PROGRAm AnD mAnAGEmEnT of the GEORGIA DEPARTmEnT OF AGRICULTURE REPORT OF A STUDY BY A TEAM OF CONSULTANTS TO THE GEORGIA DEPARTMENT OF AGRICULTURE AND THE GOVERNOR'S COMMISSION FOR EFFICIENCY AND IMPROVEMENT IN GOVERNMENT S. R. Newell W. L. Popham H. G. Herrell PROGRAM AND MANAGEMENT of the GEORGIA DEPARTMENT OF AGRICULTURE Report of a Study by A Team of Consultants to the Georgia Department of Agriculture and the Governor's Commission for Efficiency and Improvement in Government January 5, 1966 Georgia Department of Agriculture and Governor's Commission for Efficiency and Improvement in Government January 5, 1966 Gentlemen~ Submitted herewith is the report of the study by the team of consultants employed to examine the programs and operations of the Georgia Department of Agriculture. In general the team worked together on all of the programs. However, to cover all of the activities in a limited time, each consultant took major responsibility for a segment in which he was best qualified. Dr. W. L. Popham, formerly Deputy Administrator of the Agricultural Research Service in charge of animal and plant disease regulatory activities for the U. S. D. A., studied the programs concerned with animal and plant disease control and eradication, including meat inspection and laboratories. Mr. Henry G. Herrell, Deputy Administrator for Management, Marketing, and Consumer Services, U. S. D. A., analyzed the administrative management operations. Mr. S. R. Newell, formerly Deputy Administrator of the Statlatlcal Reporting Service and Chairman of the Crop Reporting Board, U. S. D. A., analyzed the marketIng and other service and regulatory activities of the Department. He, as leader of the team, coordinated the segments and prepared the final report. The team is grateful to the Georgia Department of Agriculture for providing office, secretarial, and other services. in conducting the study. The cheerfu I and whole-hearted cooperation from the entire Department staff, from messenger to administrator, in Atlanta and in the field, was a very great help throughout the study. The whole team wonts to especially thank Miss Wanda McPherson for her pleasant, eHicient, and often ingenious interpretation of bad handwriting. The consultants are indebted to the Governor's Commission for Efficiency and Improvement in Government and its Executive Director, Dr. Morris W. H. Collins, Jr., for their cooperation and assistance. The chief consultant, in particular, wonts to express personal thanks to the Stoff Secretary, Mr. C. Rodman Porter. You asked that we be critical of the program and operations, and we hove been. It is our hope, however, that the criticism will help in furthering the progress that has been made in the past decade. Submitted for the consultants, Respectfully, S. R. Newell Chief Consultant TABLE OF CONTENTS PART I Page INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 SUMMARY OF PROGRAMS. 0 0 5 PRESENT ORGANIZATION. 0 0 0 0 0 0 0 7 Program and Organization Problems 0 0 0 0 0 0 0 9 Internal Services Problems . . . . . . . . . . . . . . . . . . . . . . . 17 PROPOSED ORGANIZATION . . . . . . . . . . . . . . . . . . . . . . . 31 PART II PROGRAMS OF THE DEPARTMENT OF AGRICULTURE . . . . . . . . . . . . 37 PART I INTRODUCTION Agriculture in Georgia is a multi-billion dollar enterprise. According to the last U. S. census tak in the Fall of 1959 a little over one-half of the total land area in the State was devoted to 106aer;t7erl s farms. billion Total value of dollars. If this land and buildings on the farms was just about is accepted as a conservative estimate for 1965 and one and a modest three allow- qu is made for the machinery and equipment required on the present day farm, the value of the an~eary producing plant, the 106,000 farms, would easily exceed two billion dollars. The investment pnmworker is probably the h1'ghest fo any maJor m' dustry. per The annual cash farm income in 1962 was $820,361,000 and the preliminary estimate for 1963 is $883,025,000. The dramatic story behind these figures is shown in the two charts following (Exhibit I). The first United States census of agriculture was taken in 1924. That year represents the agricultural income pattern of the 20's, prior to the depression and adjustment programs of the SO's. The 1924 chart shows the Georgia one crop economy that was of such great concern to agricultural leaders at that time. Cotton accounted for nearly two-thirds of the cash income. Fruit and nuts, (mostly peaches) came next contributing 6.6%, then peanuts with 5.1 %, and dairy 4.1%. Contrasted with the pattern in 1924, in 1962 cotton dropped to only 12.7Y, of the total cash income. Broilers that had not been heard of in 1924 took over in 1962 as the top commercial crop, accounting for 20.2% of the cash farm income. Georgia, which was a deficit egg producing state, now derives 11% of its income from this crop and ships eggs to many states. The livestock industry has grown rapidly. Dairying accounts for 6.4% of the 1962 cash income as compared with the 1924 figure of 4.1%. Cattle and hogs have come up just about three fold since 1924. One other change of importance is the increase in cash corn in the State. Corn contribution to cash income increased from 1.1% in 1924 to 3.1% in 1962. This is important in connection with the growth in the livestock and poultry enterprises