa and Duff, concerning some\nalleged restrictive effects of the Federal Home Loan Mortgage\nCorporation requirements.\nOn May 14, 1975, Mr. Herndon again wrote the President\nenclosing an analysis of the effects of Federal regulation in\nthis field. The White House has no familiarity with the substance\nof the matters Mr. Herndon has rais ed. The tone of his arguments,\nhowever, suggests that there may be a problem of excessive\nFederal regulation that would merit re-examination to evaluate\nits usefulness and the possible desirability of changes. Since\nthe substance of your reply of May 9, 1975, indicated that the\nspecific action Mr. Herndon complained of was mandated by\nstatute, it may be appropriate to consider whether changes in\nthe legislation would be appropriate. Such an examination would\nbe in line both with the Presidential statements referred to in\nMr. Herndon's original letter and, especially, of the comprehensive\ndrive for a review and re-evaluation of the effect of Federal\nregulations on the economy, which is a key point in the President's\ndomestic program. A transcript of the President's recent meeting\nwith the heads of the ten principal independent regulatory agencies\nis enclosed and should give you a clear sense of the breadth and\nconviction of the President's thinking in this area.\nBERALD FORD\n-2-\nI would appreciate having your thoughts on this. Copies of the\nreferenced correspondence are attached.\nSincerely,\nThily W.Buclen\nPhilip W. Buchen\nCounsel to the President\nMr. Philip N. Harrington\nFederal Home Loan Mortgage Corporation\n311 First Street, N.W.\nWashington, D. C. 20001\nTHE WHITE HOUSE\nWASHINGTON\nMay 30, 1975\nMEMORANDUM FOR:\nDUDLEY CHAPMAN\nFROM:\nPHILIP BUCHEN T.W.B.\nKindly review the attached file submitted\nto me by Tod Hullin and recommend an\nappropriate response for my signature.\nAttachment\nEva,\nDo NOT Send.\nWe have m. Bucher's\noriginal memo on our backeys\nover here.\nSTATE E. FORD\nns.\nTHE WHITE HOUSE\nWASHINGTON\nMay 29, 1975\nMEMORANDUM FOR\nPHIL BUCHEN\nFROM\nTOD HULLIN\nr\nSUBJECT\nALLEGED DE FACTO INDUSTRY REGULATION\nBY FEDERAL HOME LOAN MORTGAGE\nCORPORATION\nThe initial letter in the attached package complains of\nslow approval eligibility by the FHLMC of a particular\nmortgage company. On the recommendation of HUD, this\ncorrespondence was referred to FHLMC for routine reply.\nOn May 14, another letter was forwarded to the President\nindicating a continued broader interest in FHLMC's\nde facto regulation of mortgage companies.\nAccordingly, I am forwarding this file to your office\nfor consideration and appropriate handling.\nMany thanks.\nDO NOT Send\nRegulatory\nTHE WHITE HOUSE\nWASHINGTON\nJuly 25, 1975\nDear Mr. Herndon:\nThis will acknowledge your second letter to the President\nof May 14, 1975, concerning what you assert to be restrictive\neffects of the Federal Home Loan Mortgage Corporation (FHLMC)\nstandards on the availability of mortgage funds. Your letter has\nbeen referred to the FHLMC with a request for an analysis and\nrecommendations concerning the material you submitted. You\nmay be assured that the results of that analysis will receive\nfull consideration within the Administration.\nSincerely,\nPhilip W. Buchen\nCounsel to the President\nMr. David L. Herndon\nDavies, Richberg, Tydings,\nLanda & Duff\n1125 - 15th Street, N.W.\nWashington, D.C. 20005\nbcc: Philip N. Harrington\nOF\nDEPARTMENT THE 1789 TREASURY\nTHE\nRegulatory\nTHE DEPUTY SECRETARY OF THE TREASURY\nagency\nWASHINGTON, D.C. 20220\nAugust 5, 1975\nMEMORANDUM FOR THE HONORABLE PHILIP W. BUCHEN\nCOUNSEL TO THE PRESIDENT\nWe have a verbatim tape of the news conference\nwhich contained the Secretary's remarks about the\nslowness of the regulatory process in the Star News\ntelevision station matter.\nThat was reproduced literally in the body of the\nattached article in the Star News and we have agreed\nthat this is a correct reproduction.\nBill Simon's position is clear. He was complaining\nabout the delay of the regulatory process.\nThe comments we have received since the article\nwere generally favorable press queries. We have not\nhad to frame a letter answer to people criticizing the\ncomment as yet.\nIf you want anything else, please call.