diversity necessary to design and implement their planning and management programs. The President's Advisory Council on Executive Reorganization, in discussing the management capabilities of state and local governments, stated, "We recommend that executive management grants be made to the States to be administered by the Office of Management and Budget. These grants should be on a formula basis. They should provide for an automatic passthrough as to a major portion of the grant for cities and urban counties over 75,000. Each Governor should have the discretion to make grants to smauer general purpose units of government, or to combinations of these governments."

The National Governors' Conference adopted a policy statement in August 1970 related to grants for comprehensive planning assistance in which they stated, "Assistance should be provided to plan comprehensively at the interstate, regional, metropolitan and local levels; to encourage local governments to cooperate in solving areawide problems through comprehensive planning, review, and coordination; to foster intergovernmental attacks on problems of national, rural and urban development, and to establish a method for exchange of development information among local, state and federal governments. Any legislation should provide that the grants be administered through the Executive Office of the President for distribution to the States, and through them to the regions, metropolitan areas, counties and localities."

The State of California Council on Intergovernmental Relations wishes to express its endorsement for this proposal and requests your support for the recommendation of the National Governors' Conference that a one hundred million dollar per year planning and management program be established, from the tansferred 701 program, in the Executive Office of the President with statutory responsibility for the allocation of these funds to the States in a block grant. Thank you Mr. Chairman for this opportunity to present to you the views of representatives of the cities, counties and State government in California.

Hon. JOHN J. SPARKMAN,

NEW YORK CITY HOUSING AUTHORITY,
New York, N.Y., October 18, 1971.

Chairman, Senate Banking and Currency Committee,
Washington, D.C.

DEAR SENATOR SPARKMAN: I regret that I was unable to appear personally before your Committee to testify on housing legislation. The hearing calendar already was closed when I attempted to arrange a date upon which I could present testimony.

I am writing to you because I feel that certain housing legislation absolutely is necessary to be enacted by the Congress this year with respect to the public housing program. I am submitting this statement in the hope that it will receive serious consideration by you and the members of your Committee, whether or not it is made a part of the formal record.

Before setting forth the few legislative proposals which I feel are critically needed this year, I should like to comment briefly on the proposals which have been before your Committee for comprehensive revision of the existing housing program of this nation. The Administration Bill (S. 2049) titled "Housing Consolidation and Simplification Act of 1971" regretfully is far from simple, nor does it provide for a consolidated housing program which fills the gaps which presently exists in our porgrams to meet the needs of the ill-housed citizens of the nation. This bill is substantially the same as that which the Administration submitted for consideration by Congress last year, and it suffers from substantially the same defects. I am convinced that its adoption would seriously damage the public housing program and the low-income families now being served by it. I discussed the more serious defects of the Administration Bill last year when I appeared before your Subcommittee on Housing and Urban Affairs.

HR. 9688 which was developed by the House Committee on Banking and Currency also is far from simple and fails to provide a program which can serve all segments of the population, without large gaps, who cannot afford to obtain housing of acceptable standards in the open market. Furthermore, it proposes to introduce a number of totally untested policies which may not be effective in implementing a housing program.

Having heard testimony before your Committee regarding the foregoing proposals, I believe that you will agree with the opinion of most housing officials that none of the proposed comprehensive housing reform plans has as yet been developed sufficiently to merit action by Congress. The United States Housing Act, on the other hand, reflects the best thinking of many distinguished elected representatives over the past 30 odd years and has demonstrated its uitility both in the production and operation of low-rent housing. The members of your Subcommittee can take jutifiable pride in the notable improvements which they helped formulate and enact into the law during the past few years. I recommend continuation of present public housing statutes with the few amendments specified below in preference to any of the proposed substitute legislation which has been submitted for your consideration.

The amendments to the existing Housing Act which I feel now are necessary and which I recommend for adoption at this session of Congress with respect to the public housing program are as follows:

1. AUTHORIZATION OF FUNDS TO CONTINUE PROGRAM

Section 10(e) of the present Act sets forth the maximum authorization for contracts for annual contributions to be executed by the Secretary of HUD in aid of low-rent public housing. The sum of $225 million is authorized for contracts to be executed in the fiscal year started July 1, 1971. No funds are authorized thereafter.

We urgently need authorizations to continue operations beyond June 30, 1972. These must be adopted in the present session of Congress if we are to avoid a hiatus because of the lack of any authorizations when next summer arrives. Such hiatus would cause long and costly delays in construction. It would force local authorities to halt construction and subsequently to completely retool and reconstitute their staffs when new funds become available.