in the State. The distribution of the 1963 cash income would show approximately the same comparisons as 1962 but since the 1963 figures are preliminary and subject to some revisions the '62 estimates were used. This brief summary highlights the great strides in a comparatively few years from the one crop economy of the 20's to a diversified agriculture and the greater stability that goes with it. It also points up quite well the reason for a comprehensive state program that is well coordinated with other states and federal agencies concerned with agriculture. Evolution of Government Agencies in Agriculture From the earliest days of the nation, individuals, communities and later the states sought ways to improve agriculture. At first the answer seemed to be improving farm production. This involved experimentation or research into breeds of livestock, varieties and kinds of plants, and fertilizer materials and practices. Leaders soon became aware that progress was restricted by the lack of people trained in the sciences to push the horizons beyond the simple trial and error methods. These methods produced both good and bad results but no scientifically sound answers to the vital question of why. Education thus loomed as a factor necessary for the solution to the Problem. Later, as the population expanded, concern arose over the facilities for marketing, the practices in the market, and the distribution of farm food products. This introduced a third element, that of the marketing services and regulatory activities. .Today the public services in the states involved in various aspects of agriculture and food may be mcluded under these three headings: education, research, and service and regulatory work. Res~nsibility for education in agricultural science and other disciplines and the educational and advisory work represented by the Agricultural Extension Service rests with the State University. 1 EXHIBIT I 3 GEORGIA CASH FARM INCOME - 1924 Total $209, 145, 000 (No Government payments) Livestock and Products $Z7,579.000 Percent of Total 13. 2"/o ____0~ $181, 566,000 Percent of Total 86. 8"/o GEORGIA CASH FARM INCOME - 1962 Total $831, 064, 000 (Including Government Payments) Livestock and Products ~40, 761,000 Crops $356, 603, 000 Percent of Total 53. Oo/o Percent of Total 42. 9"/o Government Payments $33,700,000 Percent of Total 4. l "lo 2 h the field of agriculture is the responsibilility of the Agricultural Experiment Station Jte8e8fC 1~ich is generally a part of the Land Grant College or State University. Marketing Sys~m wd regulatory activities related to agriculture and food are in general the responsibility MJ'VlCe an . of the State Department of Agnculture. Th' is not to imply that these areas are or should be mutually exclusive. Indeed, each one :;re: is to 80~ISoene xtent amon r g elated these to and dependent upon the other. Where this is recognized and three organizations is developed and maintained, the programs effective of each more effective; and efficiencies and economies of operation will result for each agency and the public. The Georgia State Department of Agriculture, in fact, most state departments of agriculture, :;o~1oegdnoiuzteofththee~tkhirnedes of problems dimensional apnrodbcleomnsiwdeirthatiosunfs~ijcuisetntdicslcaursisteyd.anGdeorregsioalvweastotheestfaibrlsitshs,tabtye formal legislative action, a State Department of Agnculture. The Organic Act of 1874 established the Department of Agriculture and among other things set forth the duties of the Commissioner. Following is a brief summary of the duties assigned to the Commissioner under the Act. 1. Prepare and distribute a handbook describing the geological formation and the capacities and characteristics of the soils of the various counties. 2. Provide for the proper and careful distribution, and exchange with other states and nations, of any seeds introduced by the U. S. Government or which he may deem of value. 3. Study and publicize his findings regarding the habits and propagation of insects injurious to crops, plants, and fruits of this State. 4. Examine into any question of interest to the horticulturists and fruit growers of this State. 5. Study and report upon remedies to the diseases of grain, fruits, and other crops of this State. He shall employ a chemist and a geologist to assist him in research. 6. Analyze and test fertilizers and prohibit the sale of any determined to have no practical value. 7. Report upon any matter of interest in connection with dairying. 8. Investigate and report upon the culture of wool and the utility and profits of sheep raising. 9. Investigate the potentials of irrigation of this State. 10. Study and report on fencing. 11. Collect and annually report statistics relating to agriculture in all of its branches in this State. 12. Report upon any matter or subject he may deem of interest to the agriculture of this State. 