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This file contains material relating to the Domestic Council Review Group on Regulatory Reform and President Ford's meetings with regulatory commissioners.
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Regulatory Reform (12)
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Regulatory Reform (12)
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This file contains material relating to the Domestic Council Review Group on Regulatory Reform and President Ford's meetings with regulatory commissioners.
citationUrl
collections
James M. Cannon Files (Ford Administration)
James Cannon's Issues Files
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Aeronautics, Commercial
Antitrust law
Government regulation
Independent regulatory commissions
Intergovernmental relations
Legislation
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1976
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1975-06-01
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1975
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The original documents are located in Box 29, folder "Regulatory Reform (12)" of the James
M. Cannon 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 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States of America his copyrights in all of his unpublished writings in National Archives collections.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.
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.
Digitized from Box 29 of the James M. Cannon Files at the Gerald R. Ford Presidential Library
CC: Quern
OFFICE WTM PRESIDENT UNITED
EXECUTIVE OFFICE THE PRESIDENT
OFFICE OF MAN.GEMENT AND BUDGET
STATES
WASHINGTON studio 20508
1
Honorable James M. Cannon
Executive Director
Domestic Council
The White House
Washington, D.C. 20500
Dear Mr. Cannon:
we In
Since the President announced his government-wide effort
to reduce the number of reports, 37 percent of the
President's goal was met in the first two months (as of
April 30, 1976). While this achievement is commendable, we
have a particularly tough task ahead. By June 30, 325 more
reports must be eliminated government wide.
I would like to share with you, the President's thoughts
in recent speeches.
"When I was in the Congress, when I was Vice President,
and now as President, I keep hearing that individuals
and businesses are overwhelmed with forms, government
information requests, so I asked the Office of Manage-
ment and Budget how many Federal Government forms are
there that are sent out to individuals or groups
or businesses. It was 5,200. I issued an order -
and it darn well better be lived up to - they
(Federal departments and agencies) had to cut that
10 percent and they have a couple of months to go."
The President's remarks at the
Mary F. Sawyer Municipal Auditorium
in LaCrosse, Wisconsin.
March 27, 1976
His message is clear and has been made in Milwaukee,
Dallas, Indianapolis, and other cities around the country
during the past few weeks.
FORD i LIBRARY GERALD
2
In order to properly evaluate how we stand in achieving the
initial goal of the President's paperwork reduction program,
I am requesting that each department and agency submit a
brief progress report to OMB by May 26 with:
1. A list of repetitive forms eliminated to date;
2. Candidates in the agency inventory for elimination
by June 30;
3. Total percentage reduction in repetitive forms
expected by June 30 and estimated savings in
reporting burden; and
4. Problems encountered to date and expected in
achieving the President's goal.
If you have any questions, please direct them to the
Clearance Office, 395-4529.
Sincerely,
100 Fernando Oaxaca
Associate Director for
Management and Operations
THE WHITE HOUSE
WASHINGTON
May 18, 1976
MEETING TO DISCUSS
ADMINISTRATION'S POSITION ON ANTITRUST LEGISLATION
Wednesday, May 19, 1976
9:00 AM - (30 Minutes)
The Oval Office
From: Edward Schmults
Q
I. PURPOSE
To meet with Senator Hruska and the Attorney General to review the
status of pending antitrust legislation and discuss the Administration's
position.
II. BACKGROUND, PARTICIPANTS & PRESS PLAN
A. Background: On April 6, the Senate Judiciary Committee
completed mark-up on the Hart/Scott Antitrust Improvements
Act (S. 1284). The bill is scheduled for Floor action this week.
In the House, three of the major provisions of S. 1284 are being
considered in separate legislation. The so-called parens patriae
bill has been passed and the Civil Process Act amendments were
approved on May 18 by the House Judiciary Committee without
objection.
On April 2 Senators Hart and Scott met with Justice Department
and White House Staff to urge Administration support for their
legislation and to determine possible areas of compromise. We
reemphasized the views expressed in your letters to John Rhodes
on parens patriae and Peter Rodino on the Civil Process Act
Amendments.
On May 4, 1976, you met with the Attorney General, Assistant
Attorney General Kauper and White House Staff to discuss the
Administration's position on the pending antitrust legislation.
At the meeting you indicated that you wanted to hear Senator
Hruska's views prior to making any decisions concerning
negotiations aimed at finding an acceptable bill in the Senate.
-2-
On May 7, you met with Senator Hruska on Air Force One
and heard his objections to S. 1284.
As you know, we are being urged by Senators Hart and Scott
to enter into negotiations aimed at producing an acceptable bill.
B. Participants: Senator Hruska, The Attorney General,
Philip Buchen, Max Friedersdorf, James Lynn, Jack Marsh,
Jim Cannon, Bill Kendall, Ed Schmults.
C. Press Plan: None. Meeting not to be announced. White
House photographer only.
III. TALKING POINTS
1. The purpose of this meeting is to review the status of
antitrust legislation currently before the Congress and
decide what approach we should take in working with the
Congress.
2. Roman, perhaps you would begin by giving us an overview
of the Senate's plans for action on S. 1284 and what you
would like to see the Administration do.
IV. ATTACHMENTS
Tab A
-
Outline of major features of the pending bills.
Tab B
- Options Memorandum, with attachments, prepared
by Ed Schmults
DERALD
LIBRARY
Major Antitrust Legislation
Before the Concress
FORD
GERALD
Stated
Senate
House
Administration Positions
1. Civil Process Act Amendments (S. 1284)
Civil Process Act Amendments (H.R. 39)
passed House Judiciary Subcommittee by
voice vote on April 28.
Provides for use of Civil Process Act
No provision
Opposes
powers in regulatory proceedings.
Provides for mandatory reimbursement
Reimburscment only of witnesses
No stated position
of third parties for expenses, with-
according to current standards.
out specific authorization for
appropriations.
XC exemption of information from
Provides an explicit exemption
Favors explicit exemption
disclosure under Froedom of Infor-
mition Act.
Provides grand jury information to
No provision
No stated position
FIC and private antitrust plaintiffs
after completion of civil or criminal
proceedings.
2. Promorcer Notification and Automatic
Premerger Notification and Automatic
Seay (S. 1284)
Stay (H.R. 13131) Judiciary Subcom-
mittee hearings are scheduled for
May 5.
