Were Congress to utilize the Joint Resolution as an instrument for approving or disapproving administrative action, no innovation would be involved. The Joint Resolution requires presidential signature to become effective. This legislative instrument traditionally has been relied upon to clarify congressional intent in delegatory statutes which it thought had been misinterpreted by administrative agencies or the courts. However, if in delegating powers to the executive, Congress conditioned the grant by reserving power to itself by concurrent resolution or by simple resolution of one house to define the terms under which the executive was to act and to review, approve or disapprove such administrative action, a signal departure from established practice would be recorded. In effect, the Congress would have retained the power to curb administration through legislative procedures which do not require Presidential signature to be effective, and which traditionally do not have the force of law, serving simply to express the intent of the Congress.[613] While the Constitution provides that “every order, resolution, or vote to which the concurrence of the Senate and House of Representatives may be necessary ... shall be presented to the President ... and before (they) take effect shall be approved by him,” concurrent resolutions have not for over a century and a quarter been submitted for presidential approval.[614] Apparently the earliest use of the concurrent resolution as a device for enhancing the ability of Congress to control administrative action is to be found in the Reorganization Act of 1932, followed by the Reorganization Act of 1939.[615] These statutes empowered the President to submit reorganization plans to Congress, the plans to have legal effect unless disapproved by concurrent resolution adopted within a prescribed period. Within the past two decades all three instruments--the joint resolution, the concurrent resolution, and the simple resolution passed by one house--have been used by Congress in an attempt to retain influence and control over the administration of emergency programs. Whether for good or for bad, in statutes delegating emergency authority the present trend is pointed toward inclusion of congressional power to review administrative action by concurrent resolution. DELEGATORY LEGISLATION INCORPORATING POWER TO CHECK BY CONCURRENT RESOLUTION