,!r 

GAO united states 

General ACCOMUII~ OfXlce 

WashS.n@~1,D.C.20648 

HumrnBesourcesDivieion 

B-252054 

April 5, 1994 

The Honorable John Conyers, Jr. 

Chairman, Committee on Government Operatfons 

House of Representatives 

The Honorable Edolphus Towns 

Chairman, Subcommittee on Human Resources 

and Intergovernmental Relations, 

Committee on Government Operations 

House of Representatives 

Over the past two decades, the fiscal distress at all 

levels of government contributed to a dramatic shift in 

American intergovernmental relations. Federal aid to state 

and local governments peaked in 1978, then began to decline 

as a proportion of total state and local spending. At the 

same time, federal policymaking began shifting from an 

incentive-based system of grants-in-aid designed to 

encourage state and local governments to perform an 

activity or provide a service to a more command-based 

system requiring state and local action under federal 

regulation. 

This letter responds to your request for information on the 

perspectives of state and local government representatives 

on the impact of unfunded federal mandates. We obtained 

our information through reviews of mandate studies and 

discussions with public sector associations; federal, 

state, and local officials; and researchers who have 

studied the mandate issue. Since our objective was to 

identify mandate concerns from the viewpoint of state and 

local governments, we did not evaluate the extent to which 

their views differ from federal perspectives. As agreed 

with your offices, we did not attempt to independently 

verify the accuracy of the data they provided or to 

substantiate the validity of examples offered to illustrate 

the impact of mandates (see app. I for a description of our 

scope and methodology). 

Mandates are generally defined as any constitutional, 

statutory, or regulatory provision that imposes 

requirements on local governments for which they must 

GAO/HEHS-94-110R Federal Mandates 
B-252054 I 

absorb the costs. Before the 19708, financial incentives 

were often provided with mandates to assist state and local 

governments in implementing them. However, as the 

condition of the federal budget worsened, fewer financial 

incentives accompanied federal mandates. In addition, the 

ability of state and local governments to absorb mandate 

costs declined as they faced their own budget problems. 

The major concerns of state and local officials we 

contacted were (1) the cost of implementing some mandates; 

(2) the lack of flexibility and impact of mandates on local 

budget decisions and spending priorities; and (3) the 

absence of conclusive scientific evidence (for example in 

the environmental protection area) to support the need for 

some mandate prescriptions (see app. II for the views of 

state and local representatives). 

From 1981 through 1990, 27 new federal laws or statutory 

amendments were enacted with provisions that regulate state 

and local governments (see app, III). State and local 

officials noted that exact estimates of the costs of 

implementing unfunded mandates are difficult to sort out. 

However, several jurisdictions have commissioned studies to 

estimate their costs from federal and/or state mandates 

(see app. IV for summaries of the findings of three 

selected mandate cost studies). 

Growing concern about the effects of mandates on state and 

local governments has generated a variety of 

countermeasures, but no uniform solutions have been found. 

For example, some states require the development of cost 

estimates for proposed legislation, to force legislatures 

to consider the costs of potential mandates before they are 

voted on. Legislative initiatives to restrict the passage 

of unfunded mandates have been introduced at the state and 

federal levels of government. Thirty-nine separate mandate 

relief bills had been introduced in the 103rd Congress as 

of December 1993 (see app. V). 

Copies of this letter are being sent to interested parties 

and made available to others on request. If you have any 

questions, please call me on (202) 512-6805. 

Director of Operations 

2 GAO/HEHS-94-11OR Federal Mandates 
Contents 

Letter 

Appendix I 

Scope and Methodology 

Appendix II 

State and Local Representatives' 

Perspectives on Unfunded Mandates 

Appendix III 

Major Federal Laws and Statutory Amendments 

Regulating State and Local Governments, 1981-90 

Appendix IV 

Selected Cost Studies of Unfunded Mandates 

Appendix V 

Mandate Relief Bills Introduced in the 103rd Congress 

Tables 

Table 1.1: 

Table 1.2: 

Table IV.l: 

Table IV.2: 

Table IV.3: 

