to serve the needs of low- and moderate-income families, will also need public housing, rent supplements, and Section 235 and 236-type subsidies. Considering the parsimony with which these types of funds have been made available in the past for the construction of desperately needed housing in and around our ailing cities, and for the renewal of their decaying centers, there is nothing to justify the expectation that such subsidies will suddenly become available in huge quantities, out in the country, in addition to the enormous subsidies and advances which will be needed to launch the new communities themselves. In New York State, we have had the benefit of the existence of the New York State Urban Development Corporation for more than two years. This unique agency, which is the only one of its kind in the nation, is of precisely the type which S 3640 hopes to encourage everywhere. It has gone through its growing pains and is now admirably staffed to produce housing for low- and moderateincome famiiles in both central cities and their suburbs. What it has found, however, is that its efforts in that direction are constantly thwarted by the chronic national shortage of urban renewal and Section 236 subsidies and Section 23 leasing funds. If housing will get a larger federal allocation, would it not be best to put as much of it as we can into tested programs which are in demand, are ready to go, and can demonstrably serve present needs? One other possibly negative aspect of enactment of a large-scale new communities program at this time would be what we can best describe as its talent suction effect. Observation of federal programs over the years leads us to the conclusion that every new major program attracts the most talented, most experienced, and most creative people in the federal housing establishment. A new program is where the action is. It gives able people the greatest opportunity to exert their creative abilities, and gets them out of the wel worn rut of pressures and bureaucratic tangles which inevitably accumulate in all existing programs over the years. The most dedicated public servants, those who keep trying to accomplish concrete results in spite of all obstacles, see in new programs the promise of solutions to all the impasses which have always frustrated their efforts. New programs, at least while they are new, provide an opportunity for the release of pent-up tensions. They also hold the promise of rapid advancement. And so, every time a new program is enacted, it immediately becomes staffed with a stellar cast-to the detriment of many of the agencies, bureaus, or older programs which must keep on struggling with the accumulation of problems which the new program, in spite of its advance billing, seldom succeeds in doing much about. Considering the enormous demands for urban management talents at the local, state and federal level, we urge that the manpower implications of a new communities program be carefully considered, particularly from the point of view of its impact on the effectiveness of existing programs. We believe that it would be most benficial if, as a first step, Congress enacted that part of the new communities concept which deals with grants to corporations similar to the New York Urban Development Corporation, for start-up purposes and for the financing of feasibility studies and plans. This should spur the several states to establish such corporations and this in turn, would greatly increase our national capability to produce housing. We would urge that federal financing of such corporations be made available only if the powers granted to them by the State Legislatures would be sufficient to assure that they will be capable of performing effectively in both the inner city and in the suburbs. Two other important contributions that Congress could make to the ability of such corporations to renew decayed areas of inner cities is, first, to recognize them as the Local Public Agency in all instances in which their presence in a community is requested by resolution of a local governing body; and, second, to appropriate, in addition to the normal urban renewal appropriations, add-on urban renewal writedown funds to be used exclusively in programs undertaken by such corporations. But despite the problems we see with the enactment of a major commitment to new communities at this time, we fully agree that the concept is most challenging. Such communities have been successfully established abroad, and even if they have only mildly alleviated rather than solved the urban problems of other western nations, they have 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 more funds and attention to existing programs and the need for creative new approaches to those dimensions of the urban problem which existing programs 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, among all the competing claims for housing and public works, of all resources available for urban development and redevelopment, including specifically new communities and, most important, 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, though unfortunately much belated, 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 that the Committee bear in mind constantly that 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 are 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 of 1970 may well misfire. We would also like to 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 done, but only partly, 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 the full extent of any tax abatement required to enable any federally-or even State-assisted housing project to achieve rents within the means of low- or moderate-income families. We are sure that the members of this Committee are fully aware, based on experiences in all of the States throughout the country, that the