We would be remiss, Mr. Chairman, if we did not point out that the failure of H. R. 10036 to mention the section 202 Housing for the Elderly and Handicapped is a serious omission and must be reconciled before our Associations could support this legislation. We would

urge the members of this committee to amend H. R. 10036 by adding the relevant sections of H. R. 10112 introduced by Congresswoman Heckler. Our Associations view this "Housing for the Elderly Act" as an essential ingredient in a National Housing Program.

Two particular sections of H.R. 10112 appeal to our membership. First, the controversial withdrawal of the Department of Housing and Urban Development from the Section 202 program because of budgetary pressures is eliminated. By establishing a revolving fund operating outside the regular federal Budget and financed entirely by U. S. Treasury notes, This off budget capital account is used already by the Department of Defense in some of its programs will not appear as a deficit in fiscal transactions.

which I might add

Secondly, we see great importance in the establishment of an office of Assistant Secretary of Housing for the Elderly within the Department of Housing and Urban Development.

This recommendation was a major priority of the 1971 White House Conference on Aging. The principal concern of our Associations is that there be a person responsible for meeting the housing needs of older Americans. The primary effect of establishing an Assistant Secretary, as opposed to an Assistant to the Secretary, is that the former position is within the direct line of departmental organization, is highly visible, and is less apt to remain vacant for any prolonged length of time than would be the case with the latter.

I might also add, Mr. Chairman, our Associations view the provision of assistance to nursing facilities to upgrade the physical plant to conform to fire safety standards as a priority. Last week our Associations testified in the Senate for the need to upgrade standards for Skilled Nursing Facilities and Intermediate Care Facilities. Congress has had a great hand in promoting stricter adherence to safety standards. However, Congress has been slow in providing rehabilitative assistance to nursing facilities to upgrade their physical facilities to conform to the higher standards. If Congress does not mandate action by the Department of Housing and Urban Development to underwrite improvement of nursing facilities, we may face a crisis of too many nursing homes being forced to close because they cannot meet standards and cannot afford improvements. We urge the Committee to give serious attention to this problem and to review carefully the provisions of H.R. 10293 introduced by Congressman Steele to amend the National Housing Act and related laws to provide for compliance with improved fire safety conditions in multi-family housing facilities designed for occupancy in whole or substantial part by senior citizens and to authorize Federal assistance in financing the provision of more adequate fire safety equipment for those facilities; to impose additional fire safety requirements upon nursing homes and similar facilities and assist them in meeting such requirements.

Finally, Mr. Chairman, I believe it is important that I comment on the recent housing message from President Nixon. Unfortunately, it is our Associations' view that this proposal breaks faith with older

Americans.

The President says the problem is lack of money, not housing.

In fact, the problem for older persons is lack of both.

Vague promises

of cash grants in the distant future instead of action now will only worsen today's housing crunch. Cash assistance may be helpful in the future, but cash will not buy a commodity which does not exist."

After the White House Conference on Aging in 1971, the Nixon Administration, following recommendations from its own experts in HUD and HEW, supported 70,000 new housing starts for the elderly. But this promise was suddenly scrapped last January when a 1 1/2 year moratorium on most public housing starts was declared. The stated purpose was to gain time for the study and evaluation of existing programs and to develop solid proposals for today. Now we learn that the moratorium is largely unchanged and instead of new action, we face still more recommendations for still more study.

Our Associations stress the unique needs of older persons seeking housing needs which are different from those of others with whom the elderly would compete for housing under a cash assistance program. Housing requirements for the elderly touch on many areas such as proximity to transportation, community services, ease of access, nearby health care and so forth. The 202. 235 and 236 HUD housing programs have gone a long way toward providing the kind of housing older Americans need.

To strangle those efforts now in favor of some nebulous new program in the distant future is to worsen rather than improve the housing problems faced by Americans today.

On behalf of our 5.4 million members of our two Associations, we want to express appreciation to you for affording us the opportunity to present our views for your consideration in the Department's housing study.

Our formal statement is enclosed. We trust that it will receive your full attention as it represents considerable study and in-depth analysis of the subject and the existing situation facing older Americans.

If the proper function of government is to do for the people what they cannot do for themselves, it is high time for the federal government to stop studying and begin acting on an adequate scale, if "a decent home and a suitable living environment for every American family" is to become even a partial reality before another generation passes.

From 1949 to 1973, we have seen only minimal progress in the
direction of that goal. While hopes once were high, optimism
has turned to gloom, especially in recent months. If this trend
is to be reversed, there must be more than a reaffirmation of
goals. There must be a commitment to action, accompanied by
needy allocation of an adequate share of this nation's resources.
Fool, clothing and shelter are fundamental human needs, and i
the people's government cannot recognize and act upon that set
of priorities, the government cannot be viewed as adequately
serving its people.

While ideally our system should enable individuals, through
their own efforts, to provide themselves and their families
"a decent home and a suitable living environment," the economic

realities are such that this goal remains unattainable for many people; for others, who during their economically productive years were self-sufficient, the onset of old age destroys the fragile economic self-sufficiency they once knew.

Government action in the realm of housing production and finances, while immediately urgent, can attack only one aspect of this fundamental problem. A broader response must be conceived and implemented.

Such a response must be addressed to the basic economic problems of this nation including the continuing lack of economic opportunity for many, the high level of individual taxation, the inadequacy of social insurance programs, and certainly the pattern of inflation with its related aspects of declining productivity and economically non-productive utilization of our nation's resources.

Until the fundamental problems of our economic system gain sufficient recognition to compel corrective action, secondary effects such as housing inadequacies must demand inordinate allocations of resources because of the fundamental nature of the need.

A variety of kinds of housing must be produced, must be widely dispersed geographically, and must be placed within the reach of all who need it. "Housing" must be recognized as something more than four walls and a roof, and must be designed in accordance with human needs. Housing must be so located that "living" is possible, taking into account the total environment.

The methodology of production and finance is secondary to the adequacy of the commitment. No methodology will produce adequate results, given inadequate resources. Certainly safeguards should be provided to insure the proper expenditure of public funds, as should be provided in any government program. And certainly past experience should be applied to the avoidance of predictable difficulties. These, however, are aspects of administration which should be designed to be adequate to the

task.

It must be recognized that, for those least able to pay the full cost of housing, there must be sufficient subsidy. Not all housing can be profit-making or self-sustaining; not all financing can be attracted from the profit-oriented private sector. When sufficient incentive does not exist to attract private financing, government financing is essential.

For older Americans, the Sections 202 and 235 programs provided appropriate, immediate responses to a need; certainly these should be re-implemented with utmost speed. Those older Americans

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