Public Sector Associations GAO Interviewed 

State and Local Officials GAO Interviewed 

Estimated Costs of Federal and State 

Environmental Mandates to Chicago, Illinois 

Estimated Costs of Federal Environmental 

Mandates to Anchorage, Alaska 

Estimated Costs of Federal and State 

Environmental Mandates to Columbus, Ohio 

Abbreviations 

EPA Environmental Protection Agency 

14 

17 

21 

4 

5 

18 

19 

20 

GAO/HEHS-94-11OR Federal Mandates 
APPENDIX I APPENDIX I 

SCOPE AND METHODOLOGY 

We have reviewed the issue of unfunded mandates several times in 

recent years, including studies of state experiences with 

legislative mandates and trends in intergovernmental re1ations.l 

At the request of the Chairman, House Committee on Government 

Operations and the Chairman of its Subcommittee on Human Resources 

and Intergovernmental Relations, we augmented this work through 

reviews of the current literature and discussions with affected 

parties to identify the major concerns of state and local 

governments about unfunded mandates. 

To identify and better understand mandate concerns at the state and 

local levels of government, we discussed these concerns with a 

number of public sector associations (see table l), state and local 

officials (see table 2), several researchers who have completed 

studies of the mandate issue, and federal officials at the 

Environmental Protection Agency. The states and localities we 

visited were recommended by public associations, committee staff, 

or others as illustrative of state and local mandate concerns. 

Table 1.1: Public Sector Associations Interviewed 

Advisory Commission on Intergovernmental Relations 

Association of State Drinking Water Administrators 

11 National Association of Counties II t 

National Association of Towns and Townships 

National Conference of State Legislatures 

'Legislative Mandates: State Experiences Offer Insights for 

Federal Action (GAO/HRD-88-75, Sept. 1988). 

Federal-State-Local Relations: Trends of the Past Decade and 

Emerging Issues (GAO/HRD-90-34, Mar. 1990). 

4 GAO/HEWS-94-11OR Federal Mandates 
APPENDIX I APPENDIX I 

Table 1.2: State and Local Officials Interviewed 

California: 

City officials of Davis, Lodi, Merced, Orinda and Sacramento; 

and the California Department of Finance, Department of 

Health and Welfare, and the California League of Cities 

Michigan: 

Michigan Department of Management and Budget 

North Carolina: 

City officials from Valdese, Hickory, and Winston-Salem; 

and the North Carolina League of Municipalities 

Ohio: 

Columbus Department of Health 

Wisconsin: 

Wisconsin Department of Natural Resources 

In California, North Carolina, and Wisconsin, we also obtained 

information on efforts by state and local governments to cope with 

mandate burdens by working in partnership with the governmental 

unit imposing the mandate. 

We also reviewed three major studies prepared by the cities of 

Anchorage, Alaska; Chicago, Illinois; and Columbus, Ohio, on how 

unfunded mandates affected them. (See app. IV). 

Our purpose in gathering the views of state and local officials was 

to illustrate their perceptions of how mandates affected them. As 

a result, we did not attempt to weigh the extent to which their 

views might differ from those held by affected federal agency 

officials. In addition, we did not attempt to independently verify 

the accuracy of data they provided or substantiate their examples 

of mandate impacts. We completed our work between February 1993 

and February 1994, 

5 GAO/HEHS-94-11OR Federal Mandates 
APPENDIX II APPENDIX II 

STATE AND LOCAL REPRESENTATIVES' 

PERSPECTIVES ON UNFUNDED MANDATES 

BACKGROUND 

Considerable debate exists over the definition of federal mandates. 

Mandates are broadly defined as any constitutional, statutory, or 

regulatory provision imposing requirements on local governments for 

which they must absorb the cost. Much of the debate centers on 

whether these added costs result, for example, from conditions of 

grants-in-aid accepted **voluntarily" by recipients. Those who feel 

the conditions of grants-in-aid represent a mandate note that the 

conditions may add a new function for local governments to 

administer; require that local governments fund a part of this new 

function themselves; require specific means for achieving the 

mandate locally; or set higher standards of service than local 

governments would set themselves. 

A recent example in the Medicaid program illustrates the different 

opinions about what constitutes a federal mandate. In 1991, as a 

condition of continued receipt of federal funds under the Medicaid 

program, states were required to broaden program eligibility. 

Since states share in Medicaid program costs, they generally viewed 

this broadening of program eligibility as an unfunded mandate 

because it resulted from a federal order and increased state costs. 

Others, however, viewed this broadening of program eligibility as a 

condition of grant-in-aid accepted voluntarily by the states rather 

than an unfunded mandate. 