13. Revoke, suspend, or cancel the license, certificate, or registration, or impose a reasonable penalty not in excess of $1,000 in lieu of such revocation, suspension, or cancellation, after due notice, hearing, and a determination, as provided by law, that there are sufficient grounds to take such action because of violations by the holder of such certificate, license, or registration. baaedThis is a ver~ broad charter. Some of the duties apparently were taken directly from or were on the duties of the Federal Secretary of Agriculture set forth in the Organic Act of the U. S. Department of Agriculture of 1862. For example, the requirement for the distribution of ~and collection of agricultural statistics in the Georgia law are probably based on similar pro- ...lons in the U. s. D. A. Act. 3 In the administration of service and regulatory work, the Georgia department has developed close and effective working relations with other state agencies, with surrounding states and with the U. S. Department of Agriculture. This basic cooperative policy of the Georgia Department of Agriculture has paid off in more economical and more effective administration. Of course, effective cooperation means equal participation by each party concerned. Credit for the accomplishments under this policy must also be given to the other agencies involved, including other departments of the State government, the State University, Experiment Stations, Agricultural Associations and the United States Department of Agriculture. It would be difficult to cite a State Department of Agriculture that has done a better job of developing really effective and harmonious working relations with public and private agencies concerned with agriculture and food. The activities of the State Department of Agriculture are many and varied. In one way or another every person in the State is affected and, whether he realizes it or not, is or should be interested and concerned with how effectively the basic laws influencing food and agriculture are administered. It has become customary for many people to regard the activities of a department of agriculture as a service just for farmers, and it is true that many of the activities do emphasize the service to farmers. But the program is actually more inclusive, because there are many activities such as meat inspection, the food inspection program, and enforcement of the egg law that are in the first instance directed toward the welfare of all consumers. Many of the other activities such as those to provide better seed, improve productivity of livestock, grading of agricultural products and the program to provide better and more efficient markets have an important influence in providing better and more economical food at the retail store. 4 SUMMARY OF PROGRAMS All of the programs now being conducted by the Department of Agriculture are discussed in some detail in the last chapter of this report. All are considered as appropriate activities for administration by a state department of agriculture. There are no recommendations for additions or deletions. In carrying out its responsibilities there are a number of programs that require laboratory or other facilities which the Department does not have. In the interest of economy and to avoid duplication, cooperative or contractual relations have been arranged with other agencies in the State or the United States having facilities to furnish the needed services. The following six programs are instances where joint effort with other agencies is saving money and providing better services for the people of Georgia. Milk Program In the administration of the milk program, it is required that farms producing milk must be inspected for sanitation in production and handling milk. Under the law, the Department of Agriculture may delegate farm inspection to local health departments where it is determined that their standards are at least equal to the State standards. The Department has developed a plan under which about 957c of the inspection of individual farms is handled by local health departments. This means that the farm inspections by the Department of Agriculture are confined to a small number of farms in areas where there is no qualified public health agency to take on the responsibility. This eliminates duplicate inspection at the farm and the added cost that would otherwise be involved. In carrying out other responsibilities in connection with the administration of the milk program, Department of Agriculture inspectors do make spot checks to be sure that local agencies are fulfilling their responsibilities. Food Inspection Program In administering the food law, the Department does not make health inspections in restaurants, hotels or other establishments where food is prepared for consumption on the premises. By agreement, this area in food inspection is left to the Department of Health. Administration of Seed Law The Department is required to determine the variety of seed as a part of the administration of the seed act. It is often not possible to determine variety by examination of the seed itself and when this occurs, it is necessary to grow it in outdoor plots. The Department of Agriculture does not have facilities for this kind of testing and to provide such facilities would be quite expensive. The Agriculture Experiment Station has the facilities and the personnel to oversee the variety tests. Under a cooperative arrangement between the Department of Agriculture and the Experiment Station, the Station does the variety testing and in return the Department of Agriculture makes many germination tests for the Station. Animal Disease Program Similarly, in administration of some of the laws relating to the livestock and poultry disease P~ams, laboratory facilities beyond those available to the Department of Agriculture are req~~~ Rather than incurring the expense of developing additional or expanding its present fa- ~ th~ neces~ary services are obtained more economically under contracts with the Livestock Diagn es !