nology. Industry can attract specialized talent. Industry can bring to bear qualified manpower and new materials.

NAM supports the objectives of Section 502 (a), Title V of S. 3639 which encourage the adoption of performance-type building codes and the modernization of local ordinances permitting the use of advanced technology.

Most existing codes, not only antiquated but obsolete in terms of today's hous ing, have needlessly exact specifications and inappropriate standards. Those standards which are arbitrary and outdated undermine attempts to encourage both innovation in building materials and the application of modern technological advances to housing. They discourage mass production and mass marketing, two techniques which have the potential for revolutionizing the housing industry by cutting costs and increasing supply.

In many localities prefabricated houses and even packaged components are frequently ruled out and it becomes virtually impossible to institute the newer advances in industrialized construction methods, due in lerge measure to restrictive work practices of many unions in the building and construction industries.

The situation is made worse by the plethora of different codes and ordinances throughout the United States. There are between 5,000 and 8,000 different codes across the nation; some metropolitan areas have to contend with as many as 60. Discrepancies between jurisdictions mean that standard components cannot be used, building time is increased, and additional construction costs are created.

Reform is urgently needed at local and, especially, at state levels. Model codes should be encouraged. There are differences of opinion about the desirability of a nationally uniform building code. However, in view of the high stakes and the fact that some of the most promising solutions to the housing problem will cross state borders, serious study should be given to the need for a nationally recognized performance type building code which would permit varying quality levels.

All building codes and related codes should be performance-type rather than specification type; the test should be whether the proposed mode of construction or materials used can do the desired job and meet the established performance test, rather than to insist on a specific material manufactured in a certain way. Emphasis should be on encouraging reasonable standardization, as long as certain basic requirements are properly met. The intent should be to foster technological advances, efficiencies and economies.

LOW-INCOME HOME OWNERSHIP

NAM supports the objectives of Section 402, Title IV of the "Mortgage Credit Assistance Act" (Title I of S. 3639), which aims at facilitating home ownership, and Section 10, Title II of S. 3639 which facilitates conversion of public rental housing to condominiums.

All too often publicly-supported rental housing for low-income families has, in effect, duplicated the slum environment rather than replaced it. High-rise projects in particular have often deservedly earned the name of "vertical slums." Management of many such housing projects has been unresponsive to the needs of the occupants. With little say in the day-to-day operation and overall policies, they are deprived of a sense of community, feel no identification with the project, and have no motivation either to maintain or improve the housing. Moreover, such projects-ill kept and unattractive-are socially isolated from the neigh. borhoods in which they are located and find themselves increasingly unwelcome. Occupant ownership of housing by low-income families would help solve many of these problems. Most government-assisted housing is seldom the temporary stopping-off place it was originally intended to be. More often it becomes the permanent home of its occupants. Home ownership, therefore, seems more appropriate under these circumstances. Owner-occupants feel a real stake in their housing and generally have a greater interest and pride in its upkeep and improvement. Neighborhoods tend to look more favorably on home ownership. In sum, home ownership makes for a more stable community.

There are financial advantages as well. Federal tax deductions, in effect, subsidize home ownership. With all other things being equal, an ownership dollar tends to buy more housing than a rental dollar. In addition, the cash down payment of a homeowner could be reduced if "sweat equity"-work done by the owner himself, such as painting or landscaping-is used.

From now on, the major emphasis on housing for low-income families should be placed on home ownership possibilities for both new and existing housing, and including cooperatives and condominiums. Together with the various government subsidies now available, such housing can be brought within the reach of most. though not all, low-income families. Even conventional single-family ownership. or lease-with-option-to-purchase, is now possible under some circumstances, and this should be encouraged. The provision of special services to help low-income families cope with the problems arising from home ownership also should be encouraged.

FEDERAL NATIONAL MORTGAGE ASSOCIATION

NAM supports the objectives of Section 108. Title VII of S. 3639 that the Federal National Mortgage Association be authorized to deal in conventional mortgages.