The character of federal mandates has changed significantly over 

time. Before the 197Os, federal mandates often were accompanied by 

financial incentives to assist state and local governments in 

implementing them. For example, in the early 1970s with the 

passage of the Clean Air Act and Clean Water Act, the federal 

government allocated over $18 billion nationwide for 

implementation. When the Americans with Disabilities Act was 

passed in 1990 to establish national standards to prohibit 

discrimination in public services and accommodations, very little 

federal funding was provided to state and local governments for 

implementati0n.l 

Growing concerns about the effects of intergovernmental mandates 

helped launch a broad array of efforts by the federal government to 

reform the regulatory process and to grant relief to state and 

local governments. By 1981, all three branches of the federal 

'Some local governments were able to obtain categorical grants-inaid from the Department of Transportation for assistance in 

implementing the Americans with Disabilities Act. 

6 GAO/HEHS-94-I1OR Federal Mandates 
APPENDIX II APPENDIX II 

government had taken actions designed to reduce the problems posed 

by excessive intergovernmental regulation, ease financial and 

compliance burdens, and simplify requirements. Although these 

efforts were most intense during the early years of the Reagan 

administration, they began during the 1970s and have gained 

prominence again in the 1990s. 

For example, in 1976 the Supreme Court took up the mandate issue 

and barred the application of federal wage and hour regulations to 

state and local governments. In the early 1980s the Congress 

enacted a series of statutes to restrain the growth of federal 

intergovernmental regulation, including the Paperwork Reduction Act 

of 1980 to reduce or eliminate specific forms or requirements 

imposed through federal regulatory efforts; the Regulatory 

Flexibility Act of 1980 to ease federal regulatory burdens on small 

governmental jurisdictions (populations under 50,000) and small 

businesses; and the State and Local Cost Estimate Act of 1981 to 

increase congressional awareness of the costs proposed legislation 

would impose on state and local governments. More recently, 39 

separate mandate relief bills had been introduced in the 103rd 

Congress as of December 1993. (See app. V.) 

The Reagan administration also took a variety of administrative 

actions designed to reduce or to eliminate regulatory burdens. 

These included Executive Order 12291, which established a 

centralized regulatory review and clearance process within the 

Office of Management and Budget, and Executive Order 12612, which 

set forth criteria for federal agencies when proposing new 

legislation or rules that would significantly affect state and 

local governments. 

Despite some early successes, federal mandate relief efforts did 

not achieve the intended results. A 1992 Advisory Commission on 

Intergovernmental Relations mandate study stated that despite the 

federal government's efforts to constrain the growth of 

intergovernmental regulation, the 1980s was an era of regulatory 

expansion. According to the Advisory Commission report, 27 new 

laws or major amendments to existing statutes were enacted in the 

198Os, which imposed significant additional regulatory burdens on 

state or local governments. (See app. IV.) By comparison, 22 

major pieces of intergovernmental regulation were adopted during 

the 1970s. 

VIEWS OF STATE AND LOCAL 

REPRESENTATIVES 

While the state and local officials we contacted concurred with the 

general objectives that mandates seek to achieve--such as 

breathable air, drinkable water, and public facility access for the 

disabled--they were concerned about the actual or perceived 

7 GAO/HEHS-94-11OR Federal Mandates 
APPENDIX II APPENDIX II 

consequences of specific, federal prescriptions on how to achieve 

those outcomes at the local level. State and local officials and 

interest groups cited three main concerns with mandates in their 

discussions with us: (1) the cost to implement mandates can be 

significant; (2) the lack of mandate flexibility can intrude on 

local budget decisions and drive spending priorities; and (3) 

available scientific evidence (for example, in the environmental 

protection area) is not conclusive on the need for some mandate 

prescriptions. 

Mandate Costs Can Be Siunificant 

State and local officials we contacted most often mentioned 

concerns about the costs of unfunded mandates. Although some local 

officials cited specific mandates, the cumulative effect of 

mandates on local budgets was a constant refrain of officials we 

contacted. Cities are subject to mandates directly from the 

federal government, such as the requirements in the Americans with 

Disabilities Act. States may also impose mandates on, or restrict 

funds to, local governments as an indirect result of mandates 

placed on them. 

