served as an unending opportunity for experimentation with new designs, materials, physical arrangements, and social patterns.

To resolve the dilemma between the need to allocate new funds and attention to existing programs and the need for creative new approaches to those dimensions of the urban problem which existing problems are not capable of solving, we recommend the establishment of a standing joint congressional Committee on Urban Priorities, This committee would have as its sole purpose the allocation of all competing claims for housing and public works, of all resources available for urban development and redevelopment, including specifically new communities and, most importantly, highways.

S. 3640 has several other dimensions on which we would like to offer our comments. Assistance toward the strengthening of small cities in predominantly rural areas is a welcome recognition of an important fact-namely, that there exist better means for reabsorbing people released from the farms into the Nation's economic mainstream than to pack them off to rot in alien urban slums.

But in considering such programs, it is important, though, that the committee bear in mind it is dealing with a closed system and that to tamper with its individual components is fraught with danger. In our view, the nationwide equalization of welfare benefits or the enactment of an adequate and uniform national income maintenance program is an essential prerequisite if the rural area stabilization program is to have the remotest chance of success in realizing its main purpose.

If the enactment of S. 3640 will fail to stem the migration of the displaced rural populations to the older urban areas in the Northwest, Midwest and West, all that it may succeed in achieving is the migration of much of the economic base of such areas into regions which have climatically advantaged even though still predominantly rural. It is, therefore, essential that the Senate approve the family assistance plan bill which has already passed the House. If that bill fails of passage, we believe that the rural stabilization program contained in the Urban Growth and New Communities Development Act may well

misfire.

We would like to also bring to your attention a related area in which you could do much to reduce the disadvantages under which older cities flooded by rural migrants now find themselves vis a vis their suburban and rural competitors. S. 3640 makes it very clear that the urbanization of the Nation's surplus rural population is a matter of national rather than local concern. As such, it seems to us that the local costs of coping with the problems which this process creates should be underwritten by the Federal Treasury. This is already being partly done through Federal financial participation in the welfare program. In the area of housing, we strongly urge that your committee give consideration to increasing payments in lieu of taxes in public housing to the level which the projects would pay if they were built and owned by private enterprise. We also urge that the Federal Government reimburse the locality to the full extent of any tax abatement required to enable any federally or even State or locally assisted housing projects to achieve rents within the means of low- or moderate-income families. We are sure that the members of this committee are fully aware that the need for local tax abatement

subsidies in governmentally assisted housing is one of the most powerful deterrents to its introduction into communities outside the limits of central cities, and frequently into the central cities as well.

Title III of S. 3640 would expand eligibility of areas for urban renewal treatment and write-down subsidies in ways which would be most beneficial. We urge its enactment in the form of perfecting amendments to the relevant existing sections of title I of the Housing Act of 1949, as amended. We fail to see any need for limitations and constraints on Federal assistance for such things as swamp reclamation or the proper or productive utilization of "unused, underused, or inappropriately used" land in hard-pressed, decaying cities in the manner proposed in S. 3640. Such provisions perpetuate the unfortunate current urban renewal requirement to the effect that each renewal project and I emphasize the word "renewal"-must contribute to the realization of national housing goals. In many instances, housing goals can be better realized or suitable vacant land outside the renewal areas. Such housing can be earmarked primarily for families displaced by the public action, thus permitting localities to use land freed of slums for other essential purposes. This committee could make an important contribution to the workability of the urban renewal program by making it clear that it expects each continuing housing and renewal program in each community rather than each separate renewal project to contribute to the realization of national housing goals. The chronic, evergrowing shortage of urban renewal funds, also presents a major problem. Hopefully the Senate-House Conference Committee will fund the full $1.7 billion approved by the Senate.

In any event, it is clear that we must search for new ways to assist the rebuilding of cities. We would, therefore, urge that this committee jointly with the Senate Roads Subcommittee explore the availability of post-Interstate System Highway Trust Fund to supplement the funds available for urban renewal.

Only the other day, Senator Jennings Randolph, the chairman of the Senate Roads Subcommittee, was quoted as having been convinced "that highway planning can no longer be carried forward without considering its relationship to other factors in the development of communities." He is also said to have expressed the desire to "reassert the concept of highways as a means by which other, broader public objectives can be achieved." We respectfully submit that the renewal of cities is the broadest possible objective. Besides, a huge majority of all motorists clock a lot of highway mileage on choked city streets. It seems to us, therefore, that there is every reason why new streets and street improvements, parking garages and other highway-related objectives, undertaken as part of urban renewal projects in cities, should qualify for financing out of the Highway Trust Fund.

