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HURRICANE CELIA, AUGUST 1970, CORPUS CHRISTI, TEX.

EXHIBIT I

Recap of Consumer Complaint Items involving mobile homes from one Better Business Bureau. There are 40 companies involved in some 77 complaints accumulated over a period of months the following is a sample:

[blocks in formation]

Missing switch for range and pipe for exhaust fan..

Glass shower doors broken_-_.

Sliding loose-

Defective furniture__.

Hot water heater leaked_

Ceiling tile chipped---

Frequency of complaint

1

4

1

1

1

4

1

1

3

5

4

1

1

2

1

1

1

1

2

1

3

1

1

1

1

1

1

1

1

EXHIBIT J

NATIONAL ASSOCIATION OF INDEPENDENT INSURERS,

Chicago, Ill., May 12, 1972.

Re H.R. 14716.

Hon. Lot FREY, Jr.,

U.S. Representative, Cannon House Office Building, Washington, D.C. DEAR CONGRESSMAN FREY: The National Association of Independent Insurers, whose 535 affiliated companies write approximately 85 per cent of the mobile home insurance in the nation, supports the objectives of your proposed National Mobile Home Safety Act of 1972.

We wholeheartedly agree with you that in view of the mounting human and economic loss resulting from mobile home accidents, and the general lack of safety-related measures in the mobile home field, prompt action is needed to ensure the protection of the more than seven million Americans who live in this form of housing.

The absence of clearly-defined, enforceable safety legislation for mobile homes has had inevitable consequences in the insurance industry. As you pointed out in your recent comments on the floor of the U.S. House, the average mobile home fire loss has almost doubled in the last six years. Studies by the state of Oregon have concluded that fire loss in a mobile home as compared to its value is almost four times greater than the loss-value ratio of a conventional home; and the state of Arizona estimates that the mortality rate in mobile home fires is eight times higher than that in ordinary housing.

79-555-72- -26

As our industry strives to provide the broadest possible protection at affordable and equitable rates, these conditions are unfortunately creating unnecessarily high underwriting exposures which are having a telling impact upon insurance costs. It is a bad situation and certain to get worse unless meaningful safety provisions are adopted and enforced.

The introduction of your bill, therefore, was encouraging and welcome, and the NAII is ready to lend whatever advice and assistance we can to achieve the objectives of your proposed safety Act.

Very truly yours,

VESTAL LEMMON,

President.

The next witness is Mrs. Gladys N. Spellman. What is your title, Mrs. Spellman?

Mrs. SPELLMAN. I am a member of the County Council of Prince Georges County and am here in that capacity and as the first vice president of the National Association of Counties.

The CHAIRMAN. We are delighted to have you and we will look forward to hearing your testimony.

You are recognized.

STATEMENT OF GLADYS N. SPELLMAN, MEMBER, COUNTY COUNCIL OF PRINCE GEORGES COUNTY AND FIRST VICE PRESIDENT, NATIONAL ASSOCIATION OF COUNTIES; ACCOMPANIED BY JOSEPH M. POLLARD, LEGISLATIVE CONSULTANT FOR LOS ANGELES COUNTY; AND JOHN C. MURPHY, LEGISLATIVE REPRESENTATIVE, NATIONAL ASSOCIATION OF COUNTIES

Mrs. SPELLMAN. Thank you.

I am very happy to be here and I do have with me Mr. Joseph Pollard, who is the legislative consultant for Los Angeles County, and who will present a brief statement outlining the adverse impact on Los Angeles County of certain provisions of the legislation we are discussing.

The CHAIRMAN. Well, I think you should have the time. And if he wants to file a statement, we will be pleased.

Mrs. SPELLMAN. Maybe if I just cut mine kind of short.
The CHAIRMAN. I suggest that you use your time.

Mrs. SPELLMAN. The National Association of Counties (NACO) represents nearly 900 county governments which together comprise approximately 70 percent of the Nation's population. As such, counties have a tremendous stake in housing and urban development programs which vitally affect our residents.

The National Association of Counties has, and is continuing to express strong objections to certain provisions of the pending Housing and Urban Development Act. One of the provisions which NACO finds objectionable is title IV, the community development bloc grant consolidation. As the committee knows this title authorizes the consolidation of certain HUD community development programs-urban renewal, neighborhood development, open space, and rehabilitation loans into a single bloc grant, 80 percent of which would be distributed on a guaranteed formula basis-taking into account population, poverty, overcrowding, and past program experience-to metropolitan areas and within them to so-called metropolitan cities-those of 50,000 in population or central cities.

The second provision to which NACO objects is title VI, planning and management, which will be discussed later in this statement.