Several local officials also noted that states often add to the 

mandate burden by narrowly interpreting federal regulations or in 

some cases passing down requirements that are more restrictive than 

those passed down by the federal government. For example, a study 

conducted by Columbus, Ohio, stated that the Ohio Solid and 

Hazardous Waste law parallels most federal provisions of The 

Resource Conservation and Recovery Act of 1976; but also 

establishes more stringent standards for hazardous waste 

regulations. Also, court-imposed requirements can result in 

increased costs to state and local governments. For example, local 

jurisdictions have been required to build more prison facilities to 

comply with court-ordered minimum-space requirements for prisoners. 

Although officials appreciate the potential value of mandates--for 

example, a goal of decreasing public health and environmental 

risks-- several noted that the costs of implementing mandates are 

considerable for state and local governments. 

jurisdictions have prepared, 

For example, several 

or had prepared for them, studies 

estimating their costs from federal and/or state mandates. For 

example, Michigan estimated that its spending would rise from $39.6 

million to $136.9 million (a 245-percent increase) over the 6-year 

period 1990 to 1995 due to federal Medicaid mandates. A 1991 

Columbus, Ohio, study of federal and state mandates estimated that 

compliance with existing environmental mandates alone would cost 

Columbus $1.1 billion over the next 10 years and consume nearly 

one-fourth of the city's budget by 1996. A Chicago study estimated 

that between 1992 and 1995, the city would spend over $319 million 

on unfunded federal and state environmental mandates. Anchorage, 

8 GAO/HEHS-94-11OR Federal Mandates 
APPENDIX II APPENDIX II 

Alaska, estimated federal environmental regulations would cost it 

over $429 million over the lo-year period 1991 to 2000. (See app. 

V for additional details on mandate cost studies.) 

Although mandate cost studies paint an alarming picture when viewed 

independently, they often combine the costs of federal and state 

mandates, cover different time periods and programs, or contain 

limited information on the assumptions and methods used to estimate 

the costs associated with specific mandates. As a result, for 

example, comparing study results or assessing the extent to which 

the studies measure the direct impact of federal regulation, the 

impact of state imposed requirements, or the degree of efficiency 

in local operations is difficult. 

Mandates Can Intrude on 

Local Buduet Decisions 

Officials we interviewed indicated that state and local spending 

priorities can be greatly affected by mandates. Officials also 

commented that they are not afforded sufficient input before 

regulations are drafted and added that inflexible mandates can 

result in impractical and wasteful expenditures. 

The Anchorage study found that one of the more frustrating aspects 

of environmental mandates for mayors and other local officials-- 

aside from the fiscal impact --was the loss of control over their 

budgets and decisionmaking powers. Mayors complained that higher 

levels of government set priorities and make decisions that have 

major impacts on municipal budgets and private-sector economic 

opportunities without consulting local officials. 

Echoing this theme, the Chicago study stated that each time a city 

pays for an unfunded mandate opportunity costs should be 

considered. The study noted that making such public policy tradeoffs are always difficult. For example, should the city pay the 

$40 million required to "cocoon" a bridge to comply with federal 

Environmental Protection Agency (EPA) requirements for removing 

lead-based paint, or is the money better spent on police protection 

in high crime zones? Several officials contacted said that they 

feel constrained in their ability to assess local risks and make 

risk-based decisions for the use of scarce resources, 

Officials we interviewed also expressed concern that they were 

losing control of their budgets due to the demands of federal 

mandates. For example, officials in Winston-Salem, North Carolina 

said that they are just beginning to realize the trade-offs they 

are having to make due to mandates. In the past, they were able to 

cover mandate costs from accumulated budget surpluses and federal 

funding that accompanied many mandates. Now many local governments 

are under fiscal stress as budget surpluses have declined or 

9 GAO/HEHS-94-11OR Federal Mandates 
APPENDIX II APPENDIX II 

disappeared, local tax burdens have increased, and the number and 

cumulative cost of federal mandates have grown. One official 

pointed out that the federal government needs to take the burden 

placed on local governments into consideration and set national 

priorities so that cities can tackle as many high-priority issues 

as their budgets permit. The official said that the federal 

government cannot expect the cities to solve every problem with 

limited budgets and little federal assistance. 

The "one size fits all" approach used by the federal government to 

establish some mandate requirements was another concern of state 

and local governments. This approach prescribes an often 

inflexible set of minimum standards and processes for achieving 

mandate objectives that must be carried out by the entire nation. 

Officials told us that it is not reasonable to expect every city of 

every size in every geographical location to be able to do exactly 

the same thing efficiently and effectively. 