Provides for 30 day notification with
Similar provision
Supports
20 day extension, prior to consummation
is
c: very large mergers and acquisitions
(involving transactions between $100
million and $10 million companies)
Provides for automatic stay, not to
Similar provision
Opposed-retain existing decisional LEW
exceed 60 days, with burden on defendant
to show why stay should not be issued.
An omnibus antitrust bill (S. 1284), containing five titles, was favorably reported to the full Senate on April 6. The
Sanate Judiciary Committee vote was 10-5. Opposed were Eastland, McClellan, Hruska, Thurmond, W. Scott.
-2-
Stated
Senate
House
Administration Positions
LIBRARY
Parens Patrice (S. 1284)
Parens Patriac (H.R. 8539) passed
2/
House by voice vote on March 18
FORD is
Scope: Limited to Sherman Act
Practical effect is limitation to willful
Limitation to price-fixing
GERALD
violations
price-fixing
Determs:
-Provides for mandatory award of
Court determined reduction from treble to
Favors limitation to single ages
troble damages
single damages if defendant acted in good
faith
Provides for statistical aggregation
No provision
Opposes
of damages in private class actions
Attorney's Fees:
--Count may award attorney's fees to a
Similar provision
Favor
defendent if state attorney general
acted in bad faith
Court may approve contingency fees
Flat ban against contingency fees
No stated position
according to standard criteria
Miscollancous Provisions (S. 1284)
No comparable House provisions
Brondens Clayton Act (including
Supports provision applying to Clayton
Rebinson-Patman ACE) to include
7 (mergers); opposes applying to
violations "affeeting" rather than
other sections of Clayton Act, in-
"in" interstate commerce.
cluding Robinson-Patman Act
Dismissal of claims 35 party rolying
Opposes
upon foreign statutes =0 justify
refusal to comply with discovery order.
Mandatory award of attorney's fees for
Favors discretionary awards
in unctive relief under Clayton Act.
Declaration of Policy (S. 1284)
None
No stated position
Sees forth assertions and conclusions
about Nation's commitment to a free
enterprise system, the docline of
compenition because b: monopoly and anti-
eligatitive Lehavior and the need for
vieórous antitrust chiorcement.
The President's letter of March 17 to Congressman Rhodes expressed serious reservations about the principle of parens intriac.
The President also expressed concern regarding specific provisions.
THE WHITE HOUSE
WASHINGTON
April 14, 1976
MEMORANDUM FOR THE PRESIDENT
FROM:
EDWARD C. SCHMULTS
Sg
SUBJECT:
Antitrust Legislation Now Before Congress
Issue
This memorandum outlines the status of omnibus antitrust
legislation pending before the Congress and requests your
guidance as to how we should proceed.
Background
The Administration has in the past been the champion of
vigorous antitrust enforcement and reducing government
regulation while Congress has largely been playing "catch-
up" ball. Recently the Administration's positive anti-
trust policy has been criticized by Members of Congress
and others because of our position on antitrust legislation
before the Congress. (See attached letter from Chairman
Rodino at Tab A.)
Nevertheless, Senators Hart and Scott, as a culmination
of years of work, are anxious to see important antitrust
legislation enacted into law this year and are anxious
to work with the Administration to arrive at an acceptable
bill.
Status of the Legislation
On April 2, Senators Hart and Scott met with White House
senior staff to urge firm Administration support for the
legislation and to determine possible areas of compromise.
We outlined to them the Administration's objections to
this legislation and recmphasized the views expressed in
your letters to John Rhodes on parens patriae and
Peter Rodino on the CID bill (see Tab B). Shortly there-
after, on April 6, the Judiciary Committee completed mark-up
on its legislative proposal, the Hart-Scott Antitrust
2
Improvements Act (S.1284). In the course of that mark-
up, both Senators referred to the White House meeting and
indicated their belief that suitable negotiations could
begin soon after the mark-up. They stressed flexibility
and a desire to accommodate Administration views.
In the House, three of the major provisions of S.1284 are
being considered in separate legislation. Following your
letter to Minority Leader Rhodes on the parens patriae
legislation, the House passed this bill, but modified it
to reflect some of your reservations concerning specific
provisions. The House Judiciary Committee will soon take
up the Administration's proposed amendments to the Civil
Process Act. Your March 31 letter to Chairman Rodino
urged favorable consideration of this legislation and
requested the Department of Justice to work closely with
the Committee on this bill.
Following action on the Civil Process Act amendments the
House Judiciary Committee is also expected to consider
premerger notification and mandatory stay legislation.
The Senate bill has a similar provision.
On March 31, Justice, Treasury, Commerce and the FTC agreed
on a position on the major provisions of the Senate and
House legislation. We have compared this position with
the bill reported from the Senate Judiciary Committee on
April 6 and believe that it would be possible to negotiate
an outcome close to this position. It is probable that if
legislation is enacted, it will be an omnibus bill. There-
fore, we are outlining below the main features of this
bill.
1. Parens Patriae. Any such omnibus legislation probably
would include a modified parens patriae provision as
both Houses are determined to make parens a condition
for enactment of the Administration's civil process
bill. Your March 17 letter to Minority Leader Rhodes
expressed serious reservations regarding the basic
principle of parens patriae, which allows state attorneys
general to seek damages in Federal courts as a result
of Federal antitrust violations.
In addition to your problems with the basic concept
of parens patriae, there are other major points of
difference between the Administration's position
and the legislation being considered in the Congress.
FORD is LIBRARY GERALD
3
The current Senate version of the parens patriae bill
is a significantly broader bill than that which recently
passed the House. The Senate bill as it now stands is
subject to the same criticisms we have directed at the
House bill. Nevertheless, it scems quite likely that
substantial amendments in this provision could be
accepted by the Senate.
Negotiable areas of importance to the Administration are:
limitation of scope to price fixing, elimination of
statistical aggregation in private class actions,
reduction to single damages, prohibition of contingency
fees and discretionary rather than mandatory award of
attorney's fees. For a further discussion of these
issues, see Tab C.
2. Antitrust Civil Process Act Amendments. The Senate and
House bills are in most respects compatible with the
Administration's position.
The Administration favors deleting the use of the
expanded civil process powers in regulatory agency
proceedings. It is anticipated that the House will
delete this provision.
