TABLE 3


ANALYSIS AND COMMENTS ON CONSUMER PROVISIONS OF H.R. 2500 (RESPONSIBLE BORROWER PROTECTION ACT)
AND H.R. 3150 (BANKRUPTCY REFORM ACT OF 1998)
NEEDS-BASED BANKRUPTCY
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
101
101 		101(10A)
101
101
101
101
102
102
101
101
101
101
102
102
101
101 		704(10)
1302(b)
IMPACT ON COURT
It is unclear whether the Court is expected to review the report of the trustee as to whether the debtor qualifies for Chapter 7. If so, this will put a substantial burden on the Court. Many bankruptcy judges have up to 6,000 cases filed before them each year. This would require the judge to review 20+ reports per day. The judge would then have to decide whether to set a motion to dismiss on each case. Depending on the nature of the review, the Court could be required to spend one or more hours per day in this process.
It is expected that there will be many emergency motions early in the case concerning whether the debtor qualifies to remain under Chapter 7. These will require hearings—many of which will involve testimony and other evidence—which will be quite time-consuming for the Court. Further, there will be many motions to grant extra time to the debtor to file the extensive financial information required at the beginning of the case and annually under Chapter 13.
The determination of “standards” for expenses involves the discretion of the trier of fact. This will involve evidentiary hearings on many cases, substantially increasing the workload of the Court. For example, the Court will have to decide whether it is appropriate to require the debtor to reject an expensive car lease and purchase a less expensive car or allow for the higher lease payments.
COMMENTS ON NEEDS-BASED BANKRUPTCY
The Sample Debtors Summary (Attachment B hereto) demonstrates the actual effect of the proposals under H.R. 2500 and H.R. 3150. Although the sample is not statistically significant, it appears that the complex, time consuming and costly program of needs-based bankruptcy is unnecessary and that the abuses that exist can be largely corrected with a few minor revisions to the bankruptcy code. These are as follows: (1) Amend 707(b) so that the Chapter 7 trustee has standing to bring the motion to dismiss for substantial abuse; (2) Amend 707(b) to define substantial abuse to include a debtor who has the reasonable capacity to repay at least 20% of the debtor's unsecured claims in a Chapter 13 case over three (or five) years; (3) Remove from the automatic stay residential month-to-month tenancies or tenancies at will (already partially included in H.R. 3150 163); and (4) Clarify that judges have discretion to grant prospective and/or in rem relief from stay (already partially included in H.R. 2500 109 and H.R. 3150 121). See the discussion in the Sample Debtors Summary (Attachment B) supporting this recommendation.


















TABLE 4


DISCHARGEABILITY OF DEBTS
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
107
142
145
106
141
104
143
IMPACT ON COURT
The presumption of non-dischargeability for all consumer debt incurred within 90 days before bankruptcy will encourage creditors to bring actions for small amounts of debt, even if the debtor has a good payment record prior to that time.
Making “bad acts” debt non-dischargeable in Chapter 13 will lead to a substantial amount of litigation. Chapter 13 debtors must have a regular source of income and therefore creditors will have the ability to collect on a non-dischargeable judgment. Thus there will be a high percent of unsecured creditors who will file actions to declare their debt non-dischargeable in cases where there is less than 100% payment under the plan. Further, unless creditors are specifically prevented from executing to collect on a non-dischargeable debt until the case is dismissed or discharge is entered, there will be an incentive to file dischargeability litigation even in 100% plan cases so that the creditor will not have to wait 5-7 years to get paid.


















