McMahon resigned as Liberal leader a few weeks after the 1972 election. Gorton was one of five candidates who stood the resulting leadership ballot, but polled only the fourth-highest total as Billy Snedden won a narrow victory over Nigel Bowen. Snedden subsequently appointed him to the opposition frontbench as spokesman for urban and regional development, the environment, and conservation. Soon after being sworn in as prime minister, Whitlam responded to a congratulatory letter from Gorton by promising to "advance some of the causes which you were the first Australian Prime Minister to identify". Over the following years, several failed initiatives from Gorton's prime ministership were passed into law by the Whitlam Government. This included the establishment of the Australian Film, Television and Radio School and the assertion of sovereignty over the territorial seabed and continental shelf.