States. There is never a business meeting of our national organization, but that a resolution favoring an adequate housing program is adopted. We consider an adequate housing program to be one that provides for families of all income levels in the field of housing. We would urge you to strengthen the bill now being considered by your committee in the following ways: We doubt if the private housing program as envisioned in titles I and II amendments of the new bill will provide the amount of housing estimated. We believe that a larger program should be envisioned so that we may be assured of sufficient housing for an increasing population, and as a means of undergirding the economic needs of our country at this time. We are pleased to see the section on slum clearance, urban redevelopment and renewal program in the bill. It is our opinion that the sponsors of the bill are overoptimistic as to what can be accomplished by this program. The lack of an adequate housing program has put a wear and tear upon the present housing supply so that houses are worn out considerably ahead of their usual life span. This we are aware of in every city wherein we work because we know how houses are being overused, building codes disregarded, and a doubling up far beyond any time in the history of our Nation, so that once this program gets underway we think that the number of buildings that can be rehabilitated and made livable, can only be done at such great expense that they will of necessity turn out to be housing in a considerably higher cost category than the bill envisions. A further concern that we have regarding this program is that the slum clearance program will displace many more low-income families than the rest of your program provides rehousing for. We have already had many sad experiences with title I of the Housing Act of 1949, where communities have disregarded their responsibility to find housing for those displaced. We should not create other hardships with this legislation unless more protection is put into this bill, this is exactly what will happen. Our great disappointment is that you have failed to provide for a proper public-housing program in the bill, but that this is left purely to the Appropriations Committee. In our opinion you certainly should ask for more publichousing units to be built each year than was envisioned in the Housing Act of 1949. Our population is now larger and the need is greater due to the fact that the Housing Act of 1949 was not carried out. The substitute experimental program in place of public housing which offers home ownership to low-income families for a long mortgage payment with a minimum downpayment is in our opinion shortchanging the low-income and housing consumer. What house built for $7,000 today will hold up for 40 years? In an economy where one-half of all families have incomes of $3,420 or less and 25 percent of this number, incomes less than $2,000, is it reasonable to assume that these families with the present high cost of living will be able to maintain mortgage payments of $62 per month? Moreover, for how many of these families is home ownership desirable? We provide in our economy an abundance of housing, both for rental and sale, for the consumer who can pay $80 per month and up so that free competition can operate. We do not provide even sufficient housing for the low income consumer let alone providing for a competitive market. In our opinion public housing must provide for a much larger proportion of the population than we have thus far. These are problems that must be met. They should be met in the Housing Act of 1954. STATEMENT OF JOSEPH H. EHLERS, FIELD REPRESENTATIVE, AMERICAN SOCIETY OF CIVIL ENGINEERS My name is Joseph H. Ehlers. I am field representative of the American Society of Civil Engineers and am making this statement on behalf of that society. The American Society of Civil Engineers, with a membership of about 37,000, is the oldest national engineering society in the United States with branches throughout the country. It is the technical society most actively concerned with the designing of engineering public works and shares an interest in public buildings with the American Institute of Architects. Our interest in this bill lies particularly in section 702 entitled "Reserve of Planned Public Works." I will limit my observations to that section. It is grouped with section 701 “Urban Planning" in title VII of the bill. The con nection between the two sections is remote. My remarks deal principally with the matter of the authorization to the Housing and Home Finance Administrator, in addition to supporting the basic concept of advance planning. Despite the fact that we hold the present Administrator of the Agency in high regard and greatly admire the forceful manner in which he is attacking the housing problem, we do not believe that the Federal direction of a reserve of planned public works, as a matter of principle, is a proper function of the Housing and Home Finance Agency. This is particularly true of such a program designed to stimulate construction activity whenever the economic situation makes this desirable. We do favor the concept of advance planning both of housing as well as of all types of public works. We concur in the statements made by Administrator Cole in his testimony on this section of the bill. Public works activities involving the design of water supply and sewerage plants, roads, bridges, and other engineering works should never be considered as mere adjuncts to housing activities. They have little relationship to and require a different type of personnel from slum clearance activities. They should