in "outside" inquiries that are merely seeking information and use up the time of our staff, but we do try to promptly service those that we receive now.

B. The Criminal Division does not have any citizen or industry groups that have an official tie to the division. However, we do through the United States Attorneys work with grand juries which are composed of citizens, and also we cooperate closely with various law enforcement organizations. There are a great many of these which run all the way from local crime commissions to professional organizations such as the International Association of Chiefs of Police.

Many of these groups are informally involved in the decisionmaking processes of this division in that they both furnish information and request action.

C. There are no especial procedures made for considering the needs of the poor by the division since the basic philosophy of law enforcement is to apply the law to all citizens equally, and I am sure that you agree with this. In the main, the type and kinds of crimes which this division processes do not involve poor people in the sense that you use it in social legislation. As you know, each individual defendant must be represented by an attorney and you, of course, are familiar with the process by which they are appointed and serve.

D. The question is not applicable to this division because the vast bulk of the actual contact with the complaining parties is done by the appropriate investigatory agency, and this division does not enter into these matters until the investigation has been completed and referred for prosecution.

E. Most of these questions are not applicable to this division. Agency records, proceedings, meetings and opinions are withheld from public view because of the nature of the work and are released to public view either through official actions such as the indictment of a defendant or statements issued through the public information office of the Department of Justice.

F. The principal contact that this division has with the public outside of Washington, D.C. is through the offices of the United States Attorneys.

II.

A. Yes. Most of the decision-making in this division is actually done by individual lawyers who have the assignment of a specific portion of an enforcement program, and as far as I can tell is done with reasonable promptness on a professional basis.

B. Very little specialized mechanical or computer facilities are now available, and in the field of organized crime these would be very useful. We have included in our present budget a request for a computer program to be used in organized crime work. This could also be used in the intelligence gathering action for public disturbances, riots, etc.

C. There are many established procedures, mechanisms and customs for consulting and coordinating with other government agencies since we do have such a close working relationship with the many investigatory agencies of the federal government. They vary according to the statutes, procedures and customs of the individual agencies we deal with.

D. Each section of the division has a monthly report which contains an analysis of the work of that section and an appraisal of the needs and future action of each particular piece of work. It is primarily an executive function of the section chiefs and of this office to assess the quality and efficiency of the performance. This we work on constantly. E. Not applicable.

III.

This questionnaire was circulated to each of the sections for their comments and suggestions, all of which have been taken into account in making the above answers. Most of this questionnaire is not directly applicable to the work of this division, but I hope that the above answers will be of some use to you.

Sincerely,

WILL WILSON,

Assistant Attorney General.

G. Immigration and Naturalization Service

U.S. DEPARTMENT OF JUSTICE,

IMMIGRATION AND NATURALIZATION SERVICE,

Washington, D.C., March 14, 1969.

DEAR SENATOR KENNEDY: Your questionnaire regarding citizen involvement in the administrative process seems directed primarily to the regulatory agencies. However, I am happy to respond, to the extent that the questions are relevant to the activities of this Service. My responses are enclosed and are keyed to the items in your questionnaire. Sincerely,

RAYMOND F. FARRELL, Commissioner.

I. CITIZEN INVOLVEMENT IN THE ADMINISTRATIVE PROCESS

A. There is a wide variety of input from private citizens and citizen groups into the Service's decision-making process. This input ranges from information furnished by citizen witnesses which affect decisionmaking an individual naturalization cases up to large scale responses by citizens and citizen groups to notices of proposed rule making published in the Federal Register under the provisions of 5 U.S.C. 553. These inputs are encouraged by direct solicitation and by publication in the Federal Register. Additional input increases are not required.

B. There are a variety of citizen and industry advisory groups which contribute to Service policy making and decisions. There are hundreds of voluntary social service agencies throughout the United States whose primary concern is with foreign born residents or prospective residents of the United States. Some of the larger, such as the Church World Service, the Hebrew Immigrant Aid Society, and the Catholic Welfare Conference, have representatives assigned to our larger offices who are in daily contact with our employees. The Immigration and Nationality Bar Association, with local chapters in each of the larger cities, and its National Chapter, participate in a constant exchange of views with field and headquarters offices as a contribution to our decision-making process. Industry groups, such as

the Air Transport Association, the American Merchant Marine Institute, Airport Owners and Operators Association, State and Municipal Port Authorities, and associated travel-oriented groups are involved in a continuing exchange with the Service. It is also our policy to foster regular contacts and meetings with local Chambers of Commerce at ports of entry, where immigration policy has a sig nificant impact, to encourage the solicitation of local views as an input to decision-making.

C. The views and needs of the poor are considered on an individual case basis or a group basis where immigration and nationality procedures apply. There is a range of response from the administrative waiver of required fees for individuals seeking benefits to larger involvement with federal, state and private agency programs dealing with refugee groups, which have varying percentages of members who would be classed as poor. For example, we promote and encourage English literacy classes as part of our naturalization program. With volunteer groups, we promote citizenship. These become peripheral benefits to an alien classed as poor since the lack of English or citizenship is sometimes a bar to employment.

D. Complaints regarding Service personnel or activities received from any source whatever are immediately acknowledged, with advice to the complainant that inquiry is being initiated into the matter. The appropriate Service field office is then directed to institute an investigation to develop the facts concerning the complaint. If the complaint involves an employee, immediate inquiry is initiated to determine the basis for the complaint and the action to be taken. The inquiry will generally include interviews of the complainant, the employee, and other individuals of interest. Findings are thereafter reviewed and a decision is made as to the disposition of the complaint, including the institution of formal disciplinary action where appropriate. The complainant is informed of the findings and disposition.