need for local tax abatement subsidies in publicly 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 treatTent 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 sec. ties of Title I of the Housing Act of 1949 We definitely do not see the need for a new program, requiring new rules and formulas. We also fail to see any beed for limitations and constraints on federal assistance for such things as wap reetamation 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(e) of S. 3640. The provisions of this Section perpetuate the unfortunate current urban renewal requirement to the effect that each renewal pre-and I emphasize the word "renewal"-must contribute to the realizaSafational housing goals. In many instances, housing goals can be better realized on suirabie vacant land, outside of renewal areas. Such housing can be armarked jemarily for families displaced by public action, thus permitting iotes use and freed of slums for other essential purposes. This Committee end nake in Important contribution to the workability of the urban renewal gem w naking clear that it expects each continuing housing and renewal popim in each community, rather than each separate renewal project, to contata to the realization of national housing goals The chronic, ever-growing shortage of urban renewal funds glen prosents 1 zajer problem. Given the $3 billion demand backlog, we hope that the songte Einse Conference Committee will fund more han the 31 biltion requested by The kim.nistration and passed by the House--hopefully the full 31 7 provat y he senate. If the Committee does so we hope that the Admietakoak will spend all the funds thus made available. 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 Funds 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, buffer strips, and other highway-related objectives, undertaken as part of urban renewal projects in cities, should quality for financing out of the Highway Trust Fund, thus supplementing the available renewal write-down funds. Also, since the Trust funds do not come from the federal treasury, but are rather contributed by local motorists, we urge that any facilities so financed qualify as local non-crash grants-in-aid. Hon. JOHN SPARKMAN, AMERICAN SOCIETY OF CONSUlting PlanneRS, Chairman, Committee on Banking and Currency, DEAR SENATOR SPARKMAN: Following the presentation of my testimony on S. 3640, you questioned our interpretation of the provisions of Section 141 and especially our objection to the limitations and constraints on Federal assistance which we believed were contained therein. What we had reference to is the special emphasis on housing for low- and moderate-income families for which the land or space acquired for an inner city rebuilding project would have to be used under the provisions of Section 141 (b) (2). (In my testimony, I erroneously referred to Section 141 (c).) Given the current requirement that all renewal projects devote at least half of the land to housing for low- and moderate-income families, we assumed that the enactment of S. 3640 would be immediately accompanied by administrative regulations which would make all inner city rebuilding projects subject to it as well. As we pointed out in our testimony, it is unfortunate to insist that every renewal project or, as in this instance, inner city rebuilding project, contribute to the realization of national housing goals. Without in any way advocating that the emphasis on the achievement of national housing goals be weakened, we propose that the concept be broadened to include the total program undertaken in a given community rather than continue to require each individual project, whether renewal or inner city rebuilding, to contribute to their achievement. The present requirements work a special hardship on many communities, and especially the smaller ones with decaying central business districts. In such communities, the market for commercial and higher income housing is weak. For this reason, insistence on the building of housing for low- and moderateincome families in each project, even if the project area lies directly adjacent to or within the central business district, destroys any hope of its revitalization. Such insistence is particularly inappropriate in communities which still have, or can create through urban renewal, land not too far removed from the center of town where low- and moderate-income housing could be appropriately located. The land in the central business district should best be freed for commercial and ancillary facilities and for housing for the highest achievable income level so as to bring close to the downtown area the purchasing power of its residents, which is so essential to its revitalization. As a general principle, if a community shows its willingness to discharge its housing responsibilities, it would seem eminently desirable to permit it to make use of the urban renewal process to enhance its tax base (which it would need to do to be able to afford the financial sacrifices involved in the provision of publicly assisted housing) or for any other purpose consistent with its planning objectives. In fact, we see the possibility that in the case of many communities it is these advantages that would motivate them to develop assisted housing in the first place. We therefore wish to take this opportunity to reiterate our plea that the Committee review the present Title I legislation and administrative regulations and make clear its intent to free any community which contributes to the realization of national housing goals in whatever way it chooses from any corresponding restrictions and limitations on its urban renewal activities. Section 141 e di of 8. 