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Mr. Chairman, your own efforts in bringing about this study are well known to the National Association of Counties. We feel it will do much to provide answers to the problems caused by acquisition of property by different Federal programs being taken.

We would suggest this study's recommendation be considered, prior to any action being taken.

TITLE VI-COMMUNITY FACILITIES

Our policy statement is silent as to the proposals to grant 15-year loans to finance the acquisition of open or predominantly undeveloped land, to be utilized in connection with the future construction of public works and facilities, and 50-year loans to construct such facilities (secs 602-603). It has been said that the development of communities used to follow the streetcar tracks, while today the water and sewage lines provide the guideline.

There is little doubt that this provision could be an effective tool for local governments in directing growth. There would be a number of political considerations they would be faced with, including the fact the property would be off the tax roll for some time without being utilized and whether they would be accused of land speculations, et cetera. These types of questions would have to be answered on an individual basis; however, we have no doubt many counties would seek to obtain the loans.

The amendment to section 601 would amend title II of the Housing Amendments of 1955 (the public facility loans program) to remove the population limitation for a public facility loan thereunder for communities seeking assistance for a water or sewage project.

Paragraphs 2 and 3 of section 601 of H.R. 9751 make desirable improvements in the existing community facilities program by making financial assistance under this program available for projects serving more than one community without regard to the aggregate population of the communities which it is serving, so long as each of these communities is within the existing 50,000 population limit on the program and by waiving the existing population limits on the program for municipalities which will experience substantial population growth. However, the 50,000-population-ceiling limitation would still remain in effect for all other cities, counties, and other local governments. This population limitation has several major disadvantages with respect to meeting governmental responsibilities for water supply and sewage disposal in metropolitan areas.

First, it directly discriminates against communities of 50,000 population or more by not permitting them to receive public facility loans. Second, it encourages fragmentation, duplication, and inadequate longterm facilities by prohibiting bond action by a number of communities within a metropolitan area to meet water and sewer needs when even one of these communities has over 50,000 population. We, therefore, recommend the population limitation, for this type of project, be removed.

TITLE VII—FEDERAL, STATE TRAINING PROGRAMS

The proposed section 701 providing special training of technicians involved in planning does not, in our opinion, place emphasis on one of the weaker points of the urban planning assistance program. We

feel that any special training under this program should be more directed to the recipient of the aid rather than the practitioner.

It was our understanding in Onondaga County that the prime objective of the urban planning assistance program was to get a planning program started or to "prime the pump." We have completed such a 701 program and find that it has done just that, since we now have a strong continuing program of planning. Smaller communities, however, have received similar planning grants, but have not had the same result as our own.

Local planning boards experience quite a turnover and continuity of thought is quite easily lost. Since most local communities cannot retain a professional planning staff on a continuing basis, planning frequently comes to a halt when the 701 program is completed. This is due in part to the misunderstanding of the fact that planning is a process and not a product.

Should the training which is now possible as part of the 701 program be more directed toward the recipient of the new plan, it would give those plans a much greater chance of fulfillment or sound modification. Special and periodic conferences or training schools for local planning board members should be encouraged and aid in the conduct of those training sessions need not be tied to the preparation of plans in themselves.

PROPOSED TITLE X

Section 201 authorizing the Federal housing aid mortgage insurance to assist in the financing of sites of entirely new communities has never been considered by our organization. We have nothing in our policy statement to guide us on this subject, nor have we ever discussed such an idea at any of our meetings.

We would recommend, however, that if the program is enacted, section 312, which provides planning grants for new communities, should be made only to governmental jurisdictions having sufficient responsibility and power to effectuate that plan. In many areas, such as New York State, the school program is directed by someone other than the municipality or county. Similarly, decisions made on State and federally aided highways are not entirely integrated with local planning considerations.

In short, if the planning grants are to be fully used as intended. the agent using them must have virtually complete control over the fulfillment of that plan. A step toward this can be seen in the new municipal cooperation laws of New York State which permit a great deal of flexibility and working relationships between different units of local government.