As an alternate approach, it might be desirable to return to the locales a portion of the trust fund equal to their share of the total number of owners of registered vehicles to be used strictly for highway and other approved transportation-related purposes.

This concludes my statement, Mr. Chairman. I would be glad to answer any questions.

The CHAIRMAN. Thank you very much, Mr. Raymond. You give us a lot in there to think about. And I appreciate all of your suggestions. You say:

We also fail to see any need for limitations and constraints on Federal assistance for such things as swamp reclamation or the proper or productive utilization of "unused, underused, or inappropriately used" land in hard-pressed, decaying cities in the manner proposed in Section 141 (c) of S. 3640.

Just why do you object to that?

Mr. RAYMOND. I do not have a copy of the bill with me here, Senator. My recollection is that that is related again directly to production of housing. In other words, these kinds of assistance, forms of assistance, are available for the creation of land for housing.

Now, there are many swamps that could be reclaimed, assuming that the ecologists have no objection, for industrial purposes and other purposes which the cities need to develop that kind of land for. And it seems to us, that to artificially force housing on every single piece of land assisted with Federal funds, in spite of the fact that other land may be available for the production of housing which could be produced as part of the same overall program, would be narrowing the usefulness and utilities of the Federal assistance program.

The CHAIRMAN. I must confess that I do not find wording or reason in the bill itself to agree with your suggestion there. I think the thing that is intended there is something that is desirable because it recognizes the problem that we all know to exist-that is, the difficulty of getting land on which to carry on improvements of any kind. In other words, a scarcity of land. And it seems to me that this gives us enough to use. I mean, it seems to me that the bill gives us opportunities.

Anyhow, we appreciate your suggestion on it, and we will certainly check it very carefully.

Mr. RAYMOND. Mr. Chairman, I will check it myself. And I will either retract or explain further in a letter.

The CHAIRMAN. Fine. Thank you very much.

Mr. RAYMOND. Thank you, sir.

(The complete statement and the letter Mr. Raymond promised follow :)

STATEMENT OF GEORGE M. RAYMOND, CHAIRMAN, COMMITTEE ON HOUSING AND URBAN DEVELOPMENT, AMERICAN SOCIETY OF CONSULTING PLANNERS Mr. Chairman, I want to express the appreciation of the American Society of Consulting Planners for the Opportunity afforded us to present our views on pending housing and related legislation. My name is George M. Raymond, President of Raymond, Parish & Pine, Inc., an urban planning and development consulting firm, located in White Plains, New York. I am also a Professor of Planning and Chairman of the Department of City and Regional Planning at Pratt Institute, in Brooklyn, New York. I appear before you as the Chairman of ASOP's Committee on Housing and Urban Development. The American Society of Consulting Planners is the only national organization of urban and regional planners in the private sector. Our members serve several thousand communities in almost every state, as well as counties, regions, and many of the nation's largest private land developers.

First, Mr. Chairman, I want to express our continuing amazement, which is shared by an ever growing number of people in all walks of life throughout the nation, at the enormous and seemingly growing disparity between the amount of legislation presented to, and enacted by, Congress and our ability to produce that which this legislation is intended to produce-namely, housing for low- and moderate-income families and a better urban and metropolitan environment. Perhaps the most eloquent proof of the crisis in which we now find ourselves is the squatter movement in New York City. The late Charles Abrams, in his book on "Man's Struggle for Shelter in an Urbanizing World," described the breakdown of authority which usually accompanies the proliferation of illegal

property seizures in the underdeveloped world. Surely, Congress will want to do something before New York City becomes the Calcutta of the Western Hemisphere!

It is now finally clear beyond any need for more research and more documentation that to build houses we need more than good intentions embodied in housing bills, and to save America's cities from the total decay which threatens them we need more than complex bureaucratic structures administering complex processes, procedures, and formulas. What we obviously need, and what has inexcusably become more and more scarce in the last few years, even as the need kept increasing constantly, is sufficient dollars to enable us to do the job.