not be placed in charge of agencies dealing with public housing and slum clearance activities of the Federal Government. They affect not only metropolitan development but also rural and State development. The planning and Federal approval of public works of this nature should be under the direction of Federal agencies professionally experienced and qualified in these special fields. In the December 1953 report of the President's Advisory Committee on Government Housing Policies and Programs, the advance planning of nonFederal public works is referred to only as an activity in liquidation. The new program of section 702 had not then been considered. The same principle would seem to apply to it as to the agency's school building program about which the President's Committee had this to say, "It is the conclusion of the Committee that this is not a proper activity of a housing agency. It should be assigned to the Office of Education, Department of Health, Education, and Welfare." A similar conclusion was reached about the college housing program. The advance planning and other programs of the Bureau of Community Facilities were assigned to the Housing Agency for liquidation, several years ago, following the abolition of the Federal Works Agency. At that time several groups most familiar with the subject, including the American Institute of Architects and the National Society of Professional Engineers, expressed disapproval of the assignment of this planning and community facilities work to the Housing Agency even for the purpose of liquidation. Our organization did not comment at the time since the work was only to be liquidated. Now that its reactivation is proposed, we feel that we should express our views. Assignment of such work as this to the Housing and Home Finance Agency seems to violate the principle laid down by the Commission on the Organization of the Executive Branch of the Government in 1949. That principle was to assign the engineering work to the agency dealing with the basic function, e. g., transportation, public health, education, etc. In accordance with this principle, the Bureau of Public Roads was transferred to the Department of Commerce. Responsibility for the planning of other projects has been assigned to the agencies dealing with the basic functions involved-housing to the Housing and Home Finance Agency, provision of office space to the Public Buildings Service, airports to the Civil Aeronautics Administration, and so forth. The major exception seems to be certain planning and building programs now handled in the Housing and Home Finance Agency which are of vital concern to the newly created Department of Health, Education, and Welfare. Since about 80 percent of the work under the advance planning program now nearing completion relates to educational, sanitary, or health facilities, the Department of Health, Education, and Welfare is far more concerned with the type of work involved than is any other agency. Comprehencive planning in these fields is among the already recognized responsibilities of this Department. Able engineers are already on its rolls. Public Law 139, 82d Congress-assigned the functions in connection with community facilities planning relating to health, refuse disposal, sewage treatment, and water purification to the Public Health Service. Stream pollution abatement and hospital planning have also been assigned to it. Thus, if the proposed advance planning were limited to health and educational facilities, it would constitute a comprehensive program for the types of work for which advance planning is most urgently needed. Of the 20 percent not included in such a limited program, many facilities such as firehouses, police stations, etc., can be designed in a reasonably short time and should not be the subject of Federal advances for advance planning. Coordina The proposed advance-planning program of section 702 is by no means an overall program, but would simply be one segment of a public-works reserve, principally the segment relating to health and educational facilities. tion between highway, airport, educational, and other construction used to stimulate activity in any recession would need to be provided, regardless of which agency handles the program. If a public-works program should be undertaken to stimulate construction, some billions of dollars of projects would be required. A glance at the work undertaken from 1934 to 1938 will indicate how remote such a program is from housing. The Public Works Administration during this period was concerned with such projects as New York's Triborough Bridge and Lincoln Tunnel, costing nearly $100 million; sewage-disposal plants for Cleveland, Chicago, New York, and the Twin Cities costing over $100 million, as well as others in dozens of cities; great bridges spanning the Ohio, the Missouri, and other great waterways throughout the country; educational buildings, State buildings, courthouses, dams, and power projects; even such enterprises as the New York-Washington electrification of the Pennsylvania Railroad. If the need again arises, the establishment of some similar supervisory agency would appear to be a logical development. Advance planning of public works was devised to lessen the delays in commencing construction work needed for economic stimulation. The greatest part of the delay often occurs in making preliminary economic analyses, foundation studies, and acquiring of land rather than in making final plans. Fully completed designs may become obsolete before construction is started because of changed requirements and improvements in technology. This is especially true at a time of high