A-30946, MARCH 28, 1930, 9 COMP. GEN. 417

A-30946: Mar 28, 1930

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THERE IS NO AUTHORITY FOR THE MAKING OF A SURVEY AND SPECIAL STUDIES OF THE ECONOMIC CONDITIONS. 1930: I HAVE YOUR LETTER OF MARCH 8. HE ESTIMATES THAT IT WILL COST ABOUT $250. 000 AND WILL PRACTICALLY EXTEND OVER THE ENTIRE YEAR FROM APRIL 1. THE DIRECTOR OF THE CENSUS IS IN DOUBT AS TO WHETHER HE WILL BE JUSTIFIED IN EXPENDING SUCH A LARGE AMOUNT ON FIELD WORK EXTENDING FOR SUCH A LONG PERIOD. YOUR OPINION IS THEREFORE RESPECTFULLY REQUESTED ON THE FOLLOWING QUESTIONS: "1ST. WILL THE DIRECTOR OF THE CENSUS BE JUSTIFIED IN EXPENDING A CONSIDERABLE PROPORTION OF THE APPROPRIATION FOR THIS WORK AND WOULD HE BE AUTHORIZED TO MAKE THIS EXPENDITURE. THAT IS NOT COVERED BY THE ACTUAL ENUMERATION?

A-30946, MARCH 28, 1930, 9 COMP. GEN. 417

APPROPRIATIONS - FIFTEENTH DECENNIAL CENSUS - UNEMPLOYMENT SURVEY UNDER THE APPROPRIATION FOR THE FIFTEENTH DECENNIAL CENSUS, AND THE LAW AUTHORIZING THE TAKING OF SUCH CENSUS, THERE IS NO AUTHORITY FOR THE MAKING OF A SURVEY AND SPECIAL STUDIES OF THE ECONOMIC CONDITIONS, ETC., OF UNEMPLOYMENT.

COMPTROLLER GENERAL MCCARL TO THE SECRETARY OF COMMERCE, MARCH 28, 1930:

I HAVE YOUR LETTER OF MARCH 8, 1930, AS FOLLOWS:

SECTION 1 OF THE ACT OF JUNE 18, 1929, 1929 (46 STAT. 21; U.S.C. TITLE 13, SEC. 201), AUTHORIZES THE TAKING OF A CENSUS OF UNEMPLOYMENT. MR. CHARLES E. PERSONS, AN EXPERT ON THE ECONOMICS OF UNEMPLOYMENT, IN THE ATTACHED MEMORANDUM MAKES CERTAIN RECOMMENDATIONS TO THE DIRECTOR OF THE CENSUS FOR THIS WORK. HE ESTIMATES THAT IT WILL COST ABOUT $250,000 AND WILL PRACTICALLY EXTEND OVER THE ENTIRE YEAR FROM APRIL 1, 1930, TO APRIL 1, 1931.

THE DIRECTOR OF THE CENSUS IS IN DOUBT AS TO WHETHER HE WILL BE JUSTIFIED IN EXPENDING SUCH A LARGE AMOUNT ON FIELD WORK EXTENDING FOR SUCH A LONG PERIOD. YOUR OPINION IS THEREFORE RESPECTFULLY REQUESTED ON THE FOLLOWING QUESTIONS:

"1ST. DOES THE LAW AUTHORIZE THE DIRECTOR OF THE CENSUS TO MAKE A SPECIAL STUDY OF CONDITIONS SUCH AS OUTLINED BY MR. PERSONS?

"2D. WILL THE DIRECTOR OF THE CENSUS BE JUSTIFIED IN EXPENDING A CONSIDERABLE PROPORTION OF THE APPROPRIATION FOR THIS WORK AND WOULD HE BE AUTHORIZED TO MAKE THIS EXPENDITURE, COVERING A FIELD INVESTIGATION EXTENDING OVER SUCH A LONG PERIOD OF TIME, THAT IS NOT COVERED BY THE ACTUAL ENUMERATION?

THE RETURN OF THE INCLOSURE IS REQUESTED.

THE OPENING STATEMENT OF THE MEMORANDUM OF MR. PERSONS IS TO THE EFFECT THAT SPECIAL STUDIES OF UNEMPLOYMENT GIVING A DETAILED PRESENTATION OF CONDITIONS IN INDUSTRIES ESPECIALLY SUBJECT TO SEASONAL FLUCTUATION IN EMPLOYMENT SHOULD BE REGARDED AS A CONSTITUENT PART OF THE CENSUS OF UNEMPLOYMENT TO BE TAKEN, AND THAT THE NUMBERING OF PEOPLE FOUND IDLE ON CENSUS DATES, STANDING ALONE, WILL NOT GIVE A COMPLETE AND CORRECT ANSWER AS TO THE NUMBER OF UNEMPLOYED.

BASED UPON THIS THEORY, THERE IS SET FORTH IN THE MEMORANDUM AN OUTLINE OF A SURVEY OF UNEMPLOYMENT INCLUDING STUDIES AS TO CAUSES, EFFECTS, AND REASONS FOR UNEMPLOYMENT, THE SEASONAL FLUCTUATION IN CERTAIN INDUSTRIES, AND MORE OR LESS EXTENSIVE INQUIRY INTO THE QUESTION OF TECHNOLOGICAL CHANGES AS AFFECTING THE WORKERS, SUBSEQUENT READJUSTMENT, ETC. THE COST OF THESE SPECIAL STUDIES IS SET FORTH IN THE CONCLUDING PART OF THE MEMORANDUM IN SUBSTANCE AS FOLLOWS:

BUILDING-TRADES WORKERS IN MASSACHUSETTS, WHICH WOULD BE SELECTED AS A REPRESENTATIVE DISTRICT-------------------------------- $25,000

