over, NAHRO believe that the arrangement suggested under section 404, with the housing authority leasing the housing directly from the landlord, provides assurance that the housing will remain available. and that it will be kept in proper condition, and we recommend that this same method of leasing be incorporated in section 101 (c) (2).

The local renewal agency should be given the option of contracting with the local housing authority to administer this 101 (c) (2) assist

ance program.

On page 23, I discuss section 102, which provides for rehabilitation assistance to elderly homeowners in urban renewal areas.

The new provisions for rehabilitation assistance to elderly homeowners should also be made available under the same set of conditions to all other homeowner families of low- and moderate-income who are similarly situated. This would avoid displacement by urban renewal when their homes can be improved within the framework of the urban renewal plan.

There are also many other homeowners who need even more financial assistance than that provided by the below-market interest rate formula. These include families with exceedingly low incomes, the handicapped and those with overmortgaged homes. Flexibility of financing methods is necessary to accommodate varying needs.

We recommend that this section be expanded to provide for loans at lower subsidized interest rates or no-interest loans, if necessary, for such families. We also recommend loans for all or part of the cost of rehabilitation of properties, under conditions providing for repayment on the death of the owner or upon transfer of title. We consider these legitimate costs of carrying out the renewal activities where properties lend themselves to upgrading and retention.

Section 301, dealing with a loan contract for two or more projects, I discuss on page 24.

We favor the enactment of this permissive provision. It permits cities with several projects to execute a single temporary loan contract, and under proper safeguards, to use funds on hand for one project for the purpose of meeting expenditures incurred by another.

This proposal recognizes an important principle: that the urban renewal activities in a city may be consolidated for certain purposes. The application of this principle provides a flexibility which should be extended to other aspects of the program wherever feasible.

Section 302, dealing with general neighborhood renewal plan, is discussed on page 24.

We favor the proposals to allow more realistic time periods for the completion of projects initiated under general neighborhood renewal plans and to permit the inclusion, for planning purposes, of areas not eligible for treatment as projects.

However, the general neighborhood renewal plan is not flexible enough for the proper treatment of all large areas, especially central business districts. We support, for this purpose, the approach proposed in the bill introduced by Senator Clark (sec. 102 of S. 2031) and Congressman Rains (H.R. 6431).

I would like to discuss the comprehensive renewal of central business districts, and you will find that on page 24.

We earlier expressed our regret that the administration bill did not provide an adequate vehicle and funds for assisting cities to undertake

a comprehensive approach to the elimination of blight and the revitalization of their central business districts.

Special legislation such as Senator Clark's bill, S. 2031, is needed since the eligibility and percentage of credit for local noncash grantsin-aid historically have been based on residential criteria. This bill would permit a comprehensive approach to removing blight in downtown areas and would also allow cities to receive proper credits for public facilities necessary to accomplish revitalization of their central business districts. We recommend the adoption of this bill and the provision of adequate grant funds to accomplish its purposes.

On the question of capital grant authorization, discussed on page 25, we have examined the rate of receipt of applications and approval of projects by the Urban Renewal Administration. Against an actual approval rate of $800 million a year, with a backlog of $400 million, and an increasing number of cities entering the program, the Administration proposes $1.4 billion for 2 years, or $700 million a year. It should be recognized that out of this $1.4 billion, there will be expenditures of $141 million for additional relocation payments (sec. 101) and $5 million for demonstration grants (sec. 309). This would leave $1.254 million for 2 years, or only $627 million a year.

This is not a sufficient amount to maintain even the current level of activity, to say nothing of the amounts needed to meet the rate of growth described by the Administrator in his testimony. We recommend a minimum authorization of $5 billion without limitation for any one year.

On page 27 I discuss section 604-advances for public works planning.

Under the program for public works planning administered by the Community Facilities Administration, advances are made for planning single public facilities such as a fire station or a sewage treatment plant. However, funds may not be provided for planning complexes— educational, medical, scientific, research-or a combination of such facilities. Long-range planning is necessary for the proper development of such facilities, the construction of which may take from 10 to 15 years to complete.

We recommend that the Community Facilities Administration be authorized to make advances for the planning of facility complexes of that kind.

Now I would like to discuss a very serious subject, although everything I have discussed is exceedingly serious. On pages 28 and 30 I discussed codes enforcement and a new approach by the Federal Government. I now turn to the subject of local code enforcement. As we all know, this is an essential element of community development. Without it, no city can do a complete job in housing and renewal. This was recognized in the "workable program for community improvement," which a community must have certified to be eligible for Federal financial assistance for housing and urban renewal. Planning, relocation, and community organization are other elements of the "workable program." Despite the fact that they are local responsibilities, they are eligible for some form of Federal financial assistance, which code enforcement is not. It is a stepchild.