The Administration also seeks exemption of information
obtained through this process from public disclosure
under the Freedom of Information Act. Although it is not
clear that such an exemption is necessary, many businesses
fear the possible applicability of the FOIA. The Senate
may be reluctant to grant such exemptions, and it may be
easier to achieve the exemption in conference.
Also, the Justice Department opposes a recent amendment
in the Senate bill which would require them to reimburse
third parties for expenses incurred in an antitrust
investigation.
There appears to be a good chance that these modifica-
tions will be accepted. However, there will be some
business opposition to the Civil Process Act amendments.
Bill Seidman's memorandum to you on this subject is at
Tab D.
FORD & LIBRARY GERALD
4
3. Premerger Motification and Diay Amendments. In addition
to establishing a premerger nozilication procedure, the
Serate bill creates an automatic injenction against
margers which are challenged by Federal enforcement
agencies. The Adminiotration has stated its opposition
to any stay provision, while reattirming its support
for a properly modified pre-merger notification procedure.
The final Senate mark-up provides that if a merger is
challenged by the Government, consummation of the merger
may be stayed until the court issues a decision on a
request for a preliminary injenction. However, the
stay can not exceed 60 days.
The burden would be on the defendant to demonstrate why
a preliminary injunction should not be issued. Senator
Scott has indicated a willingness to narrow this further
by shifting the burden of proof from the defendant to
the Government and to reducing the stay period.
The House will consider a similar provision. Although
there is strong support for some such provision, the
Administration has been against any automatic stay
provision.
4. Miscellaneous Amendments. The Senate bill also contains
a variety of miscellaneous provisions but the Administra-
tion only supports a provision which would amend Section 7
of the Clayton Act (mergers). This change is necessary
because of a recent Supreme Court decision limiting the
scope of Section 7 of the Clayton Act to reach only
violations "in" rather than "affecting" interstate
commerce. The Administration continues to oppose
expanding the scope to other sections of the Clayton
Act and the Robinson-Patman Act.
The Administration also opposes a provision which would
authorize dismissal of claims or defenses of any party
who relies upon foreign statutes to justify a refusal
to comply with a discovery order. The Justice Department
would also like to modify a provision requiring mandatory
award of attorney's fees for injunctive relief under the
Clayton Act. Justice prefers discretionary awards. No
similar miscellaneous provisions are likely to be
considered in the House:
&
FORD
GERALD
LIBRARY
5
5. Declaration of Policy. Finally, the Senate omnibus bill
contains a collection of assertions and conclusions
about the commitment of this country to a free enterprise
system, the decline of competition as a result of
oligopoly and monopoly, and the positive impact of
vigorous antitrust enforcement. It has been criticized
as not being based on economic consensus nor logically
connected to the procedural matters dealt with in the
body of .1284. The Administration has previously taken
no position on this provision.
Although some of the least supportable language has
been eliminated in the Senate mark-up, the Administration
would favor the elimination of this policy statement.
However, the Departments do not view further modification
or elimination as important as the modification of
certain substantive portions of the bill which are
considered above. Attached at Tab E is a table summarizing
the various provisions of the House and Senate bills.
Options:
At this stage, we have the following options:
1. Do not compromise the present Administration position.
2. Negotiate with the Senate to try to produce an
acceptable bill prior to a Senate floor vote early
next month.
3. Schedule a meeting to discuss these options.
The first option has a number of risks. If the Administration
takes no action, then it is likely that the Congress will
pass an unacceptable bill thus generating pressure for a veto
sometime this summer. On the other hand, there is some chance
that Administration silence at this time could slow down
the legislation in both Houses so that the legislation would
not be enacted. For example, an effort to filibuster the
bill in the Senate is possible.
Option 2 could substantially increase the chances of Congress
passing an acceptable bill. With your support, it is likely
that the White House staff and the Justice Department can
work with Senators Hart and Scott to agree to desirable
amendments prior to a Senate vote early next month and
avoid undesirable amendments on the Senate floor. This
FORD & GERALD LIBRARY
6
option would also help stimulate the House to move on the
Civil Process Act amendments and an acceptable premerger
notification bill.
Option 3 recommends a policy meeting on this subject, prior
to your choosing between options 1 and 2. We believe that,
in light of the complexity of the issues and the highly
fluid political environment, we should meet with you as
soon as possible.
Decision:
Option 1: Do not compromise Administration position until
Senate and House conference a bill
(Supported by
Option 2: Work affirmatively with Senators Hart and
Scott to try to produce an acceptable bill
prior to a Senate floor vote early next
month (Supported by
Option 3: Schedule a meeting
(Supported by
FORD 4 LIBRARY GERALD
wis.
Day. ILL
TAB A
CALIF
10M ILL.
WILLIAM HUNDATA MO.
CHARLE withing CALIF,
Congress of the United States
START DIRECTOR
CONYINS. 19. 9.51.
CARNER , CLING
HAMILTON 11'H,
10%
10° our FILMS FA.
M. CALDWILL
VA.
VALTER JAKHS, A'M.
CONGRO
WILLIAM %. COME - STRE
JAMES R. MAIS I.C.
care 05 CALLF.
PAUL $. MJ.
JOHN M. CHIO
Committee un the yndiciary
PRODUCT
WILLIAM
JOHN F. SERVING 0.10
ALANA. PARKIN
MEMBY 1. HYDE. ILL.
GEORGE DANILSON, CALIF.
JOINT
THOMAS N. KINDNESS, OHIO
PONGHT P. LIPINAM. NASS.
House of Representatives
MANAGE
BARJARA IONDAN. 1'X,
AMTHUR P.
RAY THOUNTON, B.H.
THOUGH WY
ELIZATE N.Y.
Mashington, D.C. 20515
DANIEL CURRY
EDWARD MEDINDRY, ICWA
FRINKLIN
MERMAN BACILLO. N.Y.
TROMAS
HOMANO L. MAZZOLI. KT.
Telephone: 202-225-3951
ALDORDER start
EDWARD w. PAITION, N.Y.
CONSTITUTIONS
CHRISTOPHER J. 0000, CONTL
ALAN 7.
VILLIAM J. HUGHES. H.J.
REPRETT FLEZ
MARTIN.A. PUSSO, ILL
March 17, 1976
BLAYMOND V.