>Iagnosbc Laboratory operated by the Coastal Plains Experiment Station and the Poultry osbc Laboratory operated by the Georgia Poultry Improvement Association. 5 Agricultural Statistics The Organic Act, establishing the Department of Agriculture, directs the Commissioner to collect agricultural statistics for the State. To fulfill this responsibility a cooperative agreement was signed between the Department, the State University and the United States Department of Agriculture, under which the State receives a far more comprehensive program of detailed statistical information than it could possibly obtain with the relatively moderate contribution of about $12,000 a year to this cooperative program. A particularly valuable part of this cooperative endeavor is in connection with the dairy statistics that are necessary in carrying out the program of the Georgia Milk Commission. In this instance, duplicate questionnaires have been eliminated by designing an inquiry or schedule that meets the needs of both the Milk Commission and the U. S. Department of Agriculture. The U. S. Department takes responsibility for tabulation of the questionnaires and this information is combined with additional information provided by the Milk Commission into a consolidated and detailed report for the dairy industry in the State. Aside from the fact that these statistics are necessary in the administration of the Milk Commission program, the dairy reports are widely used by the dairy industry and many others. Market News The Market News Program is another instance where the State Department of Agriculture has under a cooperative agreement with the U. S. Department of Agriculture expanded the usefulness of this service far beyond that which could be supplied by the available State facilities alone. Cooperative programs are conducted out of the Thomasville Livestock office and the Atlanta market. RECOMMENDATIONS Recommendation No. 1 The consultants can only commend the Department of Agriculture for the development of the cooperative program and recommend the continuation of the policies that are being followed. 6 PRESENT ORGANIZATION The following chart, Exhibit II, shows the present organization of the Georgia State De- :~mtmseonft of the Agriculture. Department The and following discussion deals first with the organization some problems related to the organization. of the pro- Organization of Program Functions The program functions of the Department are divided into three main groups. Each group is under the direction of an Administrative Assistant to the Commissioner. Group 1: The Administrative Assistant in charge of this group is responsible for five programs: Licensing and control of public warehouses Administration of the weights and measures act Commodities promotion program -Administration of public markets Cooperation with U. S. Department of Agriculture on market news and products grading program. Group 2: The Administrative Assistant in charge of this group is responsible for administration of: The Georgia Egg Law Fertilizer inspection program Pesticide regulation program Feed inspection program Entomology-plant disease control eradication Seed inspection Food inspection program Chemical services program Institutional farm management Foundation seed program Agricultural statistics - cooperation with U. s. D. A. Group 3: The Administrative Assistant of this group is responsible for: Meat inspection program Veterinary services program Animal disease eradication Livestock market and certification Contracts with the Poultry Diagnostic Laboratory and the Livestock Diseases Diagnostic Laboratory Cooperation with U. S. D. A. One large program, the Georgia Milk Commission, is actually attached to the Commissioner's office. The dotted line on the chart represents the contact with the Commissioner's office for consultation and advice. For administrative services, however, the Chairman of the Milk Commission operates in the Department much the same way as a program division head. The difference is that although the Commissioner appoints the Chairman and the operating funds are a part of the Departmental budget, policy direction of the program comes from the Board of eight members. The Milk Commission administers a very large and complicated program. 7 EXHIBIT II GEORGIA DEPARTMENT OF AGRICULTURE ORGANIZATION CHART COMMISSIONER OF AGRICULTURE COMMISSIONER'S OFFICE SECRETARY PERSONNEL OFFICE CIVIL DEFENSE AIDE CONSULTANT LEGAL COUNSEL SPECIAL INVESTIGATOR ADMINISTRATIVE ASST. TO COMMISSIONER WAREHOUSE 8< WEIGHTS DIVISION MARKETS DIVISION SPECIAL OFFICES COMPTROLLER INFORMATION 8< EDUCATION SPECIAL SERVICES MARKETING SPECIALIST COOPERATIVE SERVICES DAIRY 8< EGG DIVISION LABORATORIES DIVISION INSPECTION DIVISION \ENTOMOLOGY DIVISION SEED DIVISION STATE SEED ANALYST FOOD DIVISION AGRICULTURAL TRANSPORTATION MEAT INSPECTION DIVISION STATE BOARDS I I I _____ I .I I I _ ADMINISTRATIVE ASST. TO COMMISSIONER GEORGIA MILK COMMISSION VETERINARY DIVISION ANIMAL DISEASE ERADICATION DIVISION STATE BOARD FOR CHILDREN AND YOUTH ADVISORY BOARD, STATE SOIL CONSERVATION COMMITTEE SEED ADVISORY COMMITTEE