In commenting on the inflexibility of mandate requirements, the 

Chicago study reported that federal regulations work best when they 

clearly specify the required outcome and leave implementation to 

the local authority in charge. According to the study, however, 

federal agencies often involve themselves in implementation issues 

that result in additional administrative burdens at the local 

level. For example, to meet the Clean Air Act's carbon monoxide 

standards, Chicago established a plan to minimize traffic jams to 

alleviate a primary source of carbon monoxide emissions, Although 

the city met the standards, as validated through federal 

monitoring, city officials believed that EPA demanded costly 

documentation to support that certain aspects of the plan were 

implemented. 

The lack of flexibility associated with certain mandates was viewed 

by some officials we interviewed as causing impractical and 

wasteful expenditures, in some cases without regard for the 

diversity in community environmental situations, populations, tax 

bases, and policy needs. Local officials indicated that when 

imposing requirements--for example, for a new waste water treatment 

system or access to buildings or public facilities--differences 

among cities need to be considered. One example cited by the 

National Conference of State Legislatures was the transportation 

program for the disabled in Alexandria, Virginia. Alexandria had a 

nationally acclaimed program for using local taxicab companies to 

transport disabled persons door-to-door to any local destination at 

city expense. However, after implementing a mandated requirement 

to modify local buses to permit access for the disabled, the city 

could not afford to provide the taxicab service. As a result, 

those using wheelchairs now have to get to and from bus stops that 

can be some distance from their homes and destinations. 

10 GAO/HEHS-94-11OR Federal Mandates 
APPENDIX II APPENDIX II 

Another concern is that regulations are sometimes premised on 

certain geographic, climatic, or other conditions that do not hold 

true for all regions. For example, citing inflexible EPA 

requirements under the Clean Water Act, the International 

City/County Management Association commented 

"Even where rainfall is less than 2 inches annually and 

groundwater contamination is not an issue, new or expanding 

landfills must have a composite liner and leachate collection 

system to avoid groundwater contamination if they accept more 

than 20 tons of landfill per day. In parts of the Southwest, 

desert dumping threatens to become a serious environmental 

threat as residents refuse to pay for expensive new landfill 

capacity." 

Scientific Evidence Is Not Conclusive 

on the Need for Some Mandate Prescriptions 

The State and local officials we contacted were concerned that some 

mandate requirements are not based on sound scientific assessments. 

An official representing state drinking water administrators stated 

that many environmental regulations are implemented without current 

research to establish with certainty the level of risk and the 

costs and benefits of trying to reduce the risk. The official said 

that the lack of conclusive data often leads to regulations that 

are unreasonable, inefficient, or extremely costly. 

For example, a Columbus, Ohio, Health Department official cited 

regulation of the herbicide atrazine, used widely on cornfields, as 

an example of the costliness of scientific uncertainty in federal 

Safe Drinking Water Act regulations. According to this official, 

because atrazine has been determined to be a potential carcinogen, 

EPA limits atrazine in drinking water to a maximum yearly average 

of 3 parts per billion. The Columbus official questioned the 

scientific basis for this limit and suggested that "at this level 

an adult would have to ingest about 3,000 gallons of contaminated 

water per day to be at risk." The Columbus official further noted 

that although the city's typical levels are far below 3 parts per 

billion, the city may be required to install costly EPA-specified 

technology for atrazine removal. 

Current Mandate Relief Efforts 

Measures to relieve the impact of unfunded mandates have been 

proposed at all levels of government, although no uniform or 

widespread solution has been found. Numerous bills designed to 

reStriCt the passage of unfunded mandates have been introduced in 

state and federal legislatures. Some states have adopted 

legislation that allows cities to opt out of compliance with any 

State mandates that are not accompanied with sufficient funding to 

11 GAO/HEHS-94-11OR Federal Mandates 
APPENDIX II "PENDIX II 

implement the requirements. Other jurisdictions rely on ene fiscal 

note process, which requires the development of mandate cost 

estimates for proposed legislation, to force legislatures to review 

the costs of any potential mandate before it can be voted on. 

