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assisted under this Act. Upon receipt of a statement by the Governor of each State that the State, city or other local general purpose governmental unit has made expenditures pursuant to this Act, the Director may make a payment to the Governor not to exceed the amount allocated to each State.

Records, audits and reports: The Director would be given authority to require such records, conduct such audits and make such reports as are necessary for the effective administration of this Act.

SECTION VIII. INTERSTATE AGREEMENTS

The advance consent of Congress would be given to any interstate agreement among States or cities to undertake activities assisted by this Act.

SECTION IX. GENERAL PROVISIONS

SECTION X. REPEALS

Section 701 of the Housing Act of 1954, as amended, is repealed.

SECTION XI. EFFECTIVE DATE

This Act shall take effect on July 1, 1971.

NARRATIVE DRAFT OF PROPOSED COMMUNITY DEVELOPMENT PLANNING ACT

OF 1971

(Intended as an amendment to community development bills now before the Congress)

SECTION I

Not to exceed 11⁄2 percent of the sum allocated to each applicant, by means of an automatic formula or on a discretionay basis, for community development purposes (cite applicable section of the community development act) shall be available for expenditure upon request of the applicant, with the approval of the Secretary of Housing and Urban Development, with or without the applicant's funds, for engineering and economic surveys and investigations; for planning of future community development programs and projects and the financing thereof; for site evaluation, housing demand and supporting public service studies; for research and development necessary in connection with the planning, design, construction and maintenance of community development programs and projects; and for the development and updating of multi-year community development programs with special consideration to the availability of standard housing units, both federally subsidized and unsubsidized.

SECTION II

Sums made available under Section I of the Act shall be matched by the applicant in the same ratio as required for all other community development sums unless the Secretary of Housing and Urban Development determines that the interests of the community development program would be best served without such matching.

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Note: Total U.S. population, plus Puerto Rico, Guam, Virgin Islands, and American Samoa: 206,073,600.

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Mr. BARRETT. Thank you, Mr. Charkoudian.

Do you think there might be any inconsistency in your remarks? On the one hand, you state there would be too much review by HUD of a 3-year housing plan. On the other hand, you say it is impossible to know whether the suburbs or the central cities would benefit most from the $3,000 incentive funds. I thought the bill wisely leaves the specific amounts to the metropolitan officials. It appears to me that they would know best which communities would be in most need. Don't you think this is the way it should be done?

Mr. CHARKOUDIAN. I agree, Mr. Chairman. I think I can clarify for you what appears as a contradiction to you at this moment. Metropolitan housing agencies would determine how that incentive money would be distributed within their particular region, and I don't feel that it should be moved to the Federal level, to the Department of Housing and Urban Development. That was not my intent when I suggested that the money might not be effectively allocated. Rather, I was dealing with the mechanism itself. But even on local level, the regional level, it would be very difficult to determine where that money is to go. If in fact you ended up giving it to the suburban areas the central city would say, "well, look, we have a higher need."

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If you give it all to the central city you might thereby dissuade some of the smaller cities, the suburban areas, from entering into the program. I think that a more structured mechanism for distribution of these funds by metropolitan agencies would be helpful.

Mr. BARRETT. I notice, too, in your remarks you recommend that there be no earmarking of funds

Mr. CHARKOUDIAN. Correct.

Mr. BARRETT (continuing). Between the metropolitan area and the States. How would you split the money between 50 States and the 247 metropolitan areas?

Mr. CHARKOUDIAN. My comments on that, Mr. Chairman, were limited just to within the State; there are States which will have a higher I am thinking particularly of the Western States-that will have a higher housing need outside of the metropolitan regions, States where there are very small or very limited urbanized areas. Now, within, say, the Commonwealth of Massachusetts or the industrialized areas that proportional breakdown might be very accurate. I think that should not be a statutory mechanism but rather one to de determined by the State itself. That is my position, Mr. Chairman.

Mr. BARRETT. Greater flexibility?

Mr. CHARKOUDIAN. For the State, exactly. The Governor's conference is particularly concerned about encouraging such flexibility. Mr. BARRETT. Mr. Ashley?

Mr. ASHLEY. Mr. Charkoudian, I was interested, too, in your comments with respect to title V and the sensitivity you have toward the requirement that a housing plan substantially comply with the goals set forth under title V of the bill.

These goals, it seems to me, are really nothing new. They express public interest, previously indicated intentions of Congress, and do reflect presumably what the public considers to be its interest. How would we do it otherwise? Just say that in any given metropolitan area the public officials can get together and come up with a plan that they feel meets their social requirements, their requirements for shelter, and that that should be enough to assure them the block grant? From a realistic standpoint, does this make sense? Mr. CHARKOUDIAN. I understand your concern about my comments and I think they are certainly well founded.

If I may elaborate on that point: As you remember, Congressman, I do feel that the goals, as I stated, are lauable and should be an aspect of legislation. It was not so much even the phrase, although I used that phrase right from the bill, "substantially complies with the requirements of title V," but rather the information that an extensive package of rules and regulations developed by a Federal department might in some way circumvent the simplicity that you are seeking. We certainly do agree with you, if in fact you mean that the HUĎ review would be a simple and straightforward one. If that is the case, these particular plans meet the goals.