TABLE 5


AUTOMATIC STAY
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
109
121
3. The debtor failed to pay adequate protection as ordered by the Court; or the debtor failed to perform the terms of a plan confirmed by the Court.
109
121
208
124
163 362(b)(10)
IMPACT ON COURT
The requirement that a motion for extension of the stay must be determined within 30 days after the case is filed will increase the workload of the Court, as this will require a hearing on very short notice. Because of the requirement that the debtor overcome the presumptions by clear and convincing evidence, each of these motions will probably require an evidentiary hearing, putting pressure on Courts with overburdened calendars. These hearing will have priority on the Court's calendar because the decision must be made within 30 days after filing of the petition, regardless of when the motion is filed. And pro se debtors can be expected to file their motions well into the 30 days, as they will not be aware of the need to file a motion nor will they have the ability to bring such a motion. This will make it virtually impossible for the judge to control his calendar. This will be particularly problematic in single judge jurisdictions If the judge takes even one week of vacation or is ill for a week, the stay will terminate in cases that might well qualify for its continuance—but there was no judge available to hear these emergency motions.
Because the subsequent filing is presumed to be in bad faith as to any creditor who filed a motion for relief from stay in a prior case (whether the motion was still pending at the time the prior case was dismissed), there will be a real incentive to secured creditors to file a motion for relief from stay in every case, even if the default was minor or very recent. This will increase the workload of the Court and the cost to debtors.
Because the trustee will have very little time to act if the debtor does not reaffirm, assume or redeem personal property, the Court can expect a series of motions by trustee to be heard on shortened time seeking to give the trustee extra time to act.
Terminating the automatic stay as to residential property in which the lease has expired will reduce the number of cases filed to stop eviction and will eliminate motions for relief from stay to complete eviction.||e


















TABLE 6


RESPONSIBILITY OF DEBTOR'S ATTORNEY
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
101
101 		109(h)(4)
411
IMPACT ON COURT
It is likely that more debtors will file pro se as attorneys will be unwilling to submit themselves to the Rule 9011 sanctions. Pro se debtors put a substantial burden on the Court.
There will be more emergency motions to file the statement of extraordinary expenses after the petition or to excuse the failure to file this statement with the petition.||e


















TABLE 7


POST CONFIRMATION AMENDMENT OF PLAN
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
102
102
IMPACT ON COURT
No substantial impact is anticipated.||e


















TABLE 8


LIEN STRIPPING
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
110
128
111
129
112
123
120
130
IMPACT ON COURT
There will be a variety of litigation to clarify these provisions because of the problems noted above.||e


















TABLE 9


TIME FOR CHAPTER 13 PROCESS
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
114
406
204
401		341(a) Section 204 and 401 amends Section 341(a) to delay the first meeting of creditors so that it is not held earlier than 60 days nor later than 90 days after the filing, unless unusual circumstances justify an earlier meeting
213
409
105
125
IMPACT ON COURT
The delay to confirmation will lead to more motions for relief from stay.
H.R. 2500 213 requires the court to give a second notice of the confirmation hearing if any creditor objects to the date. This will be a substantial cost to the court and will lead to calendaring confusion.


















TABLE 10


SUBSTANTIAL ABUSE/SECTION 707 OF THE CODE
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
115
103
211
408 		707(c)
707(d)
521(e)
IMPACT ON COURT
As noted above, there will be many more motions to dismiss for substantial abuse and these will require evidentiary hearings, therefore taking courtroom time. Expanding the motion to allow the chapter 7 trustee to file it would be wise. But opening it to all creditors before we test it by allowing the trustee to file the motion will lead to many motions, thereby clogging the court's calendar without knowing whether there is any commensurate benefit to the system.
It is unclear what is expected of the Court in the five days discussed in H.R. 2500 211 and H.R. 3150 408. If this is merely a ministerial act of the clerk, there will be little impact. If a hearing is required, there will be substantial impact.


















TABLE 11


EXTENDING PERIOD BETWEEN BANKRUPTCY DISCHARGES
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
121
171
IMPACT ON COURT
  No impact.


















TABLE 12


GIVING CREDITORS NOTICE IN CHAPTER 7 AND 13 CASES
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
206
405
IMPACT ON COURT
This section will create substantial litigation in the area of damages for violation of the automatic stay. Debtors will have to prove the internal process of the creditor and will have to find out exactly when notice was received in the proper department. This will create evidentiary hearings. Because there can be substantial damages when the automatic stay is violated, this provision will create much time-consuming litigation.


















TABLE 13


FILING PROOFS OF CLAIM
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
209
403
Further, if there are assets to be distributed, the Trustee will not have a proof of claim to work from and would be limited to the books and records of the debtor (which are often in disarray). It would be very difficult, time-consuming and expensive for the Trustee to audit the debtor's entire business (as this applies to business debtors as well as individual debtors) and to ascertain which claims should be paid. This would greatly increase the administrative expenses, delay distribution, and reduce the percent of payout to unsecured creditors. This is particularly true in the case of business debtors in liquidation, where there is no management to assist the Trustee in unwinding the business history of the debtor.
IMPACT ON COURT
The trustee will be required to object to scheduled claims. At the present time, he need only object to filed claims and he has a statement of creditor showing the basis of the debt. Under this provision, that will be lacking. We can anticipate well over double the number of objections to claims that we now have. This will take additional court and clerk time. Further, if the trustee does not object to all unfiled claims, it may be a breach of duty.


