The President
The White House
Dear Mr. President:
I was extremely distressed to learn today that you have withdrawn
your Administration's carefully articulated and frequently repeated support
for H.R. 8532, the Antitrust Enforcement Improvement Act (Parens Patriae).
In my judgment, enactment of this bill would constitute unquestion-
ably the most significant contribution to antitrust enforcement and the
deterrence of widespread antitrust violations in more than a quarter century.
The basic premise of the bill is that many if not most antitrust
violations have their principal impact upon the consumer, who pays more for
goods and services than he would if there were free and open competition.
The need for the bill arises because under our present antitrust enforcement
scheme, the consumer has no effective mechanism for seeking redress, in
light of the small value of individual claims and the enormous cost and
complexity of antitrust litigation. As a result, many violations go unpun-
ished and corporate violators reap - and retain -- billions of dollars in
illegal profits every year.
The bill would fill this enforcement void by empowering state
attorneys general to bring antitrust suits on behalf of consumers in their
states injured by antitrust violations. It would create no new substantive
antitrust liability. It would merely provide for the first time an effective
mechanism for the vindication of existing consumer claims and the enforcement
of long-standing policy.
The case for this bill has been made repeatedly and most persua-
sively by authorized representatives of your own Administration. On March
18, 1974, Thomas E. Kauper, Assistant Attorney General in charge of the
Antitrust Division, testified generally in favor of an earlier version of
FORD
GERALD
LIBRARY
The President
-2-
March 17, 1976
H.K. 8532. He suggested a number of amendments, many of which were
incorporated in the draft approved by the liouse Judiciary Committee on
July 24, 1975. The Administration's views regarding the Committee bill,
the present H.R. 8532, were sought again following Committee action.
Once again, Mr. Kauper was forthright in his support of the measure.
In a letter to me dated September 25, 1975, Mr. Kauper stated:
The Administration has taken a position in suppor' of
the basic concept of permitting a State to sue on behalf
of its citizens for damages sustained because of violations
of the Sherman Act. H.R. 8532 would establish a orkable
mechanism for assuring that those antitrust viola ions
which have the broadest scope and perhaps the most direct
impact on consumers do not escape civil liability.
Mr. Kauper went on to suggest one or two amendments designed to
strengthen the enforcement potential of H.R. 8532, concluding:
While we think the further refinements suggested bove
would strengthen the bill, we would still urge en ctment
of this legislation.
Mr. Kauper's letter made it clear that this was the mature and
considered position of the entire Administration:
The Office of Management and Budget has advised this
Department that it has no objection to the submis ion
of this report from the standpoint of the Adminis ration's
program.
Within the last month, while testifying on another matter, Mr.
Kauper went out of his way to praise H.R. 8532 and the Judiciary Committee's
contribution to antitrust enforcement in reporting it to the House.
These views were echood recently in a significant speech by Deputy
Assistant Attorney General Joe Sims, who stated in Dallas, "exas, on February
27, 1976 that "as we put more resouces into the field, we continue to find
that price-fixing is a common business practice." Pointing to the need for
pending legislation to provide greater antitrust enforcement capability, Mr.
Sims went on:
Strangely enough, while the business community is taking
a strong public stand for free enterprise as a concept,
it is also mounting an enormous lobbying effort in an
attempt to delay, to cut back or to prevent the passage
of such legislation.
And so again, the call for a return to free enterprise
takes on a somewhat hollow ring.
FORD is LIBRARY GERALD
The Administration's support for the provisions of H.R. 8532
has likewise been repeatedly expressed in the Senate. Mr. Kauper testified
in favor of Title IV of S. 1284, the counterpart of H.R. 8532, in May of
1975, and as recently as February 19, 1976, Deputy Attorney General Harold
Tyler expressly reaffirmed the Administration's support for Title IV in a
letter to the Minority Leader of the Senate, the Honorable Hugh Scott, who
is a cosponsor of S. 1284.
Even more is at stake than the credibility of considered statements
by high ranking and fully authorized officials of your Administration. Your
withdrawal of this long-standing support for H.R. 8532 is utterly at odds with
your own repeated statements favoring vigorous and effective enforcement of
the antitrust laws.
I could not put the case for the necessity of effective antitrust
enforcement to the continuation of a free competitive economy better than
you have on numerous occasions. On October 8, 1974, you told a Joint Session
of Congress:
To increase productivity and contain prices, we must end
restrictive and costly practices, whether instituted by
Government, industry, labor, or others. And I am deter-
mined to return to the vigorous enforcement of the antitrust
laws.
On April 18, 1975, you told the White House Conference on Domestic
and Economic Affairs that "Vigorous antitrust enforcement must be part of the
effort to promote competition."
In your most recent State of the Union message, on January 19, 1976,
you told the Congress that "This Administration
will strictly enforce
the federal antitrust laws."
You put the matter perhaps most eloquently in your remarks to the
American Hardware Manufacturers Association on August 25, 1975:
It is sad but true -- too often the Government walks with
the industry along the road to monopoly.
The end result of such special treatment provides special
benefits for a few, but powerful, groups in the economy
at the expense of the taxpayer and the consumer.
Let me emphasize this is not -- and never will be -- an
Administration of special interests. This is an Adminis-
tration of public interest, and always will be just that.
Therefore, we will not permit the continuation of monopoly
privilege, which is not in the public interest. It is my
job and your job to open the American marketplace to all
FORD GERALD LIBRARY GERALD
comers.
Despite these ringing declarations of commitment to antitrust
policy and enforcement, your actions in recent weeks have struck repeated
The President
-4-
ch 17, 1976
blows at the hopes of the American people that these goals would be
realized. On February 19, 1976, despite previous affirmations of Adminis-
tration support, you withdrew, through Deputy Attorney General Tyler, your
blessing from important injunctive provisions of Title V of S. 1284.
On March 4, 1976, an obviously distressed Assistant Attorney
General Kauper had to tell' our Committee that the Administration opposed
S. 1136, already passed by the Senate, which would have committed significant
additional funds to the federal antitrust enforcement effort.
And yesterday you withdrew from almost two years of public support
for the concept of H.R. 8532.
I hope that you will reconsider your pronouncement of yesterday
and reaffirm your earlier support for a bill designed to put sorely needed
teeth in our antitrust enforcement scheme.