8640 introduces a possible source of confusion and ambiguity. We suppose that, since it is axiomatie that no housing or other facilities can ever be provided expeditiously under traditional renewal proces it may be safe to leave it in. We fail, however, to see the need for such a finding to justify the redevelopment of an obsolete railroad freight yard or of some of the other types of areas eligible for action under the provisions of S. 3640 I hope that the above clarifies the point raised in my testimony and we greatly appreciate your interest. Respectfully yours, GEORGE M. RAYMOND, Chairman, Committee on Housing and Urban Development. The CHAIRMAN. Next is Mr. William Slayton, executive director, and Mr. Carl Feiss, chairman, Subcommittee on Urban Growth Policy Legislation, American Institute of Architects. Come around, gentlemen. We are glad to have you here. Nice to see you again, both of you. STATEMENT OF WILLIAM SLAYTON, EXECUTIVE DIRECTOR, AND CARL FEISS, CHAIRMAN, SUBCOMMITTEE ON URBAN LEGISLATION, AMERICAN INSTITUTE OF ARCHITECTS Mr. SLAYTON. Thank you, Mr. Chairman. Mr. Chairman, I will submit our written testimony for the record if that is agreeable and summarize the points. The CHAIRMAN. It will be printed in full (see p. 1151). Mr. SLAYTON. Mr. Chairman, my name is William L. SlaytonThe CHAIRMAN. Of course, this printed record you have will be a part of the committee file (indicating yellow volume). Mr. SLAYTON. Right. I did not expect that to be printed in the record. My name is William L. Slayton. And I am vice president of the American Institute of Architects. And we welcome the opportunity to testify today in this legislation having to do with the establishment of urban growth policy in the amendment to the housing legislation. At the outset, I should like to state that the American Institute of Architects strongly supports the basic objectives of the Urban Growth and New Communities Act of 1970. We have done a considerable amount of work in the field of urban growth, and we think that this is an important subject and an important objective of the Government. We need a national urban growth policy, and this legislation would establish the mechanism for establishing an urban growth policy. We have had some experience in the United States dealing with urban growth. Perhaps the most notable experience we have had is with the Tennessee Valley Authority. And more recently, of course, we have set up the Appalachia Mission and the Delaware River Basin to deal with growth and development within these large areas. Now, S. 3640 calls for a Council on Urban Growth to be located in the Office of the President and sets up a separate Council on Urban Growth. We would suggest that this be incorporated in the Council on Environmental Quality since urban growth in a man-made environment, we feel, is an important aspect of environmental quality. We think that the proliferation of independent, or not independent. but separate bodies within the Executive Office of the President can lead to some confusion. We would suggest that these functions be combined in the present Council on Environmental Quality. In this connection, we would like to suggest that the findings and declaration of policy make some reference to the importance of preserving the natural environment in the urbanization process and that in addition some reference be made to our existing housing problem and the importance in an urban growth policy of relating housing for all income groups to places of employment. We think that this is a major objective of establishing an urban growth policy. The title of the legislation dealing with new community development emphasizes new communities-we think overemphasizes new communities or, to put it another way, underemphasizes the kind of development that will take place on the periphery of metropolitan areas. And we think that that title ought to be changed to recognize that most of our growth will take place on the periphery of our metropolitan areas. And even though we build a large number of sizable new towns, that will take care of only a small portion of our urban growth. The needs for mechanisms to control urban growth on the periphery of our metropolitan areas, I think, is essential. I would like to see this legislation give some emphasis to that. The legislation proposes the creation of a national community development corporation, a corporation that is a fairly independent corporation, even though it is a public corporation, a corporation with the authority to undertake development on its own in experimental new cities, you might say, and a corporation that will provide loans and grants to public and private agencies undertaking new town development. We would suggest strongly that a corporation not be created; that this become a regular function of the Department of Housing and Urban Development since we feel it is going to be basically a loan and grant program, a program similar in concept or in operation to the urban renewal program. This is a public function. I think it is important that it be an operation within the regular framework of Government rather than a separate corporation. And we would urge strongly that it become part of a Department of Housing and Urban Develop ment. And I think, really, it is unnecessary for the Federal Government to engage directly in the development of new towns. I think this is best left to State-chartered development corporations, public development corporations, who have a greater sensitivity, perhaps greater flexibility, in creating new towns within their own States. I think it is important to point out that in this kind of urban growth. the growth on the periphery of metropolitan areas, the development of new towns where we will be using State-chartered public development corporations, either statewide such as New York State or local development corporations for metropolitan areas, that it would probably be unnecessary to have much in the way of subsidies for such develop |