In addition, the urban planning assistance program (sec. 701) has already committed about $75 million for local planning; and, reloca

tion assistance is provided through several Federal programs, including urban renewal and the Federal highway program. Community organization activities under urban renewal are eligible for inclusion in the gross project costs of urban renewal projects. We believe code enforcement merits the same consideration as is given to these other local responsibilities. It should also be recognized that, as a result of federally aided community development programs, greater demands are being made on local code enforcement agencies. These agencies are being called upon to inspect and certify urban renewal relocation housing. Moreover, cities are now asked to do special types of code enforcement, such as area wide enforcement in neighborhood improvement areas, in line with the city's overall urban renewal objectives.

All this calls for new approaches to local code enforcement that most cities are not equipped to undertaken.

We believe that effective enforcement of housing and related codes requires more money and manpower than most cities are now able to afford. The time has come when code enforcement activities-carried out as part of a city's broad renewal objectives, but not limited to official renewal projects-must be made eligible for Federal assistance. We therefore recommend that provisions for Federal assistance for local code enforcement be included in the title III of this bill. We are not asking the Federal Government to pay for routine code enforcement. I would like to make that doubly clear. We are asking that assistance be provided to help local governments establish an effective administrative system for enforcing housing and related codes in a meaningful way. In addition, we ask that special code enforcement activities those closely related to renewal and rehabilitation, under title I-be made eligible for urban renewal assistance.

The details of these two specific recommendations are contained in our full statement, and are taken from our "1963-65 Policy Resolution." I request that the full text of this policy resolution be entered in the record.

(The material referred to follows:)

POLICY RESOLUTION, 1963-65, OF THE NATIONAL ASSOCIATION OF HOUSING AND REDEVELOPMENT OFFICIALS

Adopted at business meeting of members during 1963 national biennial
conference, Denver, Colo., October 2, 1963

PREAMBLE

As the National Association of Housing and Redevelopment Officials meets in 1963, it completes 30 years of service to the public officials and civic leaders who work toward the elimination of urban slums and blight.

We find, at this point in association history, that the massive and rapid growth of urban areas everywhere has made physical decay and obsolescence continuing facts of life. It is forcing changes in traditional methods of government operation; in patterns of social life; in the balance of economic forces. It is creating an unprecedented need for coordinated action by a myriad of different public and private interests.

To cope with this need, it is recognized that housing, urban renewal, and codes officials must find a means of more closely relating their operations to the work of the other public and private agencies that are concerned with such deeply imbedded urban problems as poverty, unemployment, lack of education, poor health, family disruption. There must be a total community effort to meet these 20th-century problems. It is foreseen that this total effort can have a

highly stimulating influence on the national economy, helping it to reach its full potential, while at the same time injecting a new vitality into American life. The aspirations of all persons for full achievement of their rights as American citizens should be recognized in the programing and execution of housing, renewal, and codes enforcement programs. Against this background, the association has evaluated the trends that have been developing since its 1961 national conference, and identifies five major areas that warrant priority attention at this time. These trends have evolved out of programs that are at differing levels of maturity. The association, therefore, has had differing levels of experience from which to draw in recommending new ways to meet the objectives set in this 1963 policy resolution.

The priority areas for action during 1963-65 are seen as :

Priority area No. 1.-Recognition of codes enforcement programs as equal partners with housing and renewal in community development.

Priority area No. 2.-Examination of the changing process of urban renewal and a redefinition of its role in total community development.

Priority area No. 3.-Recasting of all publicly assisted housing programs, including the establishment of a fully effective, full-scale program for meeting the housing needs of low-income families.

Priority area No. 4.-Recognition of the need to bring human relations understanding and skills into the community development job, as a means of establishing an environment in which all persons can enjoy the opportunities and exercise the attendant responsibilities of American life.

Priority area No. 5.-Recognition of the need for effective organization of government at the municipal, county, State, and Federal levels to achieve the overall objectives of the community development program.

PRIORITY AREA NO. 1-RECOGNITION OF CODES ENFORCEMENT AS AN EQUAL PARTNER WITH HOUSING AND RENEWAL IN COMMUNITY DEVELOPMENT

Through the Housing Act of 1949, the Nation is committed to a policy of assuring a decent home and a suitable living environment for every American family. To achieve this goal, maximum use must be made of the existing housing supply. To do so and to protect current investments in renewal and housing programs every community must administer a fully effective codes enforcement program. The history of local codes administration, however, reflects the serious budgetary problems facing local government. The result has been that many local governments have done little beyond mere adoption of codes. Yet, the end product in codes administration is compliance and, to achieve compliance, the municipality must develop an effective enforcement procedure. Therefore, financial assistance for this essential component of community development is imperative. For this reason, it is recommended that:

1. To assist local governments in developing efficient organizational structures and procedures for the administration of local codes enforcement programs, Federal grants should be provided for planning, training, and administration, including field inspections.