Otherwise, everyone will have lost significantly. The considered
pronouncements of your Administration on pending legislation will lose all
credibility if the rug is to be pulled out repeatedly by last-minute
presidential action. More important, the consumers and businessmen of this
country who stand to benefit from free and open competition and the attendant
reduction of inflation will have lost the assistance of a truly significant
piece of legislation.
The antitrust laws are the basic charter of our free enterprise
system, and I urge you to join in the effort to secure their vigorous
enforcement in the public interest.
Very truly yours,
Pen Rink
PETER W. RODINO, JR.
Chairman
PWR:edg
FORD is LIBRARY GERALD
ACCRASE
Chrch 17, 1016
TAB D
Office of the White House Press Secretary
THE WHITE HOUSE
TEXT OF A LETTER BY THE PRESIDENT
TO REPRESENTATIVE JOIN J. RHODES
March 17, 1976
Dear John:
As I outlined to you on Tuesday, March 16, I support vigorous antitrust enforcement,
but I have serious reservations concerning the parens patriae concept set forth in
the present version of H.R. 8532.
I question whether federal legislation is desirable which authorizes a state
attorney general to sue on behalf of the state's citizens to recover treble damages
that result from violations of the federal antitrust laws. The states have the
ability to amend their own antitrust laws to authorize parens patriae suits in
their own courts. If a state legislature, acting for its own citizens, is not
convinced the parens patriac concept is sound policy, the Administration questions
whether the Congress should bypass the state legislatures and provide state attorneys
general with access to the federal courts to enforce it.
In addition to by reservations about the principle of parens patrice, 1 an concerned
about some specific provisions of the legislation developed by the House Judiciary
Committee.
The present bill is too broad in its reach and should be narrowed to price fixing
violations. This would concentrate the enforcement on the most important anti-
trust violations.
In addition, the Administration is opposed to mandatory treble damage awards in parens
patriae suits, preferring instead a provision which would limit awards only to the
damages that actually result from the violation. The view that federal penalties
were inadequate, which has been used to justify mandatory treble damages in the past,
is no longer justifiable given the substantial increases in these penalties in
recent years.
The Administration opposes extension of the statistical aggregation of damages,
beyond parens patriae legislation, to private class action suits because this is
outside of the appropriate reach of this legislation.
Finally, the Administration prefers discretionary rather than mandatory award of
attorney's fees, leaving such awards to the discretion of the courts.
During the last two years, the Administration has sought to improve federal
enforcement efforts in the antitrust 3rea and the resources devoted to antitrust
enforcement have increased substantially. In December 1974, I signed the Antitrust
Penalties and Procedures Act which increased maximum penalties from $50,000 to $1 million
for corporations and $100,000 for individuals. As I indicated above, I support
vigorous antitrust enforcement, but I do not believe H.R. S532 is a responsible way
to enforce federal antitrust laws.
Sincerely,
/s/ Gerald R. Ford
The Honorable John J. Rhodes
FORD & LIBRARY GERALD
Minority Lender
House of Representatives
Washington, D.C. 20515
TAB B
THE WHITE HOUSE
WASHINGTON
March 31, 1976
Dear Chairman Rodino:
During the last year and a half, my Administration has supported
effective, vigorous, and responsible antitrust enforcement. In
December 1974, I signed legislation increasing penalties for
antitrust violations. In addition, I have submitted several legis- are
lative proposals for regulatory reform which would expand
competition in regulated industries. Assuring a free and com-
petitive economy is a keystone of my Administration's economic
program.
In October 1974, I announced my support of amendments to the
Antitrust Civil Process Act which would provide important tools
to the Justice Department in enforcing our antitrust laws. My
Administration reintroduced this legislation at the beginning of
this Congress and I strongly urge its favorable consideration.
I have asked the Department of Justice to work closely with
your Committee in considering this antitrust legislation. I
would hope that the result of this cooperation will be effective
and responsible antitrust legislation.
Sincerely,
R. Fl
The Honorable Peter W. Rodino, Jr.
Chairman
The Committee on the Judiciary
House of Representatives
Washington, D. C. 20515
FORD i LIBRARY
TAB C
Parens Patriae
The House-parsed parens pabrice bill (H.R. 8532) and Title IV
of S. 1234, the Senate counterpart on which the Judiciary
Committee completed action on April 6, aj for in a number of
respects.
Title IV had been a significantly broader bill which was
narrowed in the Senate mark-up in two ways:
1. A provision which would authorize a State to
recover damages to the "general economy" of that
State or its political subdivisions was deleted.
2. The bill was modified to apply in general to future
violations, rather than retrospecuively.
The House-passed bill, which was narrowed substantially,
compares with Title IV as follows:
1. Scope. The House bill was, in practical effect,
narrowed to willful price-fixing violations only,
by permitting statistical aggregation of damages
only in such cases. The Senate version applies
to violations of the Sherman Act.
2. Statistical Accrecation in Private Class Actions.
The House eliminated a provision to permit
aggregation in consumer class action suit. The
Senate retained this provision.
3. Damaces. The House provided for a court determined
reduction of damages from treble to single damages
if a defendant could prove he was acting in good
faith or without reason to believe he violated the
antitrust laws. The Senate bill provides for
mandatory award of trcble damage.
4. Attorneys Pees. Both the House and Senate provide
that a court may award reasonable attorney's fees
to a prevailing defendant upon finding the state
attorney general acted in bad faith.
5. Continuency Pees. The House provided for a flat
ban accinst contineency fee arrangement. The
Senate bill requires the approval of the court for
any attorney ice arrangement according to standard
critoria (e.c., number of hours of time multiplied
by reasonable hourly rate, adjusted up or down for
risk, complexity, or other factors).
LIBRARY GERALD A. FORD
2
Although a fundamental issue as to the principle of parens
patriae legislation remains, the House bill is much closer
to the modifications favored by the concerned Dopartments.
These are: limitation of scope to price-fixing; climination
of statistical aggregation in private actions and reduction
to single damages in certain cases (possibly even a flat
limitation to single damages) ; prohibition of contingency
fees.
The Justice Department is also exploring options that would
require prior Federal action or approval, before an action
/
could be taken by a state attorney general under the parens
patriae provision.