I earnestly urge that at this session your Committee adopt authorizations for at least three additional fiscal years. This will give localities the assurance of a continuing program and enable them to proceed systematically with the timeconsuming business of selecting sites and preparing plans for projects to be funded by contracts executed in future years. On the basis of the 10 year housing goals adopted by Congress in 1968, funding should be authorized at a rate of between $350 million and $400 million per year.

2. SUBSIDIES TO HELP MEET OPERATING COSTS

Congress in 1969 recognized the need to modernize the subsidy formula for public housing. It passed the Sparkman Amendment and the Brooke Amendment to make subsidies available to localities to help maintain public housing projects in sound condiiton, while keeping rents at levels that low-income families can afford to pay. In 1970 Congress increased the amount of subsidy available for operating costs to a level of $150 million.

These new operating subsidies have been of tremendous help. Most localities can now maintain their projects in reasonable condition. The threat of bankruptcy which faced so many authorities, particularly those in larger urban centers, has been eliminated.

The authorization of $150 million now provided by statute is just about sufficient to meet the needs of the program during the current fiscal year. These authorized funds, however, will not suffice to cover the needs of additional projects as they become ready for occupancy upon completion of construction, nor will the funds be adequate if the operating costs of existing projects increase. This threat to the maintenance of public housing projects in sound condition should be eliminated. I urge that your Committee approve an increase of $100 million in the amount of funds authorized for operating subsidies.

3. SECTION 23 LEASING

This ingenious method for increasing the supply of decent low-rent housing hase proved to be a valuable tool. In New York City we have made the leasing program an integral part of the City's overall housing program. It has been built into our City Mitchell-Lama middle-income housing program financed with City mortgages and tax exemptions by requiring potential developers to reserve a stipulated portion of the newly constructed units for Section 23 leasing by the

Housing Authority. The City is following the same practice in its Municipal Loan Rehabilitation Program financed with City loans and tax exemptions.

During 1970 HUD cut back very sharply on funds allocated to the leasing program. The cut back of funds was so severe that this Authority was prevented from taking occupancy of units which private developers had built specifically for leasing by the Authority. The local authorities were compelled to ask Congress for remedial legislation. Congress in the Act of 1970 adopted Section 203 mandating that at least 30% of the annual contributions contracted in any fiscal year was to be for leasing units pursuant to Section 23 of the Act.

Since adoption of this mandate by Congress, HUD has swung from its restrictive position of last year to the other extreme. It insists that Section 203 of the Act of 1970 requires that 30% of all funds allocated to local authorities, including operating subsidies for existing projects as well as contracts for new projects, must be applied to Section 23 leasing. This extreme position certainly does not conform with the intent of Congress, which basically sought merely to prevent the agency from cutting the leasing program out of existence, and is seriously damaging the potential of local authorities to build new housing. Further clarification by Congress now is necessary to correct this situation. I strongly urge that, either by statutory amendment or by report language, Congress make clear the fact that it intends that the 30% reservation of funds for Section 23 leasing applies only to funds contracted annually for new projects. With appreciation for past courtesies extended both by you and your very capable staff director, Carl Coan, I remain

Sincerely yours,

SIMEON GOLAR, Chairman.

Hon. JOHN S. SPARKMAN,

THE AMERICAN INSTITUTE OF ARCHITECTS,

October 25, 1971.

U.S. Senate, Washington, D.C. DEAR SENATOR SPARKMAN: The American Institute of Architects supports legislation to replace the present fragmentary Federal effort toward housing and community development with a coordinated, comprehensive approach that deals effectively with all their interrelated elements.

In our judgment, the proposals now pending before the Subcommittee on Housing form a framework within which the necessary reform and restructuring can be accomplished. I am enclosing a copy of a statement on Housing and Community Development Legislation presented by Robert F. Hastings, FAIA, President of The American Institute of Architects, to the Senate Housing Subcommittee, which outlines the recommendations of the Institute. The document emphasizes the need for incentives for local and state governmental reform, postconstruction evaluation of Federally-assisted housing, metropolitan coordination of housing, transportation and community development programs, consistency of Federally-assisted projects at the local level with national growth policies, and the opportunity for community-based design and planning organizations to be able to participate fully in Federal programs.

In addition, I am enclosing a copy of a statement on the Building Sciences Act of 1971 presented by Robert J. Piper, AIA, AIP, in which the Institute, joined by other design professions, expresses support for the creation of a National Institute of Building Sciences. We do urge that the design professions be included on the Institute's Board of Directors and that the technical findings of the organization not be initially mandatory for use in Federal construction programs or other projects involving Federal assistance.

We hope that