NEED FOR NATIONAL GROWTH POLICY

The American Institute of Architects endorses the concept of a national urban growth policy. The Federal Government should be concerned, in broad terms, with where urban growth will take place and should, where possible, use its public investment program to encourage growth in those areas where growth is determined desirable. We have not as a nation made such analyses or determinations, although we have for specific areas devised programs dealing with economic development. Our earliest experience, of course, was the Tennessee Valley Authority-a highly successful operation. We have also established a program for Appalachia and have also created special agencies to deal with areas such as the Delaware River Basin. The Department of Defense has established programs to assist communities in their economic development where the closing of a military installation has an adverse effect upon the economy of the community.

Consequently, it is not as though we have not established programs to deal with urban growth in specialized situations. We have had some experience in this field. But, we have not examined the nation as a whole and recommended basic policies on urban growth for the entire country. S. 3640 initiates this needed process.

S. 3640 calls for the creation of a Council on Urban Growth to be located within the Executive Office of the President. We view this provision as essential in bringing about a convergence of responsibility and coordinaton for a national growth policy. We recommend, however, that the functions of the Council on Urban Growth be incorporated in the Council on Environmental Quality. The environment is the man-made environment as well as the natural environment, and the Council on Environmental Quality should be concerned with basic policies that will aid in the creation of a good man-made environment. Thus the Council should be concerned with urbanization as well as with the preservation of the natural environment.

In this connection, we would suggest that the findings and declaration of policy make some reference to the importance of preserving the natural environment in the urbanization process and in addition that 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. A major objective of an urban growth policy is to provide real opportunity of choice for those now forced to live in inner city areas so that they may have access to jobs, most of which are being created on the periphery of our metropolitan areas. We strongly recommend that this kind of objective be included in the findings and declaration of the policy.

NEW COMMUNITY DEVELOPMENT

Title II is labeled "Development of New Communities". This is, we believe, an essential element of a National Growth Policy. However, we know that even with a large and comprehensive new town program, that most community development will take place on the periphery of our urbanizing areas primarily on the periphery of our metropolitan areas. Title II should reflect this both in its provisions and in its heading.

Title II proposes the creation of a national community development corporation that would be given the authority to carry out this new town program. We can see no advantage in the creation of a separate national corporation. The assistance provided under this proposed legislation should be administered by a department of the Federal Government. We would recommend that this program become a program of the Department of Housing and Urban Development. In this way, the program is subject to annual review by Congress in seeking its appropriations and in seeking amendments to the basic legislation. This Community Development Corporation would be exercising public powers and should, therefore, be a part of the government. An agency that administers grants should, in our opinion, be part of the government structure rather than a separate corporation.

In addition, the proposed corporation would exercise functions closely related to the functions now exercised by the Department of Housing and Urban Development and the Council on Environmental Quality. Considerable confusion would ensue. The American Institute of Architects recommends against the creation of a semi-independent Community Development Corporation and sug

gests that the program be placed in the Department of Housing and Urban Development.

Further, we feel it unnecessary for the Federal Government to engage directly in the development of new towns. This is best left to state chartered public development corporations who have greater sensitivity to the needs of their areas than would the Federal Government.

Also we feel it is improper for this semi-private corporation to be given the authority to coordinate major installations of the Federal Government. This is a major public function; it should not be exercised outside of the framework of government.

In fact, we have considerable reservations as to the ability of even a public agency to coordinate major installations. One of the most commendable and potentially important functions of the proposed Urban Growth Council could be to establish policies and guidelines for all Federal Agencies and provide a review function for proposed major installations.

In the assistance proposed for the development of new towns or peripheral development around metropolitan areas, we think it should be recognized that these developments should ultimately require practically no subsidies. A public development agency should be able to dispose of the land it acquires at a sufficient markup to pay for the development costs, the interest costs, and the management and administrative costs during the development period. The exeprience of new towns in Great Britain indicates that they are now becoming self-supporting.

It is essential, however, for these public development corporations to have access to sufficient capital to pay for the cost of acquiring land, the installation of the necessary streets and utilities, the payment of interest on the capital acquired, and the payments for administrative and management costs over a considerable period of time.

We would question, however, the political acceptability of the Federal Government is making direct loans to such public develompent corporations. The treasury has strong feelings against direct loans since such loans have a considerable impact on the budget. In addition, where these are public agenciesand we feel that only public agencies should be recipients of aid under this program. Title IV of the 1968 Act already provides assistance to private developers the public agency will have the authority to float its own loans. We would suggest that a more acceptable financing mechanism would be a Federal guarantee of such loans with an interest rate subsidy in lieu of Federal income tax exemption on the securities. The public housing program has operated successfully under a similar program.