FORD & LIBRARY GERALD
TAB
U
THE WHITE HOUSE
WASHINGTON
March 29, 1976
MEMORANDUM FOR:
THE PRESIDENT
FROM:
L. WILLIAM SEIDMAN
gos
SUBJECT:
Administration Antitrust Legislation
Issue
Should the Administration reaffirm its support for the
amendments to the Antitrust Civil Process Act (the CID
bill) ? If so, should a Presidential letter stating this
position be forwarded to the Judiciary Committees?
Background
Congress is moving toward enactment this spring of canibus
antitrust legislation. The Senate Judiciary Committee is.
in the process of marking up S. 1284, "the Hart-Scott
Omnibus Antitrust Act," and a final vote is expected on
April 6. A brief summary, prepared by the Justice Depart-
ment, of S. 1284 and the positions taken to date by the
Administration on its various provisions is set forth at
Tab A.
In the House, the various titles incorporated in S. 1234
are being considered separately. H.R. 8532, the parens
patriae bill, recently passed the House with amendments
that reflected some of the concerns raised in the March 17
letter to Congressman Rhodes. A pre-merger notification
bill similar to Title V of S. 1284 will be introduced
shortly by Chairman Rodino. Finally, the House Judiciary
Subcommittee is scheduled to mark up on March 31 the
Administration's proposal for amendments to the Antitrust
Civil Process Act (H.R. 39), which would allow the
Department of Justice to take testimony in pre-complaint
antitrust investigations.
This logislation has come under heavy attack from the
business community. The modifications of the Administration
position on the injunctive relief provisions for mergers
in S. 1284 and the House parens patriae bill have been
FORD & GERALD LIBRARY
%
interpreted as resulting from business pressure. Con-
sequently, Senator Scott has requested that be and
Senator Hart meet with you to explore the developed of
an acceptable position on the Senate bill.
The timing of legislative action requires that the
Administration position on the House and Sensite legislation
be communicated quickly.
The Civil Process Act Amendments (H.R. 39)
These amendments, together with legislation to increase
antitrust penalties, were endorsed in your Economic
Address of October 8, 1974. The increase in penalties was
enacted and signed into law in December 1974, but the
Civil Process Act amendments died in the 93rd Congress.
Attorney General Levi resubmitted this legislation to the
94th Congress and hearings have been held in both Houses.
The present Civil Process Act was enacted in 1962 to
assist the Department of Justice in investigating possible
antitrust violations. The Act helps the Department determine.
in advance of filing a suit, whether a violation has occurred.
It was enacted because pre-complaint discovery was preferable
to having the government file complaints based upon sketchy
or inaccurate information. It was designed to make possible
more informed decisions by Justice prior to creating the
burden, expense, and adverse publicity of a full government
lawsuit.
The 1962 Act, however, was a limited effort. The Antitrust
Division may only serve the Civil Investigative Demand
(CID) --a pre-complaint subpoena. on suspected violators,
the so-called "targets". The CID may only be served on
businesses for the purpose of obtaining documents relevant
to the investigation.
The proposed legislation would permit CID's to be issued
not only to "targets" of the investigation, but also to
third partics--customers, suppliers, competitors--who may
have information relevant to the investigation even though
they themselves are not suspected violators. CID's could
thus be served not only on a business entity, but also on
individuals (e.g., a witness to a meeting). Also, a CID
recipient could be compelled not only to produce documents,
but also to give oral testimony and answer written questions.
FORD & LIBRARY GERALD
3
The Justice Department views enactment of this legislation
as a vital step designed to close a gap in their anti-
trust enforcement authority. They believe it is necessary
to assure that the major increase in funds appropriated to
antitrust enforcement efforts during the last two hudgets
will be utilized in the most efficient and effective manner.
The bill will accord the Department of Justice esseptially
the same investigatory power now possessed by the FTC and
numerous other Federal agencies (e.g., Treasury, Agriculture
Labor, Veterans Administration, and most regulatory agencies)
In addition, at least 18 states (including Virginia, Texas.
Arizona; New Hampshire, Florida, and New York) have enacted
similar legislation, most within the last ten years.
Despite the inclusion in the bill of a variéty of safeguards
to protect against even the appearance of governmental over-
reaching, and numerous changes in the legislation accepted
by the Justice Department and Judiciary Committee staffs,
opposition to the legislation from the business community
continues. Attached at Tab B is a discussion of the major
objections that have been raised.
Option 1:. Reaffirm Adninistration support for the Civil
Process Act amendments and related legislation
with a letter to the House and Senate Judiciary
Committees.
In light of the Administration's recent modifications in its
position on premerger notification and parens patrice, the
Justice Department believes it is essential to reailirm in
writing our support for the amendments to the Antitrust Civil
Process Act. A proposed Presidential letter to the Chairmen
of the House and Senate Judiciary Committees reaffirming your
support for the amendments is attached at Tab C. This letter
also indicates that you have asked the Justice Department to
work with the Committees to achieve passage of this legisla-
tion.
Option 2: Reaffirm Administration support for the Civil Pro-
cess Act amendments by instructing Justice to in-
dicate such support during the House mark-no session
This approach would reaffirm the Administration's support
without highlighting your personal involvement. However,
Justice indicates that several members of the House Judiciary
Committee have said that in light of the change of Administra
tion position on parens patriae and much media speculation on
this issue, they cannot accept an expression by the Depart-
ment of Justice as a reliable expression of your position on
this issue.
ROTA. ALD FORD
4
Option 3: Instruct Justice to indicate Administration ornesi
tion to the Civil Process Act amendments ouring th
House mark-up session.
Such i' reversal of support almost certainly would result in
increased attacks on the credibility ol the Administra tion's
antitrust program. It would also tend to undermine the into-
grity of the Administration's process of clearing legislation.
Decision
Option 1
Reaffirm Administration support for the
Civil Process Act amendments and related
legislation with a letter to the House and
Senate Judiciary Committees.
Supported by: Treasury, Commerce, Justice,
Counsel's Office, OMB, CEA
Option 2
Reaffirm Administration support for the
Civil Process Act amendments by instructing
Justice to indicate such support during
the House mark-up session.
Supported by: Marsh, Friedersdorf
Option 3
Instruct Justice to indicate Administration
opposition to the Civil Process Act amend-
ments during the House mark-up session.
FORD is GERALD LIBRARY
(CHART REVISED AND NOW AT TAB A. )
GERALD ? FORD
ECONOMIC POLICY BOARD
EXECUTIVE COMMITTEE
May 21, 1976
8:30 a.m.