GEORGIA SEED DEVELOPMENT COMMISSION LIVESTOCK AND POULTRY DISEASE CONlROL BOARD GEORGIA DEVELOPMENT AUTHORITY GEORGIA fARMER'S MARKET AUTHORITY ADVISORY COMMITTEE ON INSTITUTIONAL FARMS STONE MOUNTAIN MEMORIAL ASSOCIATION TOBACCO ADVISORY BOARD WATER QUALITY COUNCIL GEORGIA SEED DEVELOPMENT COMMISSION ADVISORY BOAQD COMMISSIONER OF IMMIGRATION STATE VETERINARIAN STATE ENTOMOLOGIST GEORGIA AGRICULTURAL COMMODITIES PROMOTION COMMISSIONS WAREHOUSE SECTION WEIGHTS 8< MEASURES SECTION MARKET NEWS SERVICE COOPERATING WITH U.S.D.A. DAIRY INSPECTION SECTION EGG INSPECTION SECTION FERTILIZER SECTION PESTICIDES SECTION FEED SECTION FOOD PROCESSING PLANTS SECTION BAKERIES 8< BOTTLING SECTION WHOLESALE 8< RETAIL GROCERIES SECTION INSTITUTIONAL FARM MANAGEMENT FOUNDATION SEEDS, INC. STATISTICIAN POULTRY DIAGNOSTIC LABORATORIES BY CONTRACT: GEORGIA POULTRY IMPROVEMENT ASSOCIATION LIVESTOCK DISEASES DIAGNOSTIC LABORATORY BY CONTRACT: COASTAL PLAINS EXPERIMENT STATION 8 Organization of Administrative Servicing Functions The administrative functions of the Department actually center in the Commissioner's office. The office includes the usual secretarial services, legal counsel (which at present is not filled) and pecial assistants to the Commissioner. In addition, the office of the Comptroller, which includes 8 II the central accounting services including payrolling, preparation of the accounting materials :equired in the .preparation and cont:ol of the bu.dget, and mai! room ~ervices: reports directly to the Commisswner. Three other umts, Informatwn and Educatwn, Special Services, and Cooperative Services, all of which devote a considerable part of their time to activities and programs that would frequently be classed as informational services, report to the Commissioner. An Administrative Assistant to the Commissioner is in charge of Personnel, Training and Civil Defense activities. This Administrative Assistant has, on occasion, held some staff meetings. The Administrative Assistant to the Commissioner in charge of the marketing programs, in addition to his line duties, also performs the staff function of analyzing and controlling travel expense for the Department as a whole. The net result is that the Commissioner carries the major part of the responsibility for decision-making in most of the administrative services. Exhibit II is, in a number of respects, inaccurate and misleading with regard to the way in which the Department actually operates. None of the "Administrative Assistants to the Commissioner" is, in fact, an administrative assistant as that title is usually interpreted. Each has specific line responsibilities and is responsible to the Commissioner for direction of a group of activities. One division, the Inspection Division, does not function in the way it is charted. Neither does the chart reflect, nor was it intended to show, the field organization which constitutes a large part of the activities of the Department. PROGRAM AND ORGANIZATION PROBLEMS This section will deal with some problems that appear to the consults to need attention with regard to the operation of all of the programs, some individual programs and finally the administrative services functions of the Department. Program Development and Planning Program development and planning has been done over a period of time as is evidenced by the progress that has been made in the whole Department. In most operating agencies, program planning is closely tied to and often confined to the budgetary process. This is a practical approach, but it tends to become too much involved in the practicalities and expediencies that often surround a current situation This discussion, however, deals with a broader concept based on longer time projections. In discussing programs with individual project leaders we have gained the distinct impression that individuals, for the most part, are concerned with the day-to-day demand of the job to which they are assigned. This is not to imply that they did not understand the program objectives and were proceeding without a plan. More often than not, the plan seemed to be limited to the shortrange of meeting problems that were already on the doorstep, so to speak. This is not unusual in any organization that has a fast-moving, active operation and where personnel is limited to the extent that there is hardly time to keep up with current demands. Short run planning is, of course, necessary, but it is much more effective if there is a reasonably clear idea of the ultimate goal to be reached. Long-range planning is not easy. It is time consuming and requires lots of understanding and imagination and a very considerable amount of plain hard work. It pays off, however, in the long run because once a plan is made and an objective established, immediate decisions and short run plans can be made in a way that will contribute to the attainment of the ultimate goal. 9 The program planning and development that has been done has apparently been confined largely to the high administrative level in the Department. This is important, of course, but the top level administrators should do a great deal more in the way of program analysis than has apparently been done. For best results for the organization as a whole the stimulation of the kind of thinking and enthusiasm that is necessary for long-time planning and