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certainly do not want to go through that again. I do not interpret it to be required.

Mr. HARRISON. Piling hypothesis upon hypothesis, assuming Congress were to go ahead and fund these other programs and assuming that no other 1202 commission regulations had been promulgated by the agency, don't you think the States then would qualify under the requirements of the law for assistance under title X even in the absence of further 1202 regulations?

Dr. FRIDAY. As a lawyer I don't know that I could agree. I don't know the law well enough to answer that question.

Mr. HARRISON. Well, it was a hypothetical question.

Mr. ANDREWS. Anything further?

Mr. DELLENBACK. No.

Mr. ANDREWS. If not, we thank you again, Dr. Friday.

Our next and second witness is Mr. Warren Hill, Chancellor of Higher Education for the State of Connecticut, who is testifying in two capacities today.

Chancellor Hill is appearing before us as vice-chairman of the Education Commission of the States, and president-elect of the State Higher Education Executive Officers Association.

Chancellor Hill has served as chancellor of Connecticut's system since 1966, and for 3 years prior to that he was president of Trenton State College in Trenton, N.J.

Mr. Hill, we welcome you here and look forward to your statements.

STATEMENT OF WARREN G. HILL, PRESIDENT-ELECT, STATE HIGHER EDUCATION EXECUTIVE OFFICERS ASSOCIATION

Mr. HILL. Thank you very much, Mr. Chairman and Congressman Dellenback.

I would like to point out I have been joined at the table by Dick Millard of ECS staff. He is director of higher education services for ECS and in that capacity works very closely with both of these organizations.

I am grateful for the opportunity to appear before your committee and speak on behalf of these associations.

I am sure that you are aware that the States constitute by far the largest single funding source for higher and postsecondary education in the Nation. Total State appropriations, not including postsecondary Vocational-technical education apart from community colleges, exceeded $8.5 billion in 1972-73. This funding not only included direct support of public postsecondary educational institutions but considerable amounts of aid to private institutions and grant aids to students at both public and private institutions. The primary responsibility for funding and for planning for postsecondary education in this country rather clearly rests with the States.

I might say they are putting significant effort into it.

Although the amounts and types of statewide planning have and do vary from State to State, the States on the whole have not been negligent in recognizing and effectuating their planning responsibilities. While there was a relative handful of States with higher education planning, coordinating and/or governing agencies at the end of

the 1950's, during the 1960's and into the 1970's, 47 of the States strengthened or developed State higher education agencies with responsibilities for at least some aspects of the planning process. They did so in the 1960's to meet the needs of rapidly expanding numbers of students and continuing into the 1970's to insure orderly development, adequate diversification, and effective use of limited resources in postsecondary education. Of these agencies 27 are coordinating boards and 20 are unified governing boards. Two of the additional three States have voluntary State associations.

I might note which these are because they are so few in number, that is Vermont which has none, and Nebraska and Delaware, of the three that are omitted. While in most instances these State agencies are primarily responsible for public postsecondary education, in a number of States they have at least some responsibility for taking private higher education into account in the planning process and in more than a few cases their responsibility extends to providing State funding to private institutions. The trend over the last number of years has been in the direction of strengthening such agencies and increasing the scope of their responsibilities. On the State level such agencies tend to be under constant review and some 32 States during this last year have strengthened or modified the agencies to meet changing conditions. There seems to be little question that the States on the whole are committed to effective planning and coordination as a prerequisite for adequately meeting the postsecondary educational needs of their citizens.

The Education Amendments of 1972 clearly recognized State responsibility for postsecondary educational planning. They further underlined the recognized need for broadening the scope of such planning to cover the range of postsecondary education-public, private and proprietary-and for the involvement of the various types of postsecondary education in the planning process.

One of the most significant features of the Education Amendments of 1972 was the provision for comprehensive postsecondary planning agencies as provided in sections 1202 and 1203 of the law. This was not a wholly new Federal initiative since assistance for facilities planning had been provided through the facilities commissions since 1963, but it did significantly broaden the concept of planning and provided for an agency that could address a whole range of planning issues in postsecondary education and not just one or a few categorical programs.

Guidelines for the development of the planning commissions have been held up because the administration has indicated that they do not intend to fund the title X programs in the Education Amendments of 1972 and, therefore, the administration sees no need for funding any planning for these programs.