TABLE 14


FILING TAX RETURNS WITH THE BANKRUPTCY COURT
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
210
407
IMPACT ON COURT
There will be more motions to dismiss for failure of the debtor to file the tax returns after the first year/tax period of the plan. It is unclear who is to monitor compliance.


















TABLE 15


PROTECTION OF LESSORS AND PURCHASE MONEY SECURED CREDITORS
H.R. 2500/H.R. 3150 11 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
212
162
116
161
IMPACT ON COURT
There will be more motions for relief from the stay very early in the case if the debtor fails to begin making payments in a timely fashion.


















TABLE 16


DEBTOR FINANCIAL MANAGEMENT TRAINING
H.R. 2500/H.R. 3150 211 U.S.C.
SECTION 		SUMMARY OF
PROVISIONS 		APPLICATION
COMMENTS 		DRAFTING
COMMENTS 		OTHER
COMMENTS
111-
116


















TABLE 17


ATTACHMENT A
TIMELINE UNDER CURRENT BANKRUPTCY LAW AND AS PROPOSED UNDER H.R. 2500 & H.R. 3150
CURRENT LAW H.R. 2500 & H.R. 3150 PROPOSALS
Order for Relief
(filing date) 		CHAPTER 7 CHAPTER 13 CHAPTER 11 CHAPTER 7 CHAPTER 13 CHAPTER 11
15 days File all schedules and statement of affairs (Rule 1007(c)) File all schedules and statement of affairs (Rule 1007(c));
Debtor must file Chapter 13 plan (Rule 3015(b)) 		File all schedules and statement of affairs (Rule 1007(c)) File all schedules and statement of affairs (Rule 1007(c)) File all schedules and statement of affairs (Rule 1007(c)) File all schedules and statement of affairs (Rule 1007(c))
20 days Earliest day to convene 341(a) meeting (Rule 2003(a)) Earliest day to convene 341(a) meeting (Rule 2003(a)) Earliest day to convene 341(a) meeting (Rule 2003(a))
30 days Last day by which individual debtor must file notice of intention as to consumer property on which there is a secured lien (11 U.S.C. 521(2)(A)) [if the 341(a) meeting is earlier, that is the last day]
40 days Last day to convene the initial 341(a) meeting (Rule 2003(a)) Last day to convene the initial 341(a) meeting (Rule 2003(a))
50 days Last day to convene the initial 341(a) meeting (Rule 2003(a))
60 days Stay terminates as to all property of the estate secured by a lien or leased property if individual debtor did not file a statement of intention (11 U.S.C. 521(2)(A)) [H.R. 2500 208];
75 days
90 days
110 days If a creditor objects within 5 days for receiving notice of the confirmation hearing, and the 341(a) meeting is held on the last possible date, this is the earliest that a confirmation hearing can be held (New 11 U.S.C. 1324) [H.R. 2500 213]
135 days Last day for a confirmation hearing, which must be within 45 days of debtor filing plan (New 11 U.S.C. 1324) [H.R. 2500 114]
Reaffirmation
Agreements

Bold = Trustee involvement.

Rule XX = National Rules of Bankruptcy Procedure.

11 U.S.C. XX = Current Bankruptcy Code section.

New 11 U.S.C. XX = New or amended Bankruptcy Code section proposed by H.R. 2500.

H.R. 2500 XX = Section of H.R. 2500 where proposal can be found.



