program analysis at all levels of the organization would pay a dividend in many ways. Some division directors and section chiefs did have some ideas for future developments and some instances of careful analysis of programs were observed. Possibly some others had ideas but the consultant's approach failed to encourage them to "open up". Recommendation No. 1 It is recommended that ways be developed to get participation from all levels of the Department in the program planning process. There are several ways this might be accomplished. One is to have each program director submit annually program proposals for the long as well as the short term. These plans should follow through to estimates of cost. In some situations involving more than one Division or program an effective way of creating interest and stimulating participation at all levels is to set up a small task force to study related projects or possibly a single major problem and submit a report of findings to the Commissioner with recommendations for action. Program Direction Each of the programs of the Department is assigned to a division. There are twelve divisions shown in the present organizational chart, which will be discussed in two groups. The first group consists of the six divisions in which no futher breakdown is made and the second group of six in which the functions are divided among two or more sections. In the first group of six, three divisions have administrative assistants attached to the Director's office. In two of these three, the administrative assistant actually serves in two capacities. The assistant to the Director of the Markets Division also serves as assistant to the Director of the Commodities Promotion Division who in turn is also an administrative assistant to the Commissioner in charge of a group of divisions. The administrative assistant to the Laboratories Division serves also as the Chief of the Insecticides section, which is shown as a section under an entirely different division. The administrative assistant attached to the Entomology Division is the only one of this group that does not serve in a dual capacity. At the present time, however, he is acting in charge of the division because that position is vacant and has been for nearly a year. In two of the remaining three divisions of the first group, the Division Director directs the program while one, the Meat Inspection Division, has two men assigned as co-directors of the program. In the second group of six divisions, one, the Inspection Division, does not function as a division. The Director assigned to that Division acts as the head of the Feed Section and exercises no administrative authority over the other two sections. One division, the Dairy and Egg Division, has an administrative assistant to the Director but the Director and the administrative assistant each acts as chief of the Egg Section and the Dairy Section respectively. The Animal Disease Eradication Division is headed by a Director and the one section, Livestock Auction Markets and Certification, is headed by a section chief. In each of the remaining three divisions, the Director doubles as chief of one of the sections. Program direction is thus carried on almost entirely by a staff that is "doubling in brass". Situations do arise where it is necessary or desirable to assign individuals to more than one program. This may be done where the projects are small and reasonably closely related and where 10 either one would provide full-time employment for a man. It would be better in such case to show ~he man in charge of a combined unit. In a great majority of cases, however, the result of doubl- 'ng in two jobs, each of which would require full time, is that one gets neglected or neither ~ne is done as well as it should be. The present situation may be the result of inability to attract and hold sufficient qualified personnel at current salary rates and the fact that the Commissioner's program of upgrading of positions particularly the middle administrative category, has not yet caught up with the need. It m~Y also reflect some over-organization. Whatever the reason, it is felt that the wide use of double assignments may be one of the factors underlying the limited long-range program planning that has just been discussed and the next problem to be discussed dealing with the development of "Rules and Regulations". Recommendation No. 2 It is recommended that immediate steps be taken to review thoroughly the key staffing pattern as a basis for correcting double assignments where this would strengthen the organization. Rules and Regulations Wide variations exist in the ready availability of complete and up-to-date statements of the law and rules and regulations under which programs are administered. Implementation of the new administrative procedures act is forcing correction of this condition. After this is done, there is danger that administrators will relax in the belief that every one is informed and if they are not it is their own fault. While the orderly documentation of publication of laws and rules and regulations is a step that will improve administration all along the line it is not a complete answer to all of the problems. Every administrator in the Department readily agrees that the real objective of enforcement of a law is to get compliance and not simply to prosecute