2. The cost of code enforcement programs, in or adjacent to urban renewal project areas, should be made eligible for inclusion in the gross project costs of title I projects, and grants should be provided for intensive area code enforcement projects.

3. There should be a direct-loan program under the Federal Housing Administration to assist howeowners who otherwise cannot afford to make the repairs required to comply with local codes; flexible rates of interest should be authorized, based on owner's ability to pay.

4. Federal grants should include relocation costs and payments for families displaced by code enforcement on the same basis as for title I clearance projects. NAHRO urges local, State, and Federal officials to give greater recognition to local codes enforcement programs, and include codes officials in the planning of community development programs.

NAHRO urges that Federal, State, and local public agencies follow a policy of complying with local codes when undertaking construction projects-in the same way that private interests are obliged to comply with local regulations. NAHRO reaffirms that its concern with municipal code programs is, first, to promote effective and efficient administration of all local codes and, second, to relate the enforcement of these codes to the larger goals of community development. NAHRO recognizes that other national organizations fulfill the im

portant role of developing local codes standards, and model codes ordinances, and offers to assist and cooperate with these organizations in pursuit of effective and comprehensive local codes administration.

PRIORITY AREA NO. 2-EXAMINATION OF THE CHANGING PROCESS OF URBAN RENEWAL AND A REDEFINITION OF ITS ROLE IN TOTAL COMMUNITY DEVELOPMENT The scope and concept of urban renewal are undergoing significant change. What was initiated as a program of slum clearance and redevelopment is evolving into a broad new process aimed at total community development. Important elements of this new process are mass transit programing, open-space preservation, and the attempt to give direction to urban growth.

The decade immediately following the passage of the Housing Act of 1949 was devoted to working out effective techniques for clearing and redeveloping the most serious blighted areas of American cities. The Housing Act of 1954 added a new dimension: neighbhorhood conservation and rehabilitation. Authorization of the general neighborhood renewal plan (GNRP) in 1956, and the community renewal program (CRP) in 1959, marked the transition of renewal from a project-by-project approach to a broader, more flexible process, concerned with total development in the community and the metropolitan area.

With the changing scope of the urban renewal program in mind, NAHRO adopts four objectives, for the next 2 years;

1. Measurement and evaluation of the experience and achievements under the clearance and redevelopment concept.-The major share of urban renewal progress to date has been through clearance and redevelopment projects. Experience and accomplishments under this concept should be studied in depth, so that nationwide achievements can be measured and evaluated. An effort should be made to determine the economic and social effects of these projects on adjoining areas; on the community as a whole; and, especially, on the families, individuals, and businesses displaced by them.

2. Review of programs of neighborhood conservation, with the aim of identifying procedures that can be effectively used in all cities for large-scale programs.—Passage of legislation in 1954 authorizing Federal grants for rehabilitation and neighborhood conservation has resulted primarily in experimental and demonstration programs. These programs are making important contributions toward the achievement of neighborhood conservation objectives. The recent commitment of the administration to mobilize the resources of its agencies to achieve neighborhood conservation on a large scale is also a commendable step. New minimum property standards issued by the Federal Housing Administration and the Urban Renewal Administration, and the countrywide series of URA-FHA meetings to promote local interest in the neighborhood conservation program are important moves toward the same objectives.

At the local level, communities must dedicate themselves to the achievement of neighborhood conservation and structural rehabilitation programs on a scale commensurate with the Nation's needs. The neighborhood conservation and structural rehabilitation programs underway today are simply prototypes of what must become a new large-scale national effort. As they continue they should be studied in detail to determine what constitutes the best operating techniques, staffing standards, financing methods, and sources of citizen help including local political support-necessary to do the job. The study should consider the slum-prevention aspects of local programs, as well their effectiveness in bringing improvement to deteriorating areas.

3. Examination of urban renewal approaches and techniques necessary to accommodate metropolitan growth and development.-The new urban renewal dimension-manifest in such programs as industrial and commercial development, the communitywide planning techniques of the GNRP and the CRP, and the inclusion of open space and mass-transit considerations in renewal planningmakes a project-by-project approach obsolete. Such a project orientation no longer provides the flexibility or comprehensive framework necessary to cope with the dynamic forces of change affecting urban and metropolitan areas. Over the next few years, new insights must be applied in developing effective techniques for guiding urban growth. In this period of experimentation and demonstration, the Housing and Home Finance Agency should extend every effort to provide flexibility in administering its existing assistance programs in order to ease the transition into a broader renewal process. All communities should undertake renewal in the total sense, in order to achieve their full potential for development and growth.