TABLE 18


Debtor
Debtor has new job
5
Debtor is unemployed
3
(In these 8 cases, which are 44% of the sample Chapter 7 cases, there will not be a meaningful figure for average income for the 6 months before filing as required by the needs-based bankruptcy proposal) Reasons for Filing
(some cases fall in multiple categories)
Prevent foreclosure
2
Prevent eviction
1
Drop in income
7
Car accident
2
Medical costs
2
Judgment
1
Just too little money for necessities
2
Prior business debt
2
Other
Pro se filer
5
Credit card debt of at least one year's average salary
7
Would be in Chapter 13 under needs-based bankruptcy
4
Have credit card debt of at least one year's average salary
1
CHAPTER 13 CASES
Reasons for Filing
(some cases fall in multiple categories)
Prevent foreclosure
5
Prevent eviction
1
Drop in income
2


















TABLE 19


Debtor Annual Income No. of Credit Cards Credit Card Debt Qualifies for Chapter 7 Under Needs-Based Bankruptcy
1995 1996 1997
  8 46,919 35,000 12,000   8 39,000 Yes
11 44,963 61,257 65,148 11 43,612 No1
13 12,888 14,376 15,864   9 73,111 Yes
14 21,911 21,370   2,507 13 47,300 Yes
15 12,000 16,800   2,500 17 26,001 Yes
16 27,240 27,240 27,240   9 26,765 Yes
17 54,254 57,635 34,700 23 89,472 Yes

1Twenty-four percent payout over 5 years.

















TABLE 20


SUMMARY OF 1997 NATIONAL STANDARDS
Total Gross Monthly Income Number of Persons
One Two Three Four Over Four
Less than $830 336 453 563 704 +125
$831 to $1,249 382 510 627 740 +135
$1,250 to $1,669 421 610 714 776 +145
$1,670 to $2,499 510 662 757 805 +155
$2,500 to $3,329 537 744 835 896 +165
$3,330 to $4,169 600 802 917 1,029 +175
$4,170 to $5,829 746 927 985 1,133 +185
$5,830 and over 958 1,194 1,352 1,424 +195


















TABLE 21


NATIONAL STANDARDS
Less than $830 $831 to $1,249 $1,250 to $1,669 $1,670 to $2,499 $2,500 to $3,329 $3,330 to $4,169 $4,170 to $5,829 $5,830
and over
ONE PERSON
Food 163 191 206 247 260 313 412 439
Housekeeping supplies18 20 21 25 26 28 33 41
Apparel & Services 41 50 72 115 122 124 161 322
Personal Care Products & Services 14 21 22 23 29 35 40 56
Miscellaneous 100 100 100 100 100 100 100 100
Total $336 $382 $421 $510 $537 $600 $746 $958
TWO PERSONS
Food 219 267 337 351 408 421 498 611
Housekeeping supplies22 26 27 38 44 49 55 71
Apparel & Services 68 69 94 116 123 160 195 323
Personal Care Products & Services 19 23 27 32 44 47 56 64
Miscellaneous 125 125 125 125 125 125 125 125
Total $453 $510 $610 $662 $744 $802 $927 $1,194
THREE PERSONS
Food 262 314 375 391 427 469 524 709
Housekeeping supplies23 27 28 39 45 53 56 74
Apparel & Services 106 109 129 138 168 197 198 354
Personal Care Products & Services 22 27 32 39 45 48 57 65
Miscellaneous 150 150 150 150 150 150 150 150
Total $563 $627 $714 $757 $835 $917 $985 $1,352
FOUR PERSONS
Food 360 362 391 400 455 552 605 748
Housekeeping supplies34 35 36 44 47 55 58 75
Apparel & Services 109 140 141 142 172 198 235 355
Personal Care Products & Services 26 28 33 44 47 49 60 71
Miscellaneous 175 175 175 175 175 175 175 175
Total $704 $740 $776 $805 $896 $1,029 $1,133 $1,424
MORE THAN FOUR PERSONS
For each additional person, add to four-person total allowance: $125 $135 $145 $155 $165 $175 $185 $195


