\nStephen Atror S. Gardner\nAttachment\nBERALD FORD\nWashington Star-News\nFRONT PAGE\nJUL 31 1975\nSimon Assails FCC on Star Case\nTreasury Secretary William E.\nwrong, or favorable or un-\nAllbritton applied to the\nSimon has assailed as \"a coward's\nfavorable. We're not talking\nFCC for a waiver eight\nway out\" the Federal Communica-\nabout the substance. I just\nconsider it absolutely\nmonths ago. The FCC voted\ntions Commission's decision to delay\naction on Washington Star publisher\nunconscionable for them to\n6-1 Monday to hold public\nJoe L. Allbritton's request for a waiv-\nwash their hands.\nhearings for more informa-\n\"And if it's true that this\ntion before ruling on the\ner that would allow him to gain effec-\napplication, a decision\ntive control of both the newspaper\nnewspaper is in financial\nwhich could delay the out-\nand its broadcast stations here.\ndifficulties, (and) I have to\ncome for more than a year,\nIn answer to a question on whether\nbelieve it is true, do they go\naccording to communica-\nthe White House should apply \"heat\"\nout of business in a year as\ntions lawyers.\nTHE WHITE HOUSE\nRegulatory\nWASHINGTON\nAugust 26, 1975\nMEMORANDUM FOR PHILIP BUCHEN\nFROM:\nDOUGLAS P. BENNETT\nDPB\nSUBJECT:\nVacancies on Regulatory Boards\nand Commissions\nAs you know, during the next few months there will be\nvacancies on several regulatory boards and commissions--\nspecifically, the Interstate Commerce Commission, the\nNational Labor Relations Board, the Federal Trade Com-\nmission and the Consumer Product Safety Commission.\nI would like to call on you from time to time to talk\npersonally with our candidates for these appointments.\nThe President feels strongly about regulatory reform and\nyour insight and reaction to these candidates will be\nvery important and helpful to us in our staffing process.\nRather than ask you to simply review a resume, I feel\nthat a personal interview would be far more beneficial\nto all.\nAs candidates are identified by our office, I shall call\nyou to arrange a convenient time for you to meet with them.\nI appreciate your assistance.\nGERALD FORD LIBRARY\nTHE WHITE HOUSE\nWASHINGTON\nAugust 26, 1975\nMEMORANDUM FOR PHILIP BUCHEN\nFROM:\nDOUGLAS P. BENNETT\nSUBJECT:\nVacancies on Regulatory Boards\nand Commissions\nAs you know, during the next few months there will be\nvacancies on several regulatory boards and commissions--\nspecifically, the Interstate Commerce Commission, the\nNational Labor Relations Board, the Federal Trade Com-\nmission and the Consumer Product Safety Commission.\nI would like to call on you from time to time to talk\npersonally with our candidates for these appointments.\nThe President feels strongly about regulatory reform and\nyour insight and reaction to these candidates will be\nvery important and helpful to us in our staffing process.\nRather than ask you to simply review a resume, I feel\nthat a personal interview would be far more beneficial\nto all.\nAs candidates are identified by our office, I shall call\nyou to arrange a convenient time for you to meet with them.\nI appreciate your assistance.\nRegulatory\nTHE WHITE HOUSE\nWASHINGTON\nOctober 10, 1975\nMEMORANDUM FOR:\nJON ROSE\nTHROUGH:\nPHIL BUCHEN P.W.B.\nFROM:\nDUDLEY CHAPMAN D.C.\nSUBJECT:\nParticipation by Antitrust Consumer\nUnit in Regulatory Proceedings\nAt the last meeting of the DCRG, you asked for comment on the\nAttorney General's interest in having the Antitrust Division\nparticipate in rate-making proceedings through its Consumer\nUnit.\nI have discussed this with Rod Hills and Ken Lazarus. We all\nagree that: (1) successful opposition to a new consumer agency\nwill require that we have a credible alternative, (2) it is good\ngovernment policy to represent the interests of consumers in\nregulatory proceedings, and (3) Justice is the logical agency to\ndo it. There is some overlap with COWPS, but we see your\nrespective functions as complimentary. COWPS is a White House\nlevel, policy-making unit, while Justice has a litigating function.\nThis is a logical and promising area for regulatory reform, and\nshould be promoted as such. I would appreciate your keeping us\nthe DCRG.\ninformed of your plans and progress, both directly and through\nCC: Rod Hills\nKen Lazarus\nFORD LIBRARY"
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