Roosevelt Room
PRINCIPALS ONLY
1. Task Forces to Reduce Waste in Regulation
MacAvoy
R.FAS
is
GERALD
COUNCIL OF ECONOMIC ADVISERS
WASHINGTON
ALAN GREENSPAN, CHAIRMAN
PAUL W. MACAVOY
BURTON G. MALKIEL
May 18, 1976
MEMORANDUM TO: EXECUTIVE COMMITTEE, ECONOMIC POLICY BOARD
FROM:
Paul W. MacAvoy Prn
SUBJECT:
Presidential Task Forces to Reduce Waste
in Regulation: Progress Report #1
In his speech before the Small Business Administration
Conference of May 13, the President announced the creation
of Task Forces to reduce the costs and delays from regulation
by the Federal Energy Administration (FEA) and the
Occupational Safety and Health Administration (OSHA). This
memorandum reports on the follow-on efforts to put these
and other Task Forces in operation.
1.
Steps Taken to Date on OSHA and FEA Task Forces
The work plans for these two Task Forces have been
prepared and approved by both CEA-OMB staff involved and
by those in the agencies concerned with this effort
(attached Tabs A and B). The plans focus on operations
of the two agencies that (a) would likely benefit from
reduced or simplified regulations (b) are now the subject
of a limited reform effort from within the agencies, and
(c) can be affected by a reform effort within this
Calendar Year. The FEA plan expects some results by late
August, while the OSHA plan calls for dissemination of
simplified regulations on Parts D and L of the mandatory
standards by the autumn, and announcement of proposed
changes in Parts P and O before the end of the Calendar Year.
There is a substantial probability, however, that the work
will not be far enough along to make an announcement of
results this Calendar Year.
REVOLUTION
BICENTENNIAL
i
FORD
AMERICAN
GERALD
1776-1976
@
-2-
The staffing of the Task Forces has begun. Individuals
will be detailed from other agencies to the object agency,
usually to the Office of the Secretary of the object agency
for a period of six months. A number of candidates have
been interviewed both to determine whether they are
knowledgeable in the current problems of the object agency
and whether they are interested in taking part in the
Task Force effort. Requests for detailing individuals
will be made next week. Requests have already been made
for detailing Philip Harter (Administrative Conference),
Douglas Harlan (HEW), and Jonathan Rose (Justice) to work
with me in setting up and chairing task forces.
2.
Next Steps
Additional Task Forces should be put together in other
dependent regulatory commissions or agencies. Work is under-
way to evaluate the prospects for successful Task Force
operations in HEW, HUD, and Commerce. Those in HUD and
Commerce now do not look promising on the three criteria
outlined above. Further "opportunities" are needed.
Attachments
ERALD
Tab A
Task Force on Improving FEA Regulation
I.
INTRODUCTION:
FEA is currently systematically phasing out many of the
price and allocation regulations which have been in force
since the embargo of 1973-74. The Task Force on FEA will
study and make recommendations concerning simplifications
in FEA's post-decontrol price and allocation regulations,
and the procedures and regulations associated with FEA's
Mandatory Oil Imports Program. Also, the Task Force will
make improvements in the development process by which FEA
brings new regulations on-stream or modifies existing
regulations.
The regulations for "decontrolled" products are being
put on standby status for use in the event of another
severe supply interruption. The Task Force will consider
the regulations for all products, but particularly for
those still under control by FEA, to determine how these
regulations can be simplified in the current mode. Also,
the group will consider standby regulations with a view
toward recommending simplifications to these standby programs
should they ever be reimplemented.
II. MISSION:
to recommend simplifications in on-going and standby
FEA allocation and price regulations, and to
recommend similar changes in the regulations and
procedures for FEA's Mandatory Oil Imports Program.
to recommend improvements in FEA procedures for
developing and promulgating regulations.
III. FUNCTIONS:
1. Regulation Simplification
a. Identify existing regulations to be reviewed,
specifying:
paragraph number and act which apply,
the objective of each regulation, that is,
what it is attempting to accomplish.
-2-
b.
Identify the problems (i.e., subparts having
significant impact) or other characteristics
associated with each regulation, such as:
the workload necessary to comply (this
includes the costs for reporting and
record-keeping),
the impact of the regulation on various-size
firms,
benefits accruing to those regulated, or to
other sectors (i.e. consumers, other
businesses, etc.) - relate the benefits
to the underlying objectives of the regulation,
regulations which overlap, contradict, etc.
,
those sections of the regulation where costs
are not warranted with respect to benefits,
regulations where firm compliance is very
difficult, and where the costs of enforcing
the regulations do not warrant their
continuation.
C. Propose simplified methods to accomplish the
basic objectives, considering:
the possibility of proposing that no
regulation be promulgated,
a method of achieving a higher level of
self-enforcement,
merging related programs.
d.
Recommend simplified regulations:
prepare option paper on alternative proposals,
select preferred options.
-3-
2. Procedural Improvements
a. Determine the basic requirements in developing
and promulgating regulations, specifying
legal constraints, the need for public comments,
and outside agency oversight authority.
b. Delineate the current FEA system of regulations
development, specifying:
responsibilities of all participants,
time-sequence of work flow,
tasks performed by all participants.
C. Cite specific historical cases for subsequent
study.
d. Identify operational problems (e.g., bottlenecks)
in the current system, specifying underlying
causes. Specify difficulties such as:
insufficient input from groups both inside and
outside the agency,
problems in the relationship of different
FEA components involved in the process
(specifically, the relationship and
respective responsibilities of the Offices
of Regulatory Programs, Policy and Analysis,
and the General Counsel),
delays due to outside agency oversight and
review practices,
delays due to manpower needs.
e.
Propose improvements in procedures, including:
changes in management control and responsibilities,
changes in review powers of inernal and external
offices
improvements in access to supporting information.
f. Recommend improvements in regulations development
process. Includes preparation of options papers on
alternate proposals, and selection of preferred option
to be implemented by FEA.
-4-
IV. ORGANIZATION:
Task Force
Director
(1)
Regulations
Procedural
(4)
Simplification
Improvements
Allocation
(4)
Regulations
Price
(4)
Regulations
(16 Professionals plus
6 Support Staff)
Mandatory Oil
(3)
Imports Program
Improvements
V.