COAL MINES IN SEVERAL DISTRICTS--------------------------- 50,000

MEN'S CLOTHING INDUSTRY IN CHICAGO, NEW YORK CITY, AND POSSIBLY ROCHESTER --------------------------------------------------- 50,000

LONGSHORE WORKERS IN SEATTLE AND THE PORT OF NEW YORK----- 50,000

TECHNOLOGICAL UNEMPLOYMENT IN A FIELD NOT YET SELECTED---- 75,000

TOTAL----------------------------------------------------- 250,000

THE APPROPRIATION MADE BY THE ACT OF JANUARY 25, 1929, 45 STAT. 1119, PROVIDES FOR THE ,NECESSARY EXPENSES FOR PREPARING FOR TAKING, COMPILING, AND PUBLISHING THE FIFTEENTH CENSUS OF THE UNITED STATES AND FOR CARRYING ON DURING THE DECENNIAL CENSUS PERIOD ALL OTHER WORK AUTHORIZED AND DIRECTED BY LAW.' SECTION OF THE ACT OF JUNE 18, 1929, 46 STAT. 22, PROVIDES:

THAT THE FIFTEENTH AND SUBSEQUENT CENSUSES SHALL BE RESTRICTED TO INQUIRIES RELATING TO POPULATION, TO AGRICULTURE, TO IRRIGATION, TO DRAINAGE, TO DISTRIBUTION, TO UNEMPLOYMENT, AND TO MINES. THE NUMBER, FORM, AND SUBDIVISION OF THE INQUIRIES IN THE SCHEDULES USED TO TAKE THE CENSUS SHALL BE DETERMINED BY THE DIRECTOR OF THE CENSUS, WITH THE APPROVAL OF THE SECRETARY OF COMMERCE.

IN NEITHER OF THE ACTS CITED AND QUOTED IS THERE ANYTHING EITHER IN SPECIFIC TERMS OR BY REASONABLE IMPLICATION INDICATING AN INTENT THAT THE UNEMPLOYMENT CENSUS SHOULD INCLUDE, ALSO, SUCH SPECIAL STUDY OF CONDITIONS, ETC., AS ARE SET FORTH IN MR. PERSONS' MEMORANDUM; AND, NOTWITHSTANDING IT MAY SEEM ADVISABLE AND ADVANTAGEOUS TO EXPERTS IN ECONOMICS OF UNEMPLOYMENT THAT THE CENSUS OF UNEMPLOYMENT SHOULD REFLECT SUCH DATA, IT IS NOT BELIEVED SUCH AN EXTENSIVE SURVEY OF THE ECONOMICS OF UNEMPLOYMENT WAS CONTEMPLATED. THE LAWS AUTHORIZING THE TAKING OF THE FIFTEENTH DECENNIAL CENSUS OF THE UNITED STATES AND THE APPROPRIATIONS HERTOFORE MADE FOR THE PURPOSE, CLEARLY INDICATE THAT THE WORK AUTHORIZED UNDER THE FUNDS MADE AVAILABLE WAS TO BE LIMITED TO THE MAKING AND RECORDING THE RESULTS OF CERTAIN INQUIRIES TO BE PRESCRIBED BY THE DIRECTOR OF THE CENSUS WITH THE APPROVAL OF THE SECRETARY OF COMMERCE, AND SUCH FUNDS CAN NOT BE CONSIDERED AS AVAILABLE FOR THE PAYMENT OF SALARIES OF TRAINED INVESTIGATORS, OR FOR THE MAKING OF SPECIAL STUDIES IN THE FIELD OF ECONOMICS AS PROPOSED BY MR. PERSONS.

ACCORDINGLY, YOUR FIRST QUESTION IS ANSWERED IN THE NEGATIVE.

AS TO YOUR SECOND QUESTION, IT IS PARTLY ANSWERED IN THE PRECEDING PARAGRAPH, THAT THE APPROPRIATION FOR THE FIFTEENTH DECENNIAL CENSUS IS NOT AVAILABLE FOR FIELD INVESTIGATIONS NOT RELATED TO ENUMERATION, OR THE ACTUAL TAKING OF THE CENSUS OF UNEMPLOYMENT. HOWEVER, IF, AS STATED BY MR. PERSONS, IN ORDER TO OBTAIN ACCURATE FIGURES IT IS NECESSARY TO KEEP A RECORD COVERING A 12-MONTH PERIOD SO AS TO TAKE CARE IN CERTAIN INDUSTRIES OF SEASONAL FLUCTUATIONS, TC., THERE WOULD APPEAR TO BE NO OBJECTION TO THE HANDLING OF THE MATTER IN THAT MANNER SO THAT THE DATA OBTAINED AS TO THE NUMBER OF UNEMPLOYED WOULD REFLECT THE TRUE AVERAGE OF UNEMPLOYMENT IN THE YEAR IN WHICH THE CENSUS IS TAKEN RATHER THAN ON A PARTICULAR DATE IN THAT YEAR. THE QUESTION AS TO THE ADVISABILITY OF SUCH PROCEDURE IS PRIMARILY ONE FOR CONSIDERATION AND DETERMINATION BY THE DIRECTOR OF THE CENSUS, WITH THE APPROVAL OF THE SECRETARY OF COMMERCE AS PROVIDED IN SEC. 4 OF THE ACT OF JUNE 18, 1929, SUPRA, WITH THE UNDERSTANDING THAT THE RECORD OF UNEMPLOYMENT KEPT DURING THE YEAR WOULD BE FOR THE PURPOSE OF ENUMERATION, OR THE TAKING OF THE CENSUS AUTHORIZED BY LAW, RATHER THAN A STUDY OR SURVEY ON THE ECONOMICS OF UNEMPLOYMENT.