In most cases, counties would appear to be the most logical unit of government to prepare plans for and execute the construction of new towns, once this ability to control is obtained. For that reason we would recommend that counties be eligible to not only plan for the construction of new towns under section 310, but also serve as the local government in administering the new title, should it be enacted. Remove population limitations on Federal assistance for comprehensive planning:

Existing programs in the field of housing and community development continually stress and increasingly require comprehensive planning. This bill is an outstanding example of this fact; section 201,

section 601, paragraph (3), subsection (b), section 602, section 603, section 701. The official section-by-section analysis of the administration bill has pointed out the need for comprehensive planning is not limited to any specific type situation:

Experience has shown that there are groups of communities with declining, stable, or only normally increasing populations which are in need of comprehensive planning assistance.

Congress has previously recognized comprehensive planning as an aid to improve the economic situation of a community by removing the population requirements for areas declared depressed by section (5a) of the Area Redevelopment Act.

Notwithstanding the preceding, the Federal Government's program of financial grants to assist comprehensive planning is limited to counties and cities under 50,000 population or where the city or county is classified as a standard metropolitan statistical area in and of themselves. As previously pointed out, the population limitation is temporarily removed while the government unit is determined depressed. However, it is our feeling the need to sustain or improve a healthy economic situation is equally as important and dependent upon sound planning.

It is true these excluded political units might be able to qualify for this assistance if they are able to arrange a satisfactory regional planning agency. Section 301 of this bill would delete the requirement that such a region was experiencing "rapid urbanization," thereby further recognizing the fact planning is needed for all economic and growth situations. Although these regional arrangements are laudable objectives, they are often fraught with difficulties, not the least of which are political.

Apparently the reluctance to make 701 planning grants to counties which are part of a metropolitan area is based to some extent upon the fear it would interfere with encouraging cooperative metropolitan or regional planning. However, there is an equally important planning job necessary for individual governmental units making up the metropolitan complex, especially since these governments execute the plans. The ability for these metropolitan plans to be carried out effectively, will be directly based upon the strength of the planning units of the individual local government. The understanding of their own needs will correspondingly increase their understanding and willingness to cooperate in areawide activity.

The National Association of Counties has consistently supported the concept of intergovernmental cooperative efforts in meeting our present-day problem. We actively supported the recently passed Senate bill, S. 855, which would require the units of government in metropolitan areas to submit certain applications for Federal grants and loans to a metropolitan planning body for review and comment, prior to submission to the Federal agency.

We feel a procedure such as this would prevent the possible diminu tion of metropolitan-wide planning if the population limitations were removed.

Our support for regional cooperation is legion as indicated in the "American County Platform," which is the official policy statement of the National Association of Counties. I request that the pertinent sections of that document be inserted in the record at this point. Mr. RAINS. Have you pointed out those sections of the document?

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Mr. MULROY. Yes, sir.

Mr. RAINS. They may be included at the end of your testimony. Mr. MULROY. Yes, Mr. Chairman. I will provide them.

Moving on to other counties ineligible, but not a part of a metropolitan area: An accompanying list enumerates this group. Some of them may be temporarily eligible due to being categorized as depressed areas under section 5 of the Area Redevelopment Act. It is true these counties might qualify if they are able to arrange a satisfactory regional planning agency.

Surely these counties should not be penalized for their inability to formulate a regional arrangement. No such requirement is placed on counties with less than 50,000 population, nor where they are in a depressed category. We therefore urge the population limitation for Federal assistance to comprehensive planning under the 701 program be removed. In connection with this we endorse section 311, which would remove the dollar limitation on the authorization for the appropriation of funds for section 701 planning grants.

(The tables referred to follow :)

Counties with 50,000 or more population, which are in SMSA's, but which do not have a city of 50,000 or more population 1

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1

State and county

1960 population

Clay..

87,474

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Counties with 50,000 or more population, which are in SMSA's, but which do not have a city of 50,000 or more population1—Continued

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The New England States (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont) are not included.

The following list of counties presently ineligible for 701 comprehensive planning assistance. Many of them are temporarily eligible by virtue of section (5) of the Area Redevelopment Act. The list includes counties over 50,000 which are not in a standard metropolitan statistical area and those over 50,000 in an SMSA. Both categories are ineligible for direct grants, unless classified "depressed."

Counties with 50,000 or more population, which are not in SMSA's and which do not have a city of 50,000 or more population1

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