TABLE 22


HOUSING AND UTILITIES ALLOWABLE LIVING EXPENSES FOR CALIFORNIA
County Maximum Allowance
Family of 2
or less 		Family of 3 Family of 4
or more
Alameda County 1,261 1,484 1,706
Alpine County 956 1,124 1,293
Amador County 870 1,023 1,177
Butte County 781 919 1,057
Calaveras County 902 1,061 1,220
Colusa County 669 787 905
Contra Costa County 1,306 1,537 1,767
Del Norte County 714 840 966
El Dorado County 1,086 1,278 1,469
Fresno County 859 1,010 1,162
Glenn County 667 785 903
Humboldt County 739 869 999
Imperial County 765 900 1,035
Inyo County 872 1,026 1,180
Kern County 891 1,049 1,206
Kings County 784 923 1,061
Lake County 836 984 1,132
Lassen County 706 831 955
Los Angeles County 1,202 1,414 1,626
Madera County 842 991 1,140
Marin County 1,540 1,811 2,083
Mariposa County 832 979 1,126
Mendocino County 895 1,053 1,211
Merced County 897 949 1,092
Modoc County 535 629 724
Mono County 1,173 1,379 1,586
Monterey County 1,109 1,305 1,501
Napa County 1,115 1,312 1,509
Nevada County 1,031 1,213 1,395
Orange County 1,379 1,622 1,866
Placer County 1,159 1,364 1,568
Plumas County 773 910 1,046
Riverside County 1,116 1,313 1,510
Scaramento County 977 1,149 1,322
San Benito County 1,241 1,460 1,679
San Bernardino County 1,028 1,209 1,390
San Diego County 1,201 1,413 1,625
San Francisco County 1,248 1,468 1,689
San Joaquin County 948 1,116 1,283
San Luis Obispo County 1,155 1,359 1,563
San Mateo County 1,454 1,710 1,967
Santa Barbara County 1,202 1,414 1,626
Santa Clara County 1,418 1,668 1,918
Santa Cruz County 1,349 1,587 1,825
Shasta County 777 914 1,052
Sierra County 691 813 934
Siskiyou County 637 749 861
Solano County 1,158 1,363 1,567
Sonoma County 1,161 1,366 1,571
Stanislaus County 907 1,067 1,227
Sutter County 816 960 1,104
Tehama County 664 781 899
Trinity County 701 825 948
Tulare County 763 898 1,032
Tuolumne County 905 1,064 1,224
Ventura County 1,367 1,608 1,850
Yolo County 963 1,133 1,302
Yuba County 690 811 933


















TABLE 23


State IRS Region Census Region
Alabama SoutheastSouth
Alaska Western West
Arizona Western West
Arkansas Midstates South
California Western West
Colorado Western West
Connecticut Northeast Northeast
Delaware Southeast South
District of Columbia Southeast South
Florida Southeast South
Georgia Southeast South
Hawaii Western West
Idaho Western West
Illinois Midstates Midwest
Indiana Southeast Midwest
Iowa Midstates Midwest
Kansas Midstates Midwest
Kentucky Southeast South
Louisiana Southeast South
Maine Northeast Northeast
Maryland Southeast South
Massachusetts Northeast Northeast
Michigan Northeast Midwest
Minnesota Midstates Midwest
Mississippi Southeast South
Missouri Midstates Midwest
Montana Western West
Nebraska Midstates Midwest
Nevada Western West
New Hampshire Northeast Northeast
New Jersey Northeast Northeast
New Mexico Western West
New York Northeast Northeast
North Carolina Southeast South
North Dakota Midstates Midwest
Ohio Northeast Midwest
Oklahoma Midstates South
Oregon Western West
Pennsylvania Northeast Northeast
Rhode Island Northeast Northeast
South Carolina Southeast South
South Dakota Midstates Midwest
Tennessee Southeast South
Texas Midstates South
Utah Western West
Vermont Northeast Northeast
Virginia Southeast South
Washington Western West
West Virginia Southeast South
Wisconsin Midstates Midwest
Wyoming Western West


















TABLE 24


MSA DEFINITIONS BY CENSUS REGION
NORTHEAST CENSUS REGION


















TABLE 25


MSA State Counties
New York NY Bronx, Dutchess, Kings, Nassau, New York, Orange, Putnam, Queens, Richmond, Rockland, Suffolk, Westchester
NJ Bergen, Essex, Hudson, Huterdon, Mercer, Middlesex, Monmouth, Morris, Ocean, Passaic, Somerset, Sussex, Union, Warren
CT Fairfield, Litchfield, Middlesex, New Haven
Philadelphia PA Bucks, Chester, Delaware, Montgomery, Philadelphia
NJ Atlantic, Burlington, Camden, Cape May, Cumberland, Gloucester, Salem
DE New Castle
MD Cecil
Boston MA Bristol, Essex, Hampden, Middlesex, Norfolk, Plymouth, Suffolk, Worcester
NH Hillsborough, Merrimack, Rockingham, Strafford
CT Windham
ME York
Pittsburgh PA Allegheny, Beaver, Butler, Fayette, Washington, Westmoreland
Buffalo NY Erie, Niagara
EVERYWHERE ELSE IN THE NORTHEAST CENSUS REGION
MIDWEST CENSUS REGION


