We wholeheartedly endorse the concept in the bill of encouraging early construction of public works such as schools, fire stations, libraries, child care centers, etc., by providing a subsidy to cover interest costs on such public facilities for those initial years where there is an insufficient tax base to support such payments. As one of the pioneer residents of Park Forest, Illinois, a new community developed by Philip Klutznick in the late 1940's south of Chicago, and as a member of the School Board of that new community, I recognize the difficulty of financing schools in a newly developed area. The tax income was insufficient to pay for the operation of the schools in the first two years and there was insufficient assessment base to float bonds to finance the new schools. In this instance, we were fortunate in having a developer who recognized the importance of schools to new community development; and thus provided some housing units to be used as schools plus operating costs during the initial development period.

The point is that there should be a recognition of the importance of providing public facilities early so as to produce a complete community rather than waiting for the community to develop and produce sufficient tax base and tax revenue to support these activities. We would recommend in addition that grants rather than loans be made available for the early operational costs of these facilities and public services.

On building and housing codes, the building and housing code requirements should be no more stringent than are the existing requirements under urban renewal. We should not penalize new development in this respect. In addition, we should recognize that there may be public development corporations, such as the New York State Urban Development Corporation that have the authority to override local zoning laws and building codes. In short, the building and housing codes requirement needs some sensitive administration so as to encourage the improvement of building codes.

NEED FOR NATIONAL GROWTH POLICY

The American Institute of Architects endorses the concept of a national urban growth policy. The Federal Government should be concerned, in broad terms, with where urban growth will take place and should, where possible, use its public investment program to encourage growth in those areas where growth is determined desirable. We have not as a nation made such analyses or determinations, although we have for specific areas devised programs dealing with economic development. Our earliest experience, of course, was the Tennessee Valley Authority-a highly successful operation. We have also established a program for Appalachia and have also created special agencies to deal with areas such as the Delaware River Basin. The Department of Defense has established programs to assist communities in their economic development where the closing of a military installation has an adverse effect upon the economy of the community.

Consequently, it is not as though we have not established programs to deal with urban growth in specialized situations. We have had some experience in this field. But, we have not examined the nation as a whole and recommended basic policies on urban growth for the entire country. S. 3640 initiates this needed process.

S. 3640 calls for the creation of a Council on Urban Growth to be located within the Executive Office of the President. We view this provision as essential in bringing about a convergence of responsibility and coordinaton for a national growth policy. We recommend, however, that the functions of the Council on Urban Growth be incorporated in the Council on Environmental Quality. The environment is the man-made environment as well as the natural environment, and the Council on Environmental Quality should be concerned with basic policies that will aid in the creation of a good man-made environment. Thus the Council should be concerned with urbanization as well as with the preservation of the natural environment.

In this connection, we would suggest that the findings and declaration of policy make some reference to the importance of preserving the natural environment in the urbanization process and in addition that 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. A major objective of an urban growth policy is to provide real opportunity of choice for those now forced to live in inner city areas so that they may have access to jobs, most of which are being created on the periphery of our metropolitan areas. We strongly recommend that this kind of objective be included in the findings and declaration of the policy.

NEW COMMUNITY DEVELOPMENT

Title II is labeled "Development of New Communities". This is, we believe, an essential element of a National Growth Policy. However, we know that even with a large and comprehensive new town program, that most community development will take place on the periphery of our urbanizing areas—primarily on the periphery of our metropolitan areas. Title II should reflect this both in its provisions and in its heading.

Title II proposes the creation of a national community development corporation that would be given the authority to carry out this new town program. We can see no advantage in the creation of a separate national corporation. The assistance provided under this proposed legislation should be administered by a department of the Federal Government. We would recommend that this program become a program of the Department of Housing and Urban Development. In this way, the program is subject to annual review by Congress in seeking its appropriations and in seeking amendments to the basic legislation. This Community Development Corporation would be exercising public powers and should, therefore, be a part of the government. An agency that administers grants should, in our opinion, be part of the government structure rather than a separate corporation.

In addition, the proposed corporation would exercise functions closely related to the functions now exercised by the Department of Housing and Urban Development and the Council on Environmental Quality. Considerable confusion would ensue. The American Institute of Architects recommends against the creation of a semi-independent Community Development Corporation and sug

gests that the program be placed in the Department of Housing and Urban Development.

Further, we feel it unnecessary for the Federal Government to engage directly in the development of new towns. This is best left to state chartered public development corporations who have greater sensitivity to the needs of their areas than would the Federal Government.

Also we feel it is improper for this semi-private corporation to be given the authority to coordinate major installations of the Federal Government. This is a major public function; it should not be exercised outside of the framework of government.

In fact, we have considerable reservations as to the ability of even a public agency to coordinate major installations. One of the most commendable and potentially important functions of the proposed Urban Growth Council could be to establish policies and guidelines for all Federal Agencies and provide a review function for proposed major installations.

In the assistance proposed for the development of new towns or peripheral development around metropolitan areas, we think it should be recognized that these developments should ultimately require practically no subsidies. A public development agency should be able to dispose of the land it acquires at a sufficient markup to pay for the development costs, the interest costs, and the management and administrative costs during the development period. The exeprience of new towns in Great Britain indicates that they are now becoming self-supporting.