The National Performance Review (NPR), a major management reform 

initiative by the Clinton administration, recommended that an 

Executive Order be issued to address the problems of unfunded 

federal mandates and regulatory relief. NPR also recommended 

authorization for cabinet secretaries and agency heads to obtain 

selective relief from regulations or mandates in programs they 

oversee. GAO concurred with this NPR recommendation and noted that 

increased regulatory requirements, preemptions, and mandates could 

force state and local governments to choose between meeting their 

service responsibilities and fulfilling national regulatory 

objectives. Executive Order No. 12866, signed September 30, 1993, 

on regulatory planning and review contained provisions that address 

state and local concerns about unfunded mandates. Among other 

steps to ease the mandate burden, the Order emphasized the need for 

regulatory agencies to consult with state and local officials 

before imposing regulations. It also confirms the continuing need 

to evaluate costs and benefits, recognizes the importance of sound 

science and risk assessment, and sets up a process for identifying 

regulatory priorities. 

State and local officials we contacted stressed the belief that 

most of their concerns could be addressed if federal regulators 

allowed them to provide input before regulations were drafted. 

They believe that, under the present process, federal regulators 

view them as hostile parties to implementing national policy 

objectives rather than common stakeholders in responding to public 

health, safety, and welfare needs. Where their input is permitted 

through public hearings, it is seen as too little and too late to 

have a significant impact. They thought that if they provided 

earlier input, regulators would have a better understanding of 

diverse state and local conditions and the difficulty associated 

with one-size-fits-all prescriptions. 

Federal waivers have been used as a means to recognize diverse 

state and local conditions in the implementation of national policy 

objectives. For example, in Wisconsin, the Water Supply Division 

of the Department of Natural Resources [DNR) was successful in 

obtaining a federal waiver allowing cities and municipalities that 

had secure wells to test for contaminants on a less frequent basis 

than those communities whose wells were at greater risk. Thfs 

saved the communities and the Water Supply Division $5.8 million 

that would have been needed for testing and monitoring in the first 

year of the program. The program is expected to save over $15 

million in the first 3 years (testing is on a 3-year cycle). 

Without the frequent contacts established between the Wisconsin 

12 GAO/HEHS-94-11OR Federal Mandates 1 
APPENDIX II APPENDIX II 

DNR, the Regional DNR, and EPA headquarters, Wisconsin DNR 

officials believe that the federal waiver would not have been 

approved. 

EPA recognizes the need to make its regulatory requirements more 

flexible for small communities. Under requirements of the 

Regulatory Flexibility Act, EPA is trying to develop methods for 

obtaining small community input early in its development of 

environmental regulations. Although EPA has been successful in 

forming a number of groups to obtain local input, EPA's efforts 

have been hampered by fund shortages and personnel cuts in past 

years. 

Efforts to more actively engage state and local government 

officials have not been limited to the federal level. For example, 

in 1993 several representatives from public sector associations, 

states, and local governments formed the Coalition for 

Environmental Mandate Reform designed to systematically address 

environmental mandate concerns through joint federal, state, and 

local partnerships. The coalition plans to 

-- identify and cost-out existing environmental mandates, 

-- establish a peer science advisory committee to monitor 

environmental mandates to determine whether they are based on 

sound scientific principles, 

-- identify and prioritize local environmental conditions, 

-- rank local environmental priorities based on costs required and 

benefits received, 

-- submit a prioritization plan to the state or federal EPA office 

for review and comment, 

-- solicit approval from the local community for a final 

environmental improvement plan to be followed by approval from 

the state and federal EPA office, and 

-- evaluate and measure compliance with environmental improvement 

plans. 

Although this coalition was formed to address environmental 

mandates, an official from the group noted that their plan, if 

successful, could be expanded to apply to all federal and state 

mandates. 

13 GAO/HEHS-94-11OR Federal Mandates 
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APPENDIX IV 

SELECTED COST STUDIES OF UNFUNDED MANDATES 

APPENDIX IV 

The cities of Anchorage, Alaska, Columbus, Ohio, and Chicago, 

Illinois, have each prepared, or had prepared for them, studies : 

estimating their costs from unfunded federal and state mandates.' 

These studies each employed different methodologies and assumptions 

and covered different time periods. Consequently, the results are 

not comparable. Moreover, GAO did not independently verify the 

data presented. The following information summarizes the findings 

of the three studies. 

STUDY NO. 1 

Putting Federalism to Work for America: Tacklinu the Problems of 

Unfunded Mandates and Burdensome Regulations. This study was 

prepared by the City of Chicago and Roosevelt University Institute 

for Metropolitan Affairs (Nov. 19, 1992). 