NACO strongly supports the principle of consolidating existing community development programs and allowing local governments to determine their own priorities. The current categorical grant programs involve far too much interference and redtape on the part of the Federal Government. However, NACO cannot support a bloc grant consolidation bill providing preferential status through a formula guarantee of funds which favors so-called metropolitan cities at the expense of the counties. This position was adopted by the NACO board of directors in April 1971 and reaffirmed by NAČO in hearings held by the House Housing Subcommittee in September

1971.

Once the initial distribution of community development funds is made to so-called metropolitan cities, the balance, if any, remaining becomes a discretionary fund. This discretionary fund is for use by the Secretary of HUD to fund projects on a competitive basis for counties of any size and for cities under 50,000 in population in metropoli

tan areas.

Recent examples of the Federal Government's use of discretionary funds in such programs as HUD's planned variations, LEAA's high impact anticrime program and Labor's CAMPS program are cases in point. The implementation of each of these programs provided no role or funding for counties and demonstrated a lack of recognition for the responsibilities counties have as providers of vital urban services.

Thus, having to rely on discretionary funds by counties of all sizes and small cities creates a real threat to their present and future community development activities.

As the first special revenue sharing bill to pass a House of Congress, this title in its present form establishes an unfair precedent for future special revenue sharing bills. Equality of treatment for both counties and cities within metropolitan areas is essential since the problems which community development funds seek to solve are not confined within city limits. Nor are these problems the sole responsibility of city governments. Numerous examples exist of counties having joint community development program responsibilities along with cities such as open space and water and sewer, or counties performing services for smaller cities.

Today, counties are taking on an increasing number of municipal responsibilities at the local and regional levels. County government activity has expanded into functions and service areas once considered exclusively municipal-parks and recreation, libraries, airports, hospitals, health services, utility systems, and renewal activities. County governments are quickly expanding their activities into entirely new areas-solid waste management, water and air pollution control, emergency ambulance service and highway safety. While not all of these services are termed community development they do serve to demonstrate that counties are providers of significant services on the local level aimed at meeting the needs of their residents.

Title IV of this legislation in our view fails to take into account the needs of and services provided by, counties in metropolitan areas. And, if allowed to stand, it will have a tremendous adverse effect on county community development activities.

This title contains several inequities to which NACO objects:

1. The intent of the community development bloc grant consolidation as set forth in section 401 is to provide Federal assistance on an annual basis, with maximum certainty and minimum delay, upon which communities can rely in their budget planning. Yet, this advantage applies only to the metropolitan cities. Counties, rather, must rely on the uncertainty of discretionary funds.

2. The hold-harmless, or past-program performance provisions operates differently for metropolitan cities from that which applies to counties or smaller cities. In the instance of the former, metropolitan cities are guaranteed, as a minimum amount of funding, the 5-year average of all the programs consolidated. By contrast, counties and smaller cities must have participated in an urban renewal or neighborhood development program before being entitled to hold-harmless funds. From our viewpoint, it appears that this provision was inserted to deny most counties meaningful participation in the new bloc grant program. While counties are not the exclusive clients for urban renewal or neighborhood development program funds neither are all metropolitan cities as these hold-harmless provisions would have one believe.

NACO believes that all jurisdictions in metropolitan areas must receive a guaranteed minimum funding for all of their community development programs in order that their current activities not be drastically curtailed or eliminated.

3. The third inequity relates to the guaranteed formula share af forded to "metropolitan cities." Under this provision a "metropolitan city" is entitled to the higher amount of its hold-harmless or its formula share. In contrast, counties are not guaranteed any formula share, thereby, affording them no growth in their programs above the holdharmless amounts which a small number will receive.

Thus, while "metropolitan cities" are afforded the greater of their formula share compared to their hold-harmless amount and have advanced certainty as to the level of funding to which they are entitled, these same advantages are not afforded counties and cities under 50,000.

Unquestionably counties and cities have an equal stake in the solution of the Nation's pressing urban problems, and they must be afforded an equal opportunity to use the financial tools provided by the Federal Government for that purpose.

A recent analysis of this title which appeared in the national journal shows tremendous increased funding to cities under the new block grant program. New York City's share will increase from $46.2 to approximately $125.6, Dallas from $2.3 million to $11.5 million, Houston from $700,000 to $15.6 million while Phoenix, Ariz., would increase 1,000 percent from $700,000 to $6.9 million.

NACO does not for a moment deny that needs exist in these as well as other cities. What we do contend, however, is that similar needs exist in county jurisdictions. Attached to my prepared statement is a summary of a survey of county community development activities conducted by NACO. This summary demonstrates the Federal assistance which 45 counties are presently receiving, together with a projection for fiscal year 1973. These figures pertain to the consolidation of programs under the Senate-passed version of the legislation.

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