I will forgo the unpleasant task of setting forth in detail the extent to which the nation's housing, community facilities, urban renewal, public transportation, open space, and other needs are not now being met. The disparity between even the limited recognition by Congress of the huge dimensions of these problems, as expressed in its authorization of expenditures, and the levels of funding requested by the Administration and actually appropriated is most regrettable. For the record, I wish to state that with regard to the need for a greater level of funding for urban programs, the American Society of Consulting Planners supports the position of such other public interest groups as the National League of Cities, the U.S. Conference of Mayors, the National Housing Conference, and the National Association of Housing and Redevelopment Officials. We feel that it is imperative that the Senate-House Conference Committee on Appropriations accept the higher figures embodied in the Senate Appropriations Bill. If the funding deficiency is not made up, and made up soon, new legislation of the type which you are now considering will make very little difference to the rate at which we are currently descending into chaos and urban anarchy. In fact, new legislation which would set up complicated new programs may simply cause the misdirection, not only of resources, but also of the country's attention and limited urban development managerial capability into activities whose results, based on past experience, may or may not materialize in a significant way in a very dim and distant future.

Even though our primary concern is for more funds, in quantities more realistically related to the dimensions of the problems which cry out for solutions, we fully recognize the validity of perfecting the tools we already have, to optimize the operation of existing programs. Senator Sparkman's Housing and Urban Development Act of 1970, S. 3639, is a landmark attempt to bring about such an improvement. We commend the effort that went into the development of this legislation, as well as its intent. Others who have analyzed it in detail have pointed out, however, that some of its provisions will impose greater burdens on those families of low- and moderate-income which are now living in housing assisted under the various existing programs. In fact, in New York City, one analysis claims that the proposed amendments would raise rents in public housing by as much as $100 per month or more.

We believe that this Committee should definitely support the streamlining of programs, but at the same time make certain that the cost of it will not be borne by those who can least afford it. In fact, if anything, we believe that asking lowincome families to pay even as much as 20 to 25 percent of income for rent is totally inexcusable. If, as claimed by the Bureau of Labor Statistics, the poverty line income for a family of four is $5,500, it is difficult to accept the provisions in the bill under which families under $3,500 would pay 20 percent, and those over $3,500 would pay 25 percent of income for shelter. Families of low-income should be expected to pay not more than 15 percent, and families of moderate-income not more than 20 percent, if their other needs, and especially health and education, are to be even minimally provided for. We emphatically urge that all modifications of existing programs aim to lessen, rather than increase, the present burden of housing costs on low-income families.

The proposed elimination of fixed statutory housing cost limits is a welcome realization of their long-standing interference with the localities' ability to produce adequate housing-and, in some instances, any housing at all. The proposed legislation would substitute for it an approach which would recognize the widespread land and construction cost differentials in various parts of the country. Yet, the proposal would still establish a formula approach which, conceivably, and especially in the largest cities such as New York or Chicago, could prevent local housing authorities or private builders of assisted housing from serving the needs of low- and moderate-income families. We recommend, therefore, that the law contain a provision authorizing the Secretary of HUD, if he finds it

necessary in order to allow housing construction to proceed to vary the formula sufficiently to make sure that building can take place.

We wish to also point out that construction cost inits can come about indirectly through the statutory imposition of income limits for admission into various types of housing. If housing under a certain program cannot be built to rent at a level which families within such statutory income limits can afford, no liberalization of construction costs will make it possible for a private builder to produce it. The immediate temptation is to request that income limits be determined on the basis of the rents which an assisted project must charge, given the particular subsidy formula under which it is built. But to do so would simply move the resulting housing farther and farther beyond the reach of the families wihch need it most. Based on the experience record of federal housing programs over 35 years, it must by now be clear that there is only way in which suitable housing, on the one hand, and low- and moderate-income families who need it, on the other, can be brought together; and that is by aiming the programs directly at the families to be served. Land and construction costs are what they are. area by area. Given their lack of responsiveness to housing needs and federal housing policies, there seems to be little choice but to peg subsidies to n level which would enable the families for whom the housing is intended to take advantage of it. If necessary, the subsidy formula should be broadened to include the possibility of a negative interest rate.

While looking into ways of simplifying housing programs, we also urge that you give serious consideration to the possibility of establishing a single forlorni bonsing subsidy pool, to be apportioned to families displaced by painike weJUN and needing bensing assistance to the extent of the disparity between 4* incomes and the bonsing cost which they must mest. All other VIJE SAM to always produce gaps" between programs either due to spavalau xyft sta for all the programs needed to take care datubenait de prova di sanga whose incomes straddle the limits extatükbed for the venarnih yg ISI reason of the growing digarity between seru u 20 na 29 by Ts* programs to prodore boosing it the meninad jana of kanag gevaar has particularly bederiet emme vi fut e 10** families to make vir die pude are Prigraphie wnsideratins TETIT TULI OL 1 disçia ed famde vins tome mat Lips from in a satisfaICT memer de ma panin kenne ferbelity, InTHE MIT TO THe emer test to a weira fitting fam

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