Description 

This study sought to identify the causes and magnitude of the 

problems faced by cities and states weighed down by unfunded 

mandates and burdensome regulations, and to propose practical, 

principled solutions. The study estimated the cost of 11 federal 

and state environmental mandates on the City of Chicago for the 

period 1992 through 1995. 

Results 

Estimated costs for complying with the federal and state 

environmental regulations over the 4-year period 1992 to 1995 were 

over $319 million. The study states that, adjusted for inflation, 

in 1993 Chicago received less than half of what it received in 

federal aid in 1980--accounting for 14 percent of the city's budget 

in 1993 versus 29 percent in 1980. 

17 GAO/HERS-94-11OR Federal Mandates 
APPENDIX IV APPENDIX IV 

Table IV.l: Estimated Costs of Federal and State Environmental 

Mandates to Chicaqo, Illinois 

Mandate 

Resource Conservation 61 Recovery Act 

Estimated cost 

(1992-95) 

$159,788,344 

Underground Storage Tanks 4,480,020 

Clean Water Act/Water Quality Act 

Clean Air Act 

Safe Drinking Water Act 

Infectious Waste 

Asbestos Hazard Emergency Response Act 

Federal Insecticide, Fungicide and Rodenticide 

Act 

8,493 

138,241,223 

10,580,038 

4,246 

21,232 

95,545 

Toxic Substances Control Act I 21,232 

National Emissions Standards for Hazardous Air 

Pollution 

6,000,OOO 

Emergency Planning and Community Right-to-Know 

Act 

Total 

STUDY NO. 2 

Pavino for Federal Environmental Mandates: A Loominq Crisis for 

Cities and Counties. This study was prepared by the Municipality 

of Anchorage, Alaska (Jan. 1993). 

DescriDtion 

This study covered 10 major federal environmental mandates 

administered by the Municipality of Anchorage to determine their 

long-range impacts on the municipal budget. The budget categories 

included were personnel, supplies, other services, equipment and 

capital expense for each utility and municipal department. State 

and federally funded projects and personnel were not included, 

although municipal matching funds for those projects were. 

18 GAO/HEHS-94-11OR Federal Mandates 
APPENDIX IV APPENDIX IV 

Results 

Estimated costs of federal environmental regulations to Anchorage 

totaled $429,936,737 for the period 1991 to 2000, inflationadjusted at the prevailing 7 percent rate for environmental 

projects. Ninety-one percent of the costs involved three 

environmental acts. The most expensive program, Clean Water Act, 

accounted for 36 percent of the costs. The Clean Air Act and 

Resource Conservation and Recovery Act accounted for 34 percent and 

21 percent of costs, respectively. 

Table IV.2: Estimated Costs of Federal Environmental Mandates to 

Anchoraae, Alaska 

nvlronmen 

STUDY NO. 3 

Environmental Legislation: The Increasino Costs of Reoulatorv 

ComDliance to the Citv of Columbus. This study was prepared by 

Environmental Law Review Committee (May 13, 1991). 

Description 

This study covered the estimated cost impact of 14 federal and 

state environmental mandates to the City of Columbus, Ohio, Of the 

19 GAO/HEHS-94-11OR Federal Mandates 
APPENDIX IV APPENDIX IV 

14 mandates 7 were federal/state mandates; 3 were federal only; and 

4 were state only. 

Results 

Estimated costs for complying with environmental regulations over 

the lo-year period 1991 to 2000, were over $1 billion (in 1991 

dollars), With an average annual inflation rate of 4 percent, the 

estimated costs were over $1.3 billion. 

Table IV.3: Estimated Costs of Federal and State Environmental 

Mandates to Columbus, Ohio 

Estimated Cost 

Mandate (1991-2000) 

Asbestos Hazard Emergency Response Act $10,804,150 

Clean Air Act 5,420,694 

Clean Water Act/Water Quality Act 775,046,972 

Explosive Gas Monitoring 444,000 

Federal Insecticide, Fungicide and Rodenticide 65,500 

Act 

Infectious Waste 50,000 

Occupational Health and Safety Administration 91790,480 

Act 

Resource Conservation and Recovery Act 19,276,792 

Safe Drinking Water Act 

Superfund Amendments and Reauthorization Act 

I 

97,000 

Title III 

Solid Waste Disposal 

Toxic Substances Control Act 

Underground Storage Tanks 

Federal Rivers and Harbors Act 

Total 

910,000 

3,037,368 

0 

%1.088.484.880 

20 GAO/HEHS-94-11OR Federal Mandates 
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