Bring Back Urban Impact Statements
In the late 1970s, President Carter struggled to gather institutional and public support for a national urban agenda that would focus federal policy on cities. Urban areas, he believed, were in decline because the federal government had neglected them. Ultimately, his national urban policy was a bust that fizzled out upon Reagan's assumption of the presidency. However, at least one of his policy innovations - federal budgetary urban impact analyses - ought to be revived.
On August 16, 1978 Carter signed an executive order requiring all executive agencies to develop Urban and Community Impact Statements. The Office of Management and Budget later clarified what the UCIAs would contain. Every federal agency was to analyze each of its proposed initiatives for their impact on cities, counties, and communities and inform the OMB and the White House about policies that ran counter to Carter's urban policy. The agencies were to evaluate initiative based on income, population, employment, state and local governments' fiscal condition, and other factors (e.g. neighborhood stability) in central cities, suburbs, non-metropolitan communities, communities with high unemployment, and low-income communities.
Though the process varied somewhat, federal agencies generally had to submit the UCIAs to the OMB along with their budget requests, which the OMB then reviewed and submitted to the president for final determination of what programs and funding levels to request from Congress. Tying UCIAs to the budgetary process was a significant, and perhaps overly ambitious, action, as the formulation of the federal budget is one of the most important and work-intensive of the White House's tasks.
The UCIAs were supposed to inform substantively OMB's evaluation of agency budgetary and legislative requests, ideally striking proposals with the worst impacts on urban areas and maintaining those with the best. In practice, a GAO report on UCIAs released just prior to Reagan's termination of the analyses, found that most federal agencies failed to produce UCIAs and that OMB failed to utilize them when they were provided. But the GAO report emphasizes that the limited effectiveness of the UCIAs resulted from procedural and administrative mistakes, not programmatic ones.
Bringing UCIAs back, either through congressional action or through an executive order, would be a significant step towards unearthing the already existent hidden federal urban agenda. Indeed, federal policies like the mortgage interest tax deduction are widely recognized to have a significant impact on cities and suburbs, but decision makers do not recognize this impact when formulating policy. The UCIAs would help elevate the government's federal urban presence to explicit urban policy.
A new UCIA program could learn from the mistakes of the Carter administration. UCIAs could be completed by the White House Office of Urban Affairs, instead of by the agency charged with formulating the policy, mitigating political considerations in the evaluation of urban impacts. The UCIAs could be informed by public comment and made public after their formulation, unlike during the Carter administration. This would both engage the public in policy formulation and allow community groups and others a window into how a wide range of policies - not just explicitly urban ones - will affect their communities. The UCIAs could even be modeled after Environmental Impact statements. This would mean that they would be performed on every proposed federal project that would significantly affect cities, but would not be tied to the budgetary process, easing the burden on the White House at an already hectic time.
Reinstating Urban and Community Impact Analysis would not mean an immediate shift to a federal policy that benefited cities, but would certainly help bring the urban impacts of federal policy - both good and bad - into the light.