There are several matters which relate to implementation of specific projects.

(1) We recommend the retention of the "Widnall" requirement establishing
standards for the acquisition of private properties. It supports the
concept of area-wide rehabilitation or redevelopment and reduces the
potentiality for exploitation of the housing program by property owners
who want to be "bailed out" of bad investments.

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(2) We recommend that the federal government require/specific plan be submitted for funding which includes a statement of purpose, a detailed budget, a presentation which can be understood by the citizenry, and an opportunity for the

citizens to be heard on the plan (pp. 24-26).

(3) We recommend that the needs of major projects be recognized by
authorization of multi-year funding. This is essential to attract
private capital. (pp. 4 and 23)

(4) We recommend that if a public agency has used tax abatements as an
incentive to redevelop or rehabilitate an area, the difference between
the normal tax and the reduced tax be made an eligible expenditure
under the Act. (pp. 27-28)

Let me enlarge on the problem of multi-year funding by citing a couple
of examples from my experience. During World War II, the federal
government interned many Nisei from California in camps near Denver.
When the war was over, many of these citizens chose to remain in
Denver, and because of the housing shortage at the time, they settled

in marginal housing near the Tri-State Buddhist church on the edge of

the downtown area. I found they could afford better housing, but it was

not available in the part of the city where they wanted to live. Over a period of time, a major urban renewal project has allowed the Church to move from

a converted warehouse into a new building, a residence for elderly citizens has just been opened, and a business and cultural center for the Japanese-American community was dedicated recently. Other buildings in the area also are being renovated. This has involved a considerable time span because the community is closely knit socially and culturally, and a major effort mounted all at once would have shattered it. Yet, it was necessary to know that the funds would be available to assure that the project would be consummated before the necessary investment capital could be raised.

In contrast, a NDP (Neighborhood Development Project) program was started in a semi-rural slum on Denver's outskirts. Funding, of course, was on a year-to-year basis. The population, who had been residents of the Ozarks, were uprooted by the depression dust bowls and stopped in Denver instead of going on to California. By now, they are elderly and are not particularly affluent. I guess most of them would be called "the working poor." In any event, our inability to schedule assistance for the entire area let unscrupulous real estate men and contractors prey on them; many sold out at a pittance and others paid unconscionably high rates for repairs to "fly-by-night" outfits who accurately pointed out that the housing did not meet city codes and frightened the residents into assuming huge bills. We could not offer a firm alternative, and many families in that area were the victims. Had we been able to say with a degree of certainty that we could provide low-cost rehabilitation loans next year or the year after, most of this exploitation could have been avoided.

AIP has established a policy that suggests biennial funding contract with an allocation for two additional years, the reservation for which would be subject to an evaluation of previous performance and the submittal of an application including an adequate plan for its use.

Eighth, we suggest that the fund allocation criteria (p. 31) should be broadened to include:

(1) vacancy rate

(2) housing cost

(3) housing conditions

As an administrative detail, we question the effectiveness of a post-audit as an enforcement technique. If there has been mal-administration, the wrong-doers may have long since departed, and their successors (and the residents of the community) are the ones who are punished. While the Bible discusses the liability for the transgressions of the fathers passing onto the sons, it is questionable in our minds if this is a proper basis for inter-governmental relationships. Perhaps this is why it is so difficult to find examples of the utilization of the post-audit in the manner suggested. (p. 38 of the bill.)

Our final comment on this bill is more of a concern than a firm recommendation. There is great pressure on all levels of government from environmentalists and others to increase the funding for water and sewer developments. The unrestricted listing of this as an eligible expenditure on p. 13 of the bill could lead to a serious shortage of funds for other purposes. If the committee agrees with this hazard, we suggest some kind of a ceiling on this item; about 15% of the total authorization would maintain the present funding level.

These suggestions are made in an affirmative spirit; we reiterate that we think that this Committee is making a signal contribution to the achievement of the housing and community development quality of this nation by the bill currently before you.

A more extended statement on the community development aspects of H. R. 10036 is appended to this statement as exhibit A.

The Better Communities Act (H. R. 7277)

As the former technical director of a Model Cities program, I worked for many months testing the categorical funding system and documenting its shortcomings. Many of the problems we identified in our work with the residents of the Model Neighborhood were those problems that fell between the cracks of those categorical programs; no one had noticed that the various programs did not mesh. It also was a favorite game to exploit the overlapping programs of various agencies. Further, administration of the detailed provisions of some of these narrow acts could be ridiculous. For instance, some years ago a regional HUD official proposed to disallow the renewal of our Workable Program because Denver's housing code did not provide for screening against malarial mosquitoes. Denver is located on a semi-arid mile high plateau at the base of the Rocky Mountains, and over a century of local medical history has never had any record of malarial mosquitoes. When I pointed this out, HUD decided to withdraw its objections. But on the broader scale, these types of problems have led us planners basically to support the concept of block grant funding.we have urged that the concept of block grants, contingent primarily Awe on the effective conduct of continuous comprehensive planning, be developed and implemented as the principal means of distributing Federal aid. Both the bills before you would achieve this funding concept but only H. R. 10036 would mandate adherence to a comprehensive plan. In essence both H. R. 7277 and H. R. 10036 would consolidate into one comprehensive grant program most of the hardware grant, community development assistance programs of the Department of Housing and Urban Development. AIP recognizes the need for and supports these efforts within Congress to simplify and consolidate under a block grant approach the various Federal programs affecting community development. The multiplicity of present programs

which related to these priority public concerns and the wide range of provisions and regulations associated with the different programs may have impeded achievement of the goals which these various programs collectively seek to achieve. Each program has been fraught with red tape and excessive requirements which lack flexibility and often do not address the full set of problems or overall objectives which may exist in a particular locality. In most cases there is no guarantee of continuity of funding. For these reasons AIP recognizes that a block grant approach to community development programs should help alleviate the conflicts, duplication and lack of coordination between present national programs dealing with the improvement of the Nation's communities.

While recognizing the need for simplification and coordination in the Federal support of community development programs, we at the same time believe that the Congress should maintain certain basic requirements to insure that certain national priorities and goals are achieved. We strongly urge this Committee to maintain an application requirement based on the preparation and implementation of plans that address themselves to national goals and require state and local governments to address these national priorities and assist in the realization of national growth policies. All community development plans should be developed in accordance with the expressed comprehensive plan for the community as a whole. We must insure that expenditures of funds are done in furtherance of national purposes and toward elimination of national problems. Therefore it is necessary to require some form of application process with its inherent review and approval requirements. Federal guidelines seem essential to assure that (1) the funds will be expended in accordance with the intent of Congress; (2) all necessary safeguards to protect the process against corruption are incorporated therein; and (3) all affected persons or businesses will be held harmless within the limits of reasonable monetary compensation and procedural safeguards. We believe that this can be achieved without sacrificing aspects of greater flexibility through the simplified use of a wider scope of eligible activities to carry out innovative and effective community development strategies adapted to local conditions. We believe that a completely "no-strings" approach would be neither appropriate nor practical.