If a complaint involves a Service entity or activity, the complainant is immediately informed, if possible, of the Service position with respect to the matter brought to its attention. This will include references to applicable statutory and regulatory procedures. Otherwise, the matter is thoroughly reviewed and, if necessary, inquiries are initiated to determine the basis and ramifications of the complaint. The complainant may be interviewed to determine his interest and objectives. Upon completion of the inquiry, he is informed of the findings and position of the Service.

Where entities and activities are involved, administrative procedures as well as regulations are revised to correct unjust or inequitable practices, or to facilitate or expedite procedures in the interest of the public. Furthermore, the Service prepares recommendations looking toward amendment of statutory provisions to correct inequities in the law. During the time a complaint is being considered by the Service, the complainant is treated with objectivity and as a public spirited citizen interested in the efficiency of government.

The remedies and sanctions are deemed adequate and it has not been necessary to involve them often.

E. It is believed that those who are affected by the Service's activities have adequate knowledge thereof. The Service has made various

avenues available for those who wish to inform themselves or acquire greater knowledge of Service activities. The Service responds to all requests for information either orally or in writing, depending on how the request is presented. All district offices and sub-offices have set aside space for information counters where members of the public may present their inquiries. The information counters are manned by specially trained personnel.

Pamphlets, brochures and books have been prepared by the Service and are available to the public at Service offices or through the Government Printing Office. These contain a wealth of information on Service activities and the laws which the Service is required to administer and enforce. Some examples are:

"United States Immigration Laws. General Information"

"Development of Immigration and Naturalization Laws and Service History”

"Gateway to Citizenship"

"Our Immigration-A Brief Account of Immigration To The United States"

"A Welcome To The United States"

"Naturalization Requirements And General Information"

Various textbooks on citizenship offering instruction to those preparing for naturalization

A quarterly publication, with a magazine format, the I&N Reporter, available to the public, offers timely articles on Service activities and programs and also takes note of the latest judicial and administrative decisions affecting the work of the Service.

Awareness of the Service's functions, processes and decisions is promoted through full compliance with the provisions of the Public Information Act, 5 U.S.C. 552. Agency records, proceedings, and opinions are withheld from the public only to the extent authorized by the Public Information Act.

F. The Service has established public reading rooms in each of its 32 district offices in the United States. Available in each room are:

1. Published materials, including complete sets of precedent administrative decisions and the regulations and statutes under which the Service operates.

2. Statements of policy, interpretations and instructions to staff which have been issued by the Service and which affect the public. An index is included.

3. Copies of each district's unpublished administrative decisions, arranged by category, including copies of any relating appellate actions.

Complaint services are readily available outside Washington, and this fact is widely known to practitioners in the field of immigration and naturalization, and to the various voluntary agencies which deal with the foreign born. INS is basically a field organization whose functions have been decentralized. Its district offices, suboffices, ports of entry, and border patrol stations total several hundred. Transactions between members of the public and the Service at these various locations number in the millions. Most of those who feel aggrieved because of some Service action direct their complaints to the field offices rather than to Washington.

II. PROCEDURES FOR PROMOTING MORE RESPONSIVE AGENCY

DECISION-MAKING

A. It is considered that the decision-making procedures of the Service with the complex problems which are generally involved therein are handled and completed with reasonable speed and in many instances, with optimum speed. Every effort is made to improve, where possible, the procedures involved with a view to shortening the period of time required to adjudicate a case.

B. The Service has a program and management analysis staff which is utilized in management improvement programs. Computer oriented technology is utilized in its information processes and computer applications are under constant study. Our main computer application would be in a sophisticated name-searching process, which has as yet not reached an optimum development by the industry.

C. The Service maintains direct liaison with other government agencies whose functions touch upon the responsibilities of the Service. Service officers responsible for specific Service programs communicate directly, either by telephone or by correspondence, with their counterparts in other agencies for consultation and exchange of views. Such contacts are supplemented with meetings and conferences to discuss in depth matters of mutual interest or concern.

D. Regular inspections of field installations and activities are conducted by teams of Field Inspectors from Washington to provide the agency with independent, objective and constructive appraisals of the effectiveness, efficiency, and economy with which the operational and management responsibilities of the Service are performed. Findings are made as to whether assigned and planned objectives are being carried out in the manner prescribed, with the results intended, and in an adequate and timely fashion. The field inspection program thus provides a continuing review of the Service performance in the accomplishment of its mission, goals and priorities, and a continuing assessment of the effectiveness of its procedures and structures.

Another tool used by the Service to assess the effectiveness of its performance is its well established work measurement system. All work performed by Service officers is recorded in terms of work units, and measured in relation to the time it takes to do the work. The information collected under this system is used at every organizational level to project workloads, identify and wipe out backlogs, determine trends, evaluate new procedures, and improve work methods. Statistical reports pertinent to the work measurement system are made available monthly and consolidated semi-annually and annually.

The concepts contained in cost-benefit analysis and "P.P.B.S." have been and are currently in use as they apply to Service programs. There are no gaps in the Service's statutory authority.

III. THIS QUESTIONNAIRE

It took approximately 15 hours to consider and prepare a response to Sections I and II. The questions presented raised significant issues regarding the Service's practices, procedures, and problems and