prospective construction activity such as the present, because an emergency public-works program is principally helpful for stimulating a depressed construction industry rather than for remedying unemployment situations that may occur in other industries. A considerable part of the proposed advance planning should therefore consist of careful preliminary planning so developed that final plans can be completed in a few additional months. Incidentally, I have urged this in connection with previous advance-planning programs. Mr. Cole agrees with this view. An agency that specializes in a particular field is more competent to deal with such basic preliminary work than one concerned largely with having a reserve of blueprints. Thus, for example, the Public Health Service is intimately concerned with the basic planning of water-treatment and sewage facilities and hospitals. The American Society of Civil Engineers favors sound advance planning for the purpose stated in section 702. This work of the Division of Community Facilities should be kept separate from that of divisions handling slum-clearance planning. The President's Committee on Government Housing Policies, under the chairmanship of Mr. Cole, recently recommended the transfer of all the functions of this division to other divisions or to other agencies. The major projects in the architectural field (hospitals, schools, etc.), either are presently handled in or are recommended for transfer to the Department of Health, Education, and Welfare. The same policy should apply even more forcefully to engineering projects. It would be logical to assign the program proposed in section 702 to the Department of Health, Education, and Welfare as a program of advance planning for sanitary, health, and educational facilities. Inasmuch as the President's Advisory Committee on Housing has recommended transfer of the personnel engaged on the presently most active work of this Division to the Office of Education, it would be logical to transfer the Division of Community Facilities to the Department of Health, Education, and Welfare to be maintained as a unit for carrying on the proposed advance planning work in addition to these continuing programs, in close cooperation with the Public Health Service and the Office of Education. The authorization in section 702, should, we believe, be to the Secretary of Health, Education, and Welfare; or to the President to assign to agencies along the lines of their major responsibilities. Hon. JESSE P. WOLCOTT, NATIONAL SOCIETY OF PROFESSIONAL ENGINEERS, Chairman, House Committee on Banking and Currency, House of Representatives, Washington 25, D. C. DEAR MR. WOLCOTT: The National Society of Professional Engineers has noted with great interest the introduction and present consideration of H. R. 7839, a bill to aid in the provision and improvement of housing, the elimination and prevention of slums, and the conservation and development of urban communities. Our interest is particularly in connection with the portion of title VII of the legislation, which would provide an authorization of $10 million to resume noninterest bearing planning advances to local and State bodies for public works plans, repayable when construction is undertaken, in order that such works can be ready for construction if the economic situation should require it. The National Society of Professional Engineers has been interested in the advance planning programs since their inception as part of the War Mobilization and Reconversion Act of 1944, and we indicated our support of the continuation of these programs in 1947 and again in 1949. Many of our engineer members have had an opportunity to perform professional services in connection with the previous advance planning programs, and for that reason we feel that our organization is in a fair position to comment upon the previous programs and the desirability of reviving a similar program at this time. On three separate occasions the board of directors of the National Society of Professional Engineers has considered the matter of supporting the programs and this consideration has resulted in approval in each case. It may be in order at this point to state that the National Society of Professional Engineers is composed of 39 member State societies, which, in turn, include numerous local chapters in all parts of the Nation (now numbering over 350 such local chapters). All of the more than 32,000 members are registered under the engineering registration laws of one or more of the States. Based on our experience as outlined and the comments of our members who have participated actively in the advance planning programs, we desire to inform the committee of our continued support of the principles of a program for advance planning of non-Federal public works. Our past and present support of the advance planning program has been predicated on the finding that the programs have been fairly and efficiently administered and that the relationship of professional engineers to the administration was handled on a professional basis by those experienced and qualified as professional engineers and construction experts. It will be recalled that the program was first adminstered by the Federal Works Aency through its Bureau of Community Facilities and later by the same Bureau which had been transferred to the General Services Administration. Reorganization Plan No. 17 of 1950 transferred the administration of the advance planning program from GSA to the Housing and Home Finance Agency. This society opposed that transfer on the basic ground that the future success of the program would be jeopardized by having it administered