This was reflected in a letter from Acting Commissioner Ottina, a "dear colleague" letter that came out 12 months ago

The purpose stated for the 1202 commissions in the law, particularly in section 1203, is much broader than planning for specific categorical programs and it is the position of the State higher education executive officers and the education commission of the States that the need for comprehensive planning is at least as great if the Federal Government

puts most of its support on students as if it funded a whole range of specific programs with detailed planning requirements

The goal of the Federal student aid programs is to provide equality of educational opportunity. As a corollary, it is also assumed that increased reliance on the market, that is, letting the student make the choice about which program he will attend, will reduce the necessity for Federal planning. If that is the case, it will, at the same time, increase the need for State planning.

Any effective system of equalizing educational opportunity must assure the availability of an appropriate mix of institutions and programs distributed geographically so that students will not have great difficulty in enrolling in them. The cost of educational programs is also an important factor in assuring educational opportunity because the Federal Government has made no commitment to support the full cost of education for students who need financial assistance and, in fact, the implicit Federal assumption is that a full system of low tuition programs and institutions will be provided by the States.

The only way the goal of equal opportunity can be realized in the next decade is through a diverse system of institutions, partly private and proprietary, but in most States primarily publicly supported.

The need for State planning to assure a diverse set of institutions able to serve students at reasonable cost is at least as great under the new Federal strategy for support of postsecondary education through students as it was under the concept of supporting special programs.

State planning is primarily a State responsibility and the Education Amendments of 1972 recognize that, but there is an important role for the Federal Government. Even our largest States are supplying only a small part of the total educational program of the Nation and each State is affected in many ways by the actions of its neighbors. If equal opportunity is an important goal for Connecticut, it is also an important goal for Maine, Washington, and Texas. If the Federal Government provides no assistance in helping the States confront their responsibilities for providing equal educational opportunity individual States will be less likely to face up to what is needed nationally and the substantial inequalities of opportunity that now exist between the States will be perpetuated into the future.

It should be pointed out that the law, in section 1202, does not mandate identical structures in the 50 States nor does it specify in section 1203 how specific planning procedures shall be carried out. It permits States to designate existing agencies or establish new ones to serve the planning purposes. As such it reinforces developments within the States. The desirability of such reinforcement was endorsed by the National Governor's Conference through its acceptance of the report of its Human Resources Committee in March of 1972.

Turning specifically to the issue paper and guidelines, as others have pointed out, never in the history of Federal higher and postsecondary education has the opportunity for participation, comment and review on the part of the postsecondary educational community, including members of the State political communities concerned with postsecondary education, been as widespread as in relation to the 1202 issue paper and guidelines.

The Office of Education is to be congratulated on its openness and willingness to seek and take advice in their development. Even before the issue paper was developed, representatives of a wide variety of institutions and agencies involved or that would be affected by the legislation-were called together to identify and discuss the issues. These included college presidents, State higher education executive officers, chief State school officers, State community college directors, State vocational education directors, State vocational advisory council directors, proprietary institution representatives, and State legislators. Once the Office of Education task force had completed its draft of the issue paper it was distributed to some individuals across the country for review and comment.

Over 500 responses were received and it is our understanding that the paper was extensively revised in the light of the reactions received. One of the highly salutory net effects of such widespread involvement was that it served as a catalyst to extensive discussions on State levels among the various components of the postsecondary educational community. Groups that had not gotten together before did so. For the first time in history, the State directors of community colleges, vocational education, and adult and continuing education met together in New Orleans in January to discuss mutual complementation and cooperation.

In anticipation of the guidelines, a series of States have taken action and most others are currently waiting for the guidelines to appear before doing so. Four States have passed legislation designating or establishing commissions. These are attached to the material that has been provided for you.

In nine States Governors have acted to designate agencies as the commissions. In seven other States legislation is currently pending. It is a matter of major concern in the States that actions taken or proposed not be contravened by subsequent Federal guideline changes. We are submitting as an appendix to the testimony a survey of the status of action in each of the 50 States as of March 30, 1973, prepared by the Education Commission of the States.