TABLE 26


MSA State Counties
Chicago IL Cook, DeKalb, DuPage, Grundy, Kane, Kanakakee, Kendall, Lake, McHenry, Will
IN Lake, Porter
WI Kenosha
Detroit MI Genesee, Lapeer, Lenawee, Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, Wayne
Milwaukee WI Milwaukee, Ozaukee, Washington, Waukesha
Minneapolis MN Anoka, Carver, Chisago, Dakota, Hennepin, Isanti, Ramsey, Scott, Sherburne, Washington, Wright
WI Pierce, St. Croix
Cleveland OH Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, Summit
Cincinnati OH Brown, Butler, Clermont, Hamilton, Warren
KY Boone, Campbell, Gallatin, Grant, Kenton, Pendleton
IN Dearborne, Ohio
St. Louis MO Franklin, Jefferson, Lincoln, St. Charles, St. Louis, Warren, St. Louis city
IL Clinton, Jersey, Madison, Monroe, St. Clair
Kansas City MO Cass, Clay, Clinton, Jackson, Lafayette, Platte, Ray
KS Johnson, Leavenworth, Miami, Wyandotte
EVERYWHERE ELSE IN THE MIDWEST CENSUS REGION
SOUTH CENSUS REGION


















TABLE 27


MSA State Counties
Washington, DC MD & DC Calvert, Charles, Frederick, Montgomery, Prince George's, District of Columbia
VA Arlington, Clarke, Culpepper, Fairfax, Fauquier, King George, Loudoun, Prince William, Spotsylvania, Stafford, Warren, Alexandria city, Fairfax city, Manassas city, Manassas Park city
WV Berkeley, Jefferson
Baltimore MD Anne Arundel, Baltimore, Carroll, Harford, Howard, Queen
Atlanta GA Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Pickens, Rockdale, Spalding, Walton
Miami FL Broward, Dade
Dallas-Ft. Worth TX Collin, Dallas, Denton, Ellis, Henderson, Hood, Hunt, Johnson, Kaufman, Parker, Rockwall, Tarrant
Houston TX Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery, Waller
EVERYWHERE ELSE IN THE SOUTH CENSUS REGION
WEST CENSUS REGION


















TABLE 28


MSA State Counties
Los Angeles CA Los Angeles
San Francisco CA Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, Santa Cruz, Colano, Sonoma
San Diego CA San Diego
Portland OR Clackamas, Columbia, Marion, Multnomah, Polk, Washington, Yamhill
WA Clark
Seattle WA Island, King, Kitsap, Pierce, Snohomish, Thurston
Honolulu HI Honolulu
Anchorage AK Anchorage borough
EVERYWHERE ELSE IN THE WEST CENSUS REGION


















TABLE 29


ALLOWABLE TRANSPORTATION EXPENSES1
Ownership Costs
First Car Second Car
National $335 $269


















TABLE 30


OPERATING COSTS & PUBLIC TRANSPORTATION COSTS
No Car One Car Two Cars
Northeast Region $198 $250 $303
New York 258 311 364
Philadelphia 206 259 312
Boston 214 267 320
Pittsburgh 142 195 248
Buffalo 126 179 232
Midwest Region 170 222 275
Chicago 224 277 330
Detroit 270 323 376
Milwaukee 188 241 294
Minneapolis-St. Paul 237 290 343
Cleveland 173 226 279
Cincinnati 197 250 303
St. Louis 176 229 282
Kansas City 215 268 321
South Region 174 227 279
Washington, D.C. 251 304 357
Baltimore 196 249 302
Atlanta 252 305 358
Miami 244 297 350
Dallas-Ft. Worth 273 326 379
Houston 245 298 351
West Region 212 264 317
Los Angeles 235 288 341
San Francisco 267 320 373
San Diego 255 308 361
Portland 166 219 272
Seattle 221 274 327
Honolulu 269 322 375
Anchorage 271 324 377

1Does not include personal property taxes.