More credit must be made available for housing if our housing supply is to expand sufficiently to meet the tremendous need for it. Conventional mortgages should be given assistance comparable to that given government-insured and guaranteed mortgages. Many banks and saving institutions have reached their legal limit on the amount of funds they can tie up in mortgages. Other financial institutions hesitate to invest in housing. The encouragement of conventional mortgages by FNMA purchase would facilitate the direction of much needed additional investment into the housing field.

CONCLUDING REMARKS ON S. 3639

NAM believes that the housing crisis should have a top national priority. In line with this belief, the Association helped to promote the concept that led to the creation of the National Corporation for Housing Partnerships under Title IX of the Housing and Urban Development Act of 1968. Through the medium of NAM publications, companies have been encouraged to provide funds for the Housing Partnerships as well as for the local limited partnerships that will actually build housing units.

In addition, NAM has encouraged HUD to establish a Business Advisory Committee to promote private enterprise solutions to the problems of housing. Thus the businessmen's potential contribution to the broader areas of housing and urban renewal would be formally recognized and given status by the federal government. And, in so doing, recognition would be given to the innovative capacity of American business to help government solve major urban problems.

A National Business Advisory Committee, attached to HUD and working with other groups and organizations, would have the potential for a truly effective partnership with government.

A NATIONAL URBAN POLICY

In addition to our remarks on the proposed housing legislation, the Association would like to comment, in a broader context, on the need for a national urban policy.

The NAM Board of Directors in May 1970 approved a position on National Urban Policy, which is included at the end of this statement. This policy points out that the solution of the social and economic problems that attend the urbanization of our nation is a paramount need that must involve every segment of our society. The policy emphasizes, particularly, the impact of the condition of urban America on the economic stability and vitality of the nation and urges that government and industry recognize and act on this fact.

At the same time, the NAM. recognizing the complex social, political and economic systems that exist in the major metropolitan areas of the nation, urges that the many resultant problems no longer be treated in piecemeal fashion. Effective results will not be obtained in individual urban areas unless local problems are considered in the context of their relation to the problems existing in other urban centers.

In sum, a national urban policy, rather than many local urban policies, is needed. That policy must set national goals, delineate responsibilities of the various elements of society, and generate enthusiasm for leadership and action. This policy also must stimulate a sense of urgency that reflects the crisis proportions of the nation's ills.

VAM policy supports the objective which led to the creation of the Urban irs Council at the White House. As charged by the President, this Council

will attempt to develop a national urban policy having regard both to immediate and to long-range concerns, and to priorities among them.

NAM regards the achievement of this objective to be of critical importance to the nation, and stands ready to promote and insure industry participation in the development and implementation of a policy that will enlist all elements of society in attacking the problems that threaten the future of our urban society.

POLICY POSITION ON "HOUSING"

NATIONAL ASSOCIATION OF MANUFACTURERS

Continuing efforts should be made to provide more abundant and higher quality housing, particularly for low and moderate income families. The soundest advances in private housing ownership and other community improvements will be the result of individual and group efforts at the community and neighborhood level, and these should be encouraged in every practical way. Occupant ownership of housing units by low income families is preferable to institutionalized rental housing projects because it encourages the occupant in improvement and maintenance of the property. Programs to facilitate the conversion of public housing projects to a cooperative or condominium basis should be encouraged. In such cases where cooperative or condominium conversions is not feasible, steps should be taken to more deeply involve tenant organizations in the management of public housing projects.

The Association urges business interests to cooperate with corporations and partnerships created under Title IX of the Housing and Urban Development Act of 1968 in order to encourage the widest possible participation by private enterprise in the provision of housing for low or moderate income families. It should be recognized that the problems in the field of housing are of such magnitude that they should be approached on a cooperative basis by all segments of industry. At the same time, individual businessmen should be active at local levels in action housing programs, redevelopment boards and other agencies, and in studies of the impact of local real estate taxation on housing.