PERSONNEL REQUIREMENTS:
1. Regulations Simplification
Allocation Regulations - Four senior professionals
(GS-14 or above) familiar with the concepts of allocation of
petroleum or scarce commodities, but not employed by FEA.
Should be familiar with petroleum production, refining and
distribution systems.
Possible Source
1 - Lawyer
Department of Justice
1 - Enforcement Specialist
Internal Revenue Service
1 - Systems Analyst
OMB
1 - Petroleum/Industrial
Department of Interior
Engineer
Price Regulations - Four senior professionals (GS-14
or above) familiar with the petroleum industry and price control
mechanisms, but not employed by FEA.
- -5-
Possible Source
1 - Laywer
Department of Justice
1 - Enforcement Specialist
Internal Revenue Service
1 - Systems Analyst
OMB
1 - Economist
Department of Treasury
Mandatory Oil Imports Program Improvements - Three senior
professionals (GS-14 or above) familiar with the petroleum industry,
with particular emphasis on refinery economics.
Possible Source
1 - Lawyer
Department of Justice
1 - Economist
Department of of Commerce
1 - Refinery Engineer
Department of Interior
2. Procedural Improvements - Four senior professionals
(GS-14 or above) familiar with organizational and management
practices in government, with particular emphasis on the
development of regulations.
Possible Source
1 - Lawyer
FPC, ICC
1 - Operations Analyst
Department of Defense
1 - Management Analyst
Department of Commerce
Department of Interior
1 - Program Analyst
Department of Transportation,
etc.
GERALD FORD LIBRARY
Tab B
Task Forcè on Improving OSHA Regulation
The OSHA Task Force will center its attention on
revising the national consensus safety standards that apply
to general industry. These 50,000 standards have been
the subject of much criticism as being confusing, complex,
unrelated to safety conditions, and difficult to under-
stand. The Task Force will attempt to clarify and
simplify and, where redundant, to eliminate standards.
In addition, where there are gaps in coverage, new
standards will be added.
For some months the Department of Labor has had in
operation an extensive program to revise two major subparts
of the general industry safety standards (Subpart D -
Walking and Working Surfaces, and Subpart L - Fire Protection)
and a standard for anhydrous ammonia, together representing
about one-seventh of the consensus standards. This effort
was undertaken in order to update and simplify those in effect
since OSHA adopted as mandatory the national voluntary con-
sensus in 1971. The Department of Labor is carrying out an
extensive solicitation of written public comments as a first
step in revising these standards. In addition to the request
for comments, a series of public meetings has been announced
for various locations in the United States, to provide direct
input from the public. Following the meetings and a full
consideration of all comments received, OSHA will propose as
soon as possible any necessary revision of these standards.
The Presidential Task Force will accelerate and extend
this initiative to revise consensus standards. It is
estimated that without additional staff resources, the
OSHA effort to revise all of the consensus safety standards
would take two or more years to be completed. The Task
Force effort will add lawyers and technicians to complete
preparation of standards for comment and assist in analyzing
the public responses. The target for the Task Force effort
is to initiate public review of Subpart O (Machine and
Machinery Guarding) and Subpart P (Hand and Portable
Power Tools) by early fall. In addition the Task Force
will address general issues concerning OSHA's standards
such as specification of design versus performance
standards, and the problems of incorporating rapidly
changing external standards by reference.
-2-
Organization of the Task Force
The membership in the Task Force will be made up of
individuals both from within the Department of Labor and
from other agencies. It is necessary to have DOL personnel
in order to obtain the expertise to complete the work
accurately and quickly. It is also necessary to add individuals
from other agencies to enable DOL to carry on this expanded
work. Therefore the Task Force will have as co-chairmen
Joseph Kirk of OSHA, and Philip Harter of The Administrative
Conference of the United States. The operating Director
of the Task Force will be Anson Keller from OSHA. There
will be three additional members from within DOL, two from
the OSHA Safety staff and one from the DOL Solicitor's
office. The remaining members of the Task Force will be com-
posed of six attorneys and six engineers familiar with health
and safety regulation. Mr. Francis Lunnie will handle the
administrative details for the Task Force. In addition,
the Task Force will require four secretaries.
The selected personnel would be detailed from government
agencies for six months to the Committee on Regulation in the
Office of the Secretary of DOL. They would be under the
direction of the co-chairmen of the Task Force and would be
given office space in the Department of Labor.
Work Plan
Work will begin immediately on preparation of the two
additional subparts of the consensus standards. This work
would put into place the process of review that is now
being undertaken for Subparts D and L. The subparts would
be prepared for publication in the Federal Register, request
for comments and information would be made to business and
trade organizations, meetings would be scheduled and
written comments processed when received.
The preparation for publication in the Federal Register
is the most important detailed step. Previous comments
have to be compiled, whether received from individuals or
national standards organizations. The enforcement
experience to date has to be reviewed, including relevant
commission decisions and cases. At this point, staff
-3-
analysis of basic issues is also critical, including issues
as to whether more could be done to simplify the standards
by referring to certified equipment rather than specifying
the exact detail of each item as a piece of that equipment.
The final product of the review is the preparation of a
paragraph-by-paragraph presentation of existing standards
and comments received for the Federal Register.
Meetings on the additional subparts will be scheduled,
and comments will be received for sixty days after publication
in the Federal Register. After the comments have been con-
sidered, OSHA technical experts will prepare the proposed
revised and simplified standards with the members of the
Task Force.
GERALD
CC: Leach
THE WHITE HOUSE
WASHINGTON
w
May 21,
Excellent
MEMORANDUM FOR:
DICK CHENEY
JIM CANNON
BOB HARTMANN
Good Jun
JACK MARSH
BILL SEIDMAN
FROM:
ED SCHMULTS
As the attached editorials from the Christian Science Monitor,
the New York Times and the Wall Street Journal indicate,
I believe the President's Agenda for Government Reform Act
is off to a good start. The local press around the country
is also reporting it favorably. We are looking for ways to
maintain the President's "out front" position on government
reform.
Attachments
BERALD
THE CHRISTIAN S
SCIENCE MONITOR 5/21/76
"First the blade, then the ear,
The Monitor's view
Reforming the regulators
NYTIMES 5/19/76
Caging the Elephant
Selling Regulatory Reform
REVIEW & OUTLOOK
c