It is essential, however, for these public development corporations to have access to sufficient capital to pay for the cost of acquiring land, the installation of the necessary streets and utilities, the payment of interest on the capital acquired, and the payments for administrative and management costs over a considerable period of time.

We would question, however, the political acceptability of the Federal Government is making direct loans to such public develompent corporations. The treasury has strong feelings against direct loans since such loans have a considerable impact on the budget. In addition, where these are public agenciesand we feel that only public agencies should be recipients of aid under this program. Title IV of the 1968 Act already provides assistance to private developers the public agency will have the authority to float its own loans. We would suggest that a more acceptable financing mechanism would be a Federal guarantee of such loans with an interest rate subsidy in lieu of Federal income tax exemption on the securities. The public housing program has operated successfully under a similar program.

We wholeheartedly endorse the concept in the bill of encouraging early construction of public works such as schools, fire stations, libraries, child care centers, etc., by providing a subsidy to cover interest costs on such public facilities for those initial years where there is an insufficient tax base to support such payments. As one of the pioneer residents of Park Forest, Illinois, a new community developed by Philip Klutznick in the late 1940's south of Chicago, and as a member of the School Board of that new community, I recognize the difficulty of financing schools in a newly developed area. The tax income was insufficient to pay for the operation of the schools in the first two years and there was insufficient assessment base to float bonds to finance the new schools. In this instance, we were fortunate in having a developer who recognized the importance of schools to new community development; and thus provided some housing units to be used as schools plus operating costs during the initial development period.

The point is that there should be a recognition of the importance of providing public facilities early so as to produce a complete community rather than waiting for the community to develop and produce sufficient tax base and tax revenue to support these activities. We would recommend in addition that grants rather than loans be made available for the early operational costs of these facilities and public services.

On building and housing codes, the building and housing code requirements should be no more stringent than are the existing requirements under urban renewal. We should not penalize new development in this respect. In addition, we should recognize that there may be public development corporations, such as the New York State Urban Development Corporation that have the authority to override local zoning laws and building codes. In short, the building and housing codes requirement needs some sensitive administration so as to encourage the improvement of building codes.

NEED FOR NATIONAL GROWTH POLICY

The American Institute of Architects endorses the concept of a national urban growth policy. The Federal Government should be concerned, in broad terms, with where urban growth will take place and should, where possible, use its public investment program to encourage growth in those areas where growth is determined desirable. We have not as a nation made such analyses or determinations, although we have for specific areas devised programs dealing with economic development. Our earliest experience, of course, was the Tennessee Valley Authority-a highly successful operation. We have also established a program for Appalachia and have also created special agencies to deal with areas such as the Delaware River Basin. The Department of Defense has established programs to assist communities in their economic development where the closing of a military installation has an adverse effect upon the economy of the community.

Consequently, it is not as though we have not established programs to deal with urban growth in specialized situations. We have had some experience in this field. But, we have not examined the nation as a whole and recommended basic policies on urban growth for the entire country. S. 3640 initiates this needed process.

S. 3640 calls for the creation of a Council on Urban Growth to be located within the Executive Office of the President. We view this provision as essential in bringing about a convergence of responsibility and coordinaton for a national growth policy. We recommend, however, that the functions of the Council on Urban Growth be incorporated in the Council on Environmental Quality. The environment is the man-made environment as well as the natural environment, and the Council on Environmental Quality should be concerned with basic policies that will aid in the creation of a good man-made environment. Thus the Council should be concerned with urbanization as well as with the preservation of the natural environment.

In this connection, we would suggest that the findings and declaration of policy make some reference to the importance of preserving the natural environment in the urbanization process and in addition that 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. A major objective of an urban growth policy is to provide real opportunity of choice for those now forced to live in inner city areas so that they may have access to jobs, most of which are being created on the periphery of our metropolitan areas. We strongly recommend that this kind of objective be included in the findings and declaration of the policy.

NEW COMMUNITY DEVELOPMENT

Title II is labeled "Development of New Communities". This is, we believe, an essential element of a National Growth Policy. However, we know that even with a large and comprehensive new town program, that most community development will take place on the periphery of our urbanizing areas-primarily on the periphery of our metropolitan areas. Title II should reflect this both in its provisions and in its heading.

Title II proposes the creation of a national community development corporation that would be given the authority to carry out this new town program. We can see no advantage in the creation of a separate national corporation. The assistance provided under this proposed legislation should be administered by a department of the Federal Government. We would recommend that this program become a program of the Department of Housing and Urban Development. In this way, the program is subject to annual review by Congress in seeking its appropriations and in seeking amendments to the basic legislation. This Community Development Corporation would be exercising public powers and should, therefore, be a part of the government. An agency that administers grants should, in our opinion, be part of the government structure rather than a separate corporation.

In addition, the proposed corporation would exercise functions closely related to the functions now exercised by the Department of Housing and Urban Development and the Council on Environmental Quality. Considerable confusion would ensue. The American Institute of Architects recommends against the creation of a semi-independent Community Development Corporation and sug