Mr. ASHLEY. Well, we are interested in assisting housing located other than in our central cities which is presently much the proposition we are faced with at the present time. We would like to see broader geographic consideration given to the location of such housing and Federal use planning in the metropolitan areas where such

housing is to be located, but again what we are confronted with today is the fact that an overwhelming majority of our public housing units are located in the inner city, generally in economic or racial ghettoes, and section 235/236 housing is being located not according to the judgments of public officials at all, but almost solely on the basis of the initiative of private builder-developers. We don't mean to sit here in Washington and say that this is good, bad, or indifferent, except as their view might be reflective of the sentiments of local public officials, but it has been our experience that most local public officials consider this to be a very, very real problem, and one that is growing— that is, the separation of people from jobs, the exclusion of people because they have no choice other than the inner city. So this was essentially the motivation that was not invented here in Washington; it was invented in every metropolitan area in the country with rare exceptions.

Mr. CHARKOUDIAN. Mr. Chairman, may I comment on that?
Mr. BARRETT. Did you finish your question?

Mr. ASHLEY. Yes, sir.

Mr. BARRETT. Yes.

Mr. CHARKOUDIAN. I could not agree with you more, Congressman Ashley. I do want to make clear as I do in my formal statement, I wholeheartedly concur with the need for a metropolitanwide housing planning effort. There is no question about that. I can tell you that the various efforts being made across the country to develop subsidized housing outside the central cities and outside the large metropolitan areas, are not working. We in Massachusetts, as you, Mr. Chairman, may have heard, do have a so-called antisnob zoning legislation. This particular mechanism is beginning to find sponsors who are willing to fight for housing, using the State appeals road in the suburban areas of our metropolitan regions but it is not happening fast enough. I agree 100 percent that we have to have metropolitanwide efforts in housing. Because the limited State efforts in this direction are not working, it is correct the Federal Government should make this effort. We just do not want a bureaucratic intervention that would actually hinder the achievement of desired objectives.

Mr. ASHLEY. Well, I do not think there is a great deal of difference between our views on this. What we have sought to do, of course, is to vest the responsibility for making decisions about where people live and about how they are going to live where the people are, which is in our metropolitan areas. Accordingly, we are not seeking here to promote a new Federal bureaucracy. On the contrary, what we are suggesting here is a type of instrumentality or mechanism which can be the product of each particular State, because we certainly lay down no suggestions with respect to the composition or the size of the metropolitan State housing agencies. It would be totally up to the States to exercise their judgment in this area, but we do think-and I must say this is both sides of the aisle, expressing what Secretary Romney said to us, too-that it really is not bureaucratic meddling to suggest that the Congress has an interest in the expenditure of very substantial amounts of housing funds, and that we want to see these funds expended in a far more successful way in order to accomplish what we are trying to do, which is to provide decent shelter and a good living environment to a lot more people than we do now.

Mr. CHARKOUDIAN. Mr. Chairman, may I ask a question through you of Congressman Ashley on this matter he is presenting?

Mr. BARRETT. Yes.

Mr. CHARKOUDIAN. Congressman Ashley, do you feel the phrase "substantially complies" would not create the type of monsters that even Secretary Romney referred to, the gigantic handbooks that were developed for the urban renewal program of title I of the Housing Act of 1949. If that is what you are saying then certainly we are saying exactly the same thing.

Mr. ASHLEY. What I am saying is that the requirement can be fairly simply stated: With the anticipated growth of our metropolitan areas it is the sense of the Congress that there be housing opportunities for people of differing income levels. For example, we certainly would construe it to be a matter of national purpose that people not be excluded because of the color of their skin or the origin of their ancestors. Another example is that the preliminary earmarking should give full consideration to areas that best lent themselves in terms of proximity to jobs, and so forth, so far as location is concerned. These are among the factors to be taken into account in determining whether a plan substantially complies with congressional intent.

I do not foresee regulations that are budrensome in detail in terms of compliance at all. On the contrary, I think that again what we are trying to do is to obviate the kind of redtape that has characterized urban renewal development in so many instances. But I think that with urban renewal we do very much want to say "What is your general plan here? What is it you have in mind and does this conform with what the Congress and the courts and the President have said about the directions we should be pursuing?"

I might just read a short paragraph from our report which says, "However, taken as a whole, the plan must be approved by HUD as one which, over the 3-year period, makes progress toward the fulfillment of established Federal objectives-housing for all income groups, located so as to provide greater access to job opportunities, and built in conjunction with basic community facilities and services." That does not suggest to me that we are somehow manufacturing a snare and a delusion or a means of entrapping communities, metropolitan areas, into a morass of bureaucratic redtape.

We do have the point system, for example, on water and sewer that is being pursued now, and if you want to address yourself to the bureaucratic redtape that is involved there why that may be interesting.

Mr. CHARKOUDIAN. No, I think, Mr. Chairman

Mr. BARRETT. You may proceed.

Mr. CHARKOUDIAN. That particular quotation from your subcommittee's very good study expresses the very spirit in which I hope the issue will be resolved. We are merely asking how much is going to be legislatively earmarked and how much discretion is going to be left with the Secretary. As Congressman Ashley has pointed out, it should be certainly minimal in terms of the amount of redtape regulatory control and leaving to the discretion of the regions, the regions which hitherto have not been doing their job have not even existed in the minds of the public, to plan for this housing which must be built with regional consideration.

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