through an agency which has a primary mission in the housing field as distinguished from the public-works field; a real and substantial difference in philosophy of operation and administration. Our position on the question did not prevail. The advance planning function has been in a state of liquidation in the Housing and Home Finance Agency for the past several years. Inasmuch as the program was being liquidated it did not seem too urgent that any further steps should be taken to retain the advance planning program administration in a proper agency. However, now that the program is to be reactivated, it becomes a matter of deep concern to us that the new authorization will retain it in the Housing and Home Finance Agency. Rather than repeat our somewhat extensive comments on this question, we enclose a copy of our letter of January 21, 1954, to the Honorable Albert M. Cole, Administrator, Housing and Home Finance Agency, and Chairman of the President's Advisory Committee on Government Housing Policies and Programs. The letter was a comment on certain portions of the Advisory Committee's recent report, and a copy of the letter was sent to the President. Since our letter to Mr. Cole was written, the anticipated revival of the advance planning program has become a reality and the problem therefore becomes more urgent and immediate. In addition to the possible solutions of alternative administrative location of the advance planning program outlined in our letter to Mr. Cole, an additional possibility has appeared. That is the proposed Public Facilities Administrator in the Executive Office of the President, as suggested in the Public Facilities Act of 1954, introduced on February 8, 1954, by Senator Douglas (S. 2913) and Representative Bolling (H. R. 7766). We have been advised by Mr. Cole that our views will be given the most careful consideration and by Gov. Sherman Adams, of the White House staff, that the President had referred our comments to Dr. Arthur Burns, of the Council of Economic Advisers. It is hoped that your committee will give serious consideration to the question of the administrative location of the advance planning program. The National Society of Professional Engineers will be most pleased to provide any additional information at our disposal or consult with you or any member of the committee, or designated representatives, to further consider this matter. We request that this letter and the enclosure be included in the record of the hearing before the committee. With sincere appreciation for your consideration, PAUL H. ROBBINS, P. E., Hon. JESSE P. WOLCOTT, REDEVELOPMENT BUILDERS OF NEW YORK, Chairman, Banking and Currency Committee, DEAR CONGRESSMAN WOLCOTT: On behalf of the Redevelopment Builders of New York, I would appreciate the opportunity of presenting for the record of your hearings on the Housing Act of 1954 our views and comments with respect to this proposed legislation and particularly its provisions for expanded action for the renewal of American cities. We are an association of the private building organizations engaged in carrying out privately financed redevelopment projects on a full taxpaying basis under the New York City slum-clearance program. Consequently we are already dealing at firsthand with the problems of rebuilding blighted and rundown city areas on a basis that will transform living conditions and will constitute a sound outlet for private-investment funds. The comments set forth below are based on our practical experience in this field and are presented with the thought that they may be of help to your committee in its consideration of this legislation. At the outset, we would like to endorse strongly the basic provisions of the Housing Act of 1954 with respect to urban renewal and redevelopment and the accompanying FHA amendments designed to facilitate private investment in such undertaking. We believe that, with certain minor amendments and administrative interpretations, these provisions are workable and would provide a substantial stimulus to the job of revitalizing American cities. SECTION 220 From the standpoint of private enterprise participation in the rehabilitation and redevelopment of blighted areas, the most important new provision in the Housing Act of 1954 is section 220. In our opinion, the authorization of mortgages covering up to 90 percent of the value of multifamily developments in urban renewal areas is fully justified in view of the greater obligations which private developers must assume in undertaking such projects as compared with the conventional development of suburban apartments on open land. Likewise, we endorse the provision for higher mortgage allowances for elevator construction. These will permit a realistic reflection in FHA mortgage financing of the higher cost of such construction and will correct the situation whereby redevelopment builders have been called upon to develop high-rise elevator buildings within the mortgage ceilings designed for less costly garden-apartment structures. There are, however, several matters which we would like to call to your attention from the standpoint of accomplishing in full the objectives of section 220. FHA valuations. We have no objection to the language in section 220 setting forth the basis on which the FHA valuation of multifamily projects will be determined. However, if the objective of section 220 is to be accomplished, we believe it is essential that the mortgage commitments issued by FHA actually represent 90 percent of the overall cost of a project, including land and all other expenses. In our opinion, this means that the findings of the Housing and Home |