violators. Experience in administration of regulatory laws clearly shows that the great majority of the people governed by a law intend to do the right thing. This attitude is built into our form of government. If we start with the idea that the laws under which programs are conducted in the Department are essentially "rules of fair play", the desirability of making the rules of the game understandable to all the players becomes clear. This does not imply that administration should be soft. Any such policy would become a two edged sword. People as a whole respect positive and impartial administration and will, in most cases, play by the rules if we do our part in letting them know just what the rules are. While the material for issuance under provisions of the Administrative Procedures Act is being prepared, each program division might well be reviewing the material that has been issued and consider what additions or new information might be helpful to a full understanding of the law. The Seed Division, for example, has done a good job of including additional explanatory information in one small bulletin and others might consider doing something similar. Recommendation No. 3 It is recommended that the Department plan a series of uniform bulletins or pamphlets to include additional information that will aid in interpreting and understanding the law and the officially promulgated rules and regulations. Legal Counsel The office of legal counsel in the Commissioner's Office is not filled at the present time. We understand that some provisions are underway to correct this situation. 11 The consultants believe that the administration of any regulatory program as extensive as that conducted by this Department justifies the full time services of an attorney. The volume and complexity of legal work in the Department supports this opinion. Recommendation No. 4 It is recommended that this position be filled as soon as possible. Feed, Fertilizer and Insecticide Programs There is considerable similarity in the basic requirements and methods used in administra- tion of the feed, fertilizer and insecticide laws. Each is essentially a labeling law and each requires the collection of samples to be tested in the laboratory. The central administration in Atlanta has established requirements for labels under each of the laws. Copies of labels must be submitted with application for registration. Labeling regulation for insecticides is somewhat more complicated than the other two laws in that the chemical composition claimed must be passed on in relation to the claims made, and instructions for application and caution notes must be placed on the label before the compound may be registered. The section head in charge of each of these laws is responsible for issuing licenses, collection of fees, and taking final action on all violations. He also prepares the materials for rules and regulations and develops plans and procedures for field inspection which is now handled by the consolidated field inspection forces. Inspectors draw samples and examine the labels for compliance with the law. A considerable volume of statistics is compiled by each section. It appears that these functions are over organized. That is, the three laws could be handled more economically and just as effectively in one unit. The statistical reporting varies quite a lot as between the sections. A question arises as to how much of this is actually used. Some careful review should be made and steps taken to eliminate that which is not needed and the several reports should at least conform to good statistical standards for presentation. Recommendation No. 5 It is recommended that the three sections be combined in one unit to be known as the Feed, Fertilizer, and Insecticide Division. Market Facilities Atlanta Market The Atlanta Market was built under the provisions of thi Market Authority Act and began operation in January 1959, the middle of the fiscal year. The market serves as the central produce market for the Atlanta area and as a distribution point for a large region in the State and in other states. The market is a well designed and well managed facility. Sales on the market last year were valued at $47,288,916. In building the Atlanta market, as in the case of similar markets built in other states in this region, it was recognized that a considerable period of time is required to build up rentals, and to get the market organized and firmly established on a paying basis would require a considerable period of years. During this development period rentals and fees could not be expected to meet all of the current operating costs including maintenance and necessary capital improvements plus interest on the capital investment and retirement of bonds. To provide for this development period it was agreed that an annual appropriation of $650,000 would be made available at least through the period necessary to amortize the bonds. Good progress has been made. Revenue from rentals, fees and other charges have met total direct operating costs with some surplus ever since the first full year of operation in 1960. In 12 1964, total revenue amounted plus of $212,623 (figures are to $616,613 and operating expenses were $402,990, leaving a surrounded) a~ilable for nece_ssary capital improyem.~nts and helping with interest and amortization of the b.