Housing subsidies should be clearly specified and measurable so as to be amendable to the congressional appropriations process and so the American people may know their true total cost.

The Federal National Mortgage Association should be authorized to establish a strong secondary market for conventional mortgages in addition to governmentinsured and guaranteed mortgages.

The U.S. Department of Housing and Urban Development should establish a Business Advisory Committee in order to promote private enterprise solutions to housing and urban renewal problems, and to promote the use of modern materials and techniques in order to lower the cost of housing construction and rehabilitation. The Committee should be appointed by the Secretary of Housing and Urban Development on the basis of recommendations by organizations active in the business and financial community, and knowledgeable in the housing field. The Committee should encourage the adoption of performance-type building codes and the modernization of local ordinances. Study should be given to the possibility of a nationally recognized building code of a performance-type which would permit the use of existing technological advances and encourage the development of others. Careful consideration should be given to the potentialities for rehabilitation of housing as an approach offering less social dislocation and the possibility of greater economy than mass demolition.

POLICY POSITION ON "NATIONAL URBAN POLICY"

NATIONAL ASSOCIATION OF MANUFACTURERS

Solution of the social and economic problems that attend the urbanization of the United States is a paramount need that must involve every segment of society. Government and industry must act on the knowledge that the condition of our urban centers will increasingly determine the economic stability and vitality of the nation.

The NAM acknowledges the obligation of the industrial community to participate in the solution of these problems, and to consider the impact of its own 48-279-70-pt. 2-54

decisions and actions on the well-being of the total society. This obligation has particular force with respect to those social ills that are the direct or indirect consequence of industrial activity, or suggest action that business and industry have special competence to provide.

It must also be recognized, however, that the major metropolitan areas of the nation are in fact complex social, political and economic systems. Their myriad problems should no longer be dealt with piecemeal, out of context with each other, nor will effective results be obtained through sporadic efforts in individual metropolitan areas that are not considered in the light of an overall national policy. Similarly, the economic burden of dealing with social problems cannot be borne by any single element of society. Appropriate incentives must be provided to induce the participation of all elements, and the costs must be assumed by society as a whole.

The resources of business and industry can be most effectively employed in urban problem-solving in consideration of a total policy which clearly defines goats, fixes responsibility, and generates leadership. This requires the development of a realistic National Urban Policy, implemented to achieve specific goals with the sense of urgency that a mounting crisis demands. This national policy should provide national priorities and define specific goals that will inspire broad public support.

The NAM supports the objective, which led to the creation of the President's Urban Affairs Council, of developing "a National Urban Policy having regard both to immediate and to long-range concerns, and to priorities among them." NAM regards the achievement of this objective to be of critical national importance, and offers its resources in the development and implementation of a policy that will enlist all elements of society in the attack on the problems that threaten the future of an increasingly urban nation.

Hon. JOHN SPARKMAN,

NATIONAL CONFERENCE OF CATHOLIC CHARITIES,

Chairman, Banking and Currency Committee,
U.S. Senate, Washington, D.C.

Washington, D.C., July 15, 1970.

MY DEAR SENATOR SPARKMAN: The enclosed statement was adopted by the Commission on Housing and the Commission on Aging of the National Conference of Catholic Charities. It concerns one aspect of the Housing and Urban Development Act of 1970 which you introduced in the Senate (S. 3639), namely, its failure to provide specifically that assistance shall be given to housing for the elderly and to earmark funds for that purpose. The Commissions fear that unless this is done any assistance given to such housing under general authority may be minimal particularly at this time when there is a crisis in housing and great pressures will undoubtedly be exerted on behalf of other classes of citizens for the available funds.

We urge you to propose an amendment to the Act which will identify by special title and programs the efforts to be made on behalf of the elderly and the funds to be authorized for that purpose. The elderly need this special attention.

Respectfully yours,

Rev. Msgr. LAWRENCE J. CORCORAN,
Secretary.

