THE DEPARTMENT OF TRANSPORTATION is 20 years old this month. Alan Boyd, the first secretary of transportation, viewed DOT as primarily a policy-making agency, with him reigning, so to speak, but not ruling over its constituent agencies, such as the Federal Aviation Administration.

Under President Reagan, DOT has developed into an operating agency, with its various constituent agencies totally subservient, not only to the secretary of transportation's policies but also to operating oversight by the DOT secretary's staff. That has caused a considerable amount of unrest among the operating agencies, but so far no major revolts - though the FAA administrator did protest strongly when he was ordered to make changes in one of his top field offices.Apparently Congress is not too dissatisfied with the way DOT is being operated, for the present secretary, Elizabeth Hanford Dole, is always treated with great care by the power brokers on Capitol Hill. Of course, having the Senate majority leader for a husband hasn't hurt Mrs. Dole in her relationship with the Senate at all.

The relationship with House leaders is not so cozy. Rep. Norman Mineta, D- Calif., chairman of the House Aviation Subcommittee, has repeatedly criticized the way the FAA has been starved for funds, particularly in its massive effort to upgrade the level of air safety deemed acceptable by DOT.

Despite DOT's prodding, FAA is behind in its program to carry out the multi-billion dollar National Aerospace Plan, intended to replace old vacuum- tube radio equipment and obsolete air traffic control computers with state- of-the-art equipment. FAA is also behind schedule in replacing all the controllers who were fired in 1981 when they walked off their jobs in an ill- advised strike.

Congress, tired of soothing promises, actually went so far as to pass a law in the closing hours of the past session that requires FAA to have on duty 15,000 air traffic controllers by next Sept. 30. At least 70 percent of them will have to be fully qualified, not trainees or clerks.

FAA, which has 14,803 controllers on duty, says only 9,528 are fully

qualified. The agency anticipates no trouble in meeting the requirement laid down by Congress - even if the training of some must be speeded up to meet the fully qualified criteria.

Underlying Secretary Dole's success in sweet-talking Congress is a determination to get on with the air safety job, come Gramm-Rudman or high water. That has resulted in considerable progress being made in several of her key programs, even though she has not been able to achieve the total success she has aimed for.

Her handling of D.C. airports legislation is a good example of her determination. Given up for lost several times even by its most ardent supporters, the effort to transfer Washington National and Dulles International out of the hands of the FAA and into the more responsive control of a regional airports authority was finally achieved in a last-minute compromise among a dozen or more conflicting interests.

They included the Maryland congressional delegation, which was fearful that its own Baltimore-Washington airport would be hurt (more money will be made available for BWI, said Mrs. Dole) and those congressmen who worried that sale of the airports would be little more than a massive giveaway (forget about sale, we'll just lease the airports, said the secretary). By such astute bargaining, the secretary was able to achieve an airport divestiture that no other secretary had (though they all had tried).

Even Secretary Dole's apparent failure to get congressional approval of the sale of Conrail to Norfolk Southern Corp. was really not a defeat for her divestiture policy. Mrs. Dole might have been able to carry out her plan to sell Conrail to Norfolk Southern if NS had not been overconfident. Assuming that they had Conrail in the bag, NS was unwilling to compromise and thus lost the deal.

Mrs. Dole is facing a dilemma. She says her only political ambition is to help her husband win re-election as senator from Kansas. That's also the senator's public stance at the moment, despite the fact that many see him as a presidential candidate in 1988. But there also is talk of her being offered the vice presidential spot on a Bush-Dole ticket. North Carolina might even claim her as a favorite daughter in the presidential race itself.

Just how good a job has Elizabeth Dole done as secretary of transportation? There is no clear answer. There are those who are critical of her (and we might be among them) and those who think favorably of her. But without a doubt, she has clout on Capitol Hill, and that makes her a formidable political force.

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