Whether there is funding or not for the 1202 commissions and their planning functions (sec. 1203), it is critically important that the discussions in relation to more effective and comprehensive planning by all the parties concerned continue. One of the unfortunate aspects of the decision to withhold the issue paper and guidelines is that it has left everyone-States, institutions, and agencies-in midair without further guidance and without an opportunity to see, comment further, or act upon the basis of the revisions introduced in the light of the earlier responses.

We sincerely hope that the issue paper and guidelines will be released, if for no other reason than to clear up the confusion and to continue to act as a catalyst for discussion and action.

One final note should be added. It seems to us that the issue is not and should not be Federal mandating of particular State structures. We would not claim that sections 1202 and 1203 are necessarily the most adequate formulation possible. Rather, the issue is the importance of Federal recognition and the reinforcement of the criti

cal role of effective comprehensive planning for post-secondary education on the part of the States. Planning of that order is seen as the precondition of the vitality, freedom and continuation of the pluralistic and diversified (yet complementary) postsecondary educational system that holds such promise for meeting both the needs of our diverse citizenry and the manpower needs of society. Thank you, Mr. Chairman.

[Material referred to above is as follows:]

SURVEY OF PRESENT STATUS OF STATE PLANNING FOR THE 1202 STATE COMMISSIONS (SEC. 1202, EDUCATION AMENDMENTS OF 1972), MAR. 30, 1973

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Alabama: When the guidelines are released, it is planned that a bill will be X
introduced to designate the Commission on Higher Education, augmented
by about 5 persons, as the 1202 commission.

Alaska: House bill 180, passed by the house and now in the senate, creates
the 1202 commission. The bill was amended to include legislators on the
11-member commission and to require legislative confirmation of the
ex officio members. Senate might eliminate the legislative confirmation
clause but could retain the specification of legislators on the commission.
The State scholarship program administration will be assumed by the

commission.

Arizona: An ad hoc committee was set up by the Governor and met once. X
After the first meeting it was decided to wait for the final guidelines.
After receipt of the Ottina letter, the chairman disbanded the committee
and the Commission on Higher Education (board of regents) has withheld
further action.

Arkansas: A proposed bill has been drafted which designates the depart- X
ment of higher education as the 1202 commission; however, it is not
conclusive that the bill will remain as drafted or be revised to specify a
new agency. The bill probably will not be submitted unless the guidelines
are released.

California: Assembly bill 7770 has introduced a bill which embodies the rec-
ommendations of the joint committee on the master plan. The bill speci-
fies that a postsecondary education council be created and that the coun-
cil will serve as the 1202 commission. This language will remain in the
bill.
Colorado: The State is waiting for the final guidelines and regulatons. It X
also recognizes that the Commission on Higher Education will require
some reorganization of its membership such as the addition of a woman.
Connecticut: The Commission believes that no legislation is required and
that the Governor can designate the 1202 commission. A measure has
been introduced naming the commission as the 1202 commission, includ-
ing responsibility for developing strategy for encouraging vocational-
technical education in elementary-secondary schools. The measure is in
committee with no opposition and is awaiting an attorney general opinion
as to whether legislation is needed.
Delaware: Prior to the Ottina letter, both the Council of Presidents and the X
facilities commission had made recommendations to the Governor. The
council recommended that it be the base for the 1202 commission aug-
mented by additional persons to meet the requirements. The facilities
commission has indicated that it would be willing to serve as the 1202,
also augmented.

Florida: At the date of receipt of Ottina letter, the State commissioner of X
education had determined that the board of education (comprised of the
cabinet of the State government) should be the 1202 commission with a
staff to be appointed to implement the commission. The question of
staffing has not been further considered.

Georgia: No action has been taken regarding the appointment of the 1202 X
commission although prior to the Ottina letter, discussions had been held
and the Governor was nearing a decision.

Hawaii: The president of the university system had, in a memorandum, pre- X
sented his recommendations concerning the 1202 commission and the
Governor had indicated that he would defer to the president's proposal
and advice. No further action has developed.

Idaho: The Governor had agreed to designate the State board of education X
as the 1202 commission, augmented by no more persons than necessary.
A plan was being developed but such development has now been halted.
The current feeling on the part of the Governor is on the negative side
unless it means a sustantial loss of Federal funds.

Illinois: The board of higher education has requested the Governor to desig- X
nate it the 1202 commission. The Governor has not as yet acted, but is
expected to shortly.

X

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