NATIONAL CONFERENCE OF CATHOLIC CHARITIES

COMMISSION ON AGING COMMISSION ON HOUSING

The National Conference of Catholic Charities is the coordinating agency of the major social welfare programs of the Catholic Church in the United States. Its Commission on Aging and Commission on Housing have the responsibility to identify the concerns of the NCCC in the fields of aging and housing and to direct and articulate its interests in those areas.

At their meetings on April 28-29, 1970, the NCCC Commission on Aging and Commission on Housing adopted the following joint statement with respect to 3639 and H.R. 16643, 91st Congress, 2d Session (The Housing and Urbar elopment Act of 1970):

Having considered S. 3639 and H.R. 16643, 91st Congress, 2d Session, from the aspect of the elderly of our nation, we are deeply dismayed that this proposed legislation does not specifically provide that assistance shall be given to housing for the elderly and does not earmark funds for that purpose. We fear that unless this is done any assistance given to such housing under general authority may be minimal. Section 202 of the Housing Act of 1959, as amended, authorizes direct loans at below market rates of interest to build or rehabilitate rental housing for the elderly. It has provided many nonprofit groups, including those under Church auspices, with the opportunity to develop many meaningful housing programs for our senior citizens. This law was a useful tool in our efforts to meet the housing needs of the elderly. The administrative action of the Secretary of the Department of Housing and Urban Development in discounting the use of this law is, in our opinion, unfortunate.

The proposed legislation does not direct the Secretary of the Department of Housing and Urban Development to provide any particular quantity of housing for the elderly, does not specify any proportion of the appropriated funds to be used for this purpose, and does not mandate any actual assistance to housing for the elderly, does not specify any proportion of the appropriated funds to be We fear that housing for the elderly will not be assisted, or will be assisted in token amounts only, if these matters are left to the sole discretion of the Secretary of the Department of Housing and Urban Development. Many of the elderly are also poor, are not organized, and are generally without advocates. We feel that a legislated categorical program is needed if the elderly are to get their fair share of the Federal housing dollar and if the Department of Housing and Urban Development is to have within its ranks persons both skilled in, and committed to, the field of aging.

We urge that S. 3639 and H.R. 16643 be amended to identify by specific title and program particular kinds of assistance for housing for the elderly and that sums of money-in dollar amounts-be earmarked for such purpose.

Finally, we urge that the legislation also be amended to instruct the Secretary of the Department of Housing and Urban Development to include in its Washington staff and in the staffs of its regional and area offices personnel whose prime responsibility and expertise are in the area of housing for the elderly.

STATEMENT OF THE NATIONAL LUMBER AND BUILDING MATERIAL Dealers ASSOCIATION

Mr. Chairman and members of the subcommittee: My name is Richard Norvell. I am a lumber and building material supplier from Nashville, Tennessee, and I present these views as Chairman of the Legislative Advisory Committee of the National Lumber and Building Material Dealers Association.

The National Lumber and Building Material Dealers Association has between nine and ten thousand members in 28 state and regional federated associations throughout the nation. Therefore, the terms of the Housing and Urban Development Act of 1970 are of the utmost interest to our members, and we appreciate the opportunity to express our views on S. 3639 to this Subcommitee.

We wholeheartedly endorse the aim of this legislation, both to increase the supply of decent housing and to consolidate, extend, and improve laws relating to housing and urban renewal and development. Our members have been in the forefront of the national effort to provide more decent housing in the past, and we look forward in the future to expanded efforts under this legislation.

We have studied in detail the provisions of S. 3639 and we believe this legislation will accomplish its stated aims. However, we have some suggestions which we believe will improve the bill and we would like to submit these for your consideration.

MORTGAGE CREDIT

The new Mortgage Credit Assistance Act is both needed and desirable in consolidating the numerous authorities scattered throughout the National Housing Act into a minimum number of broad, flexible programs, in eliminating obsolete and duplicating authorities, and in improving existing operations and subsidy programs.

On the other hand. present FHA programs have, for the most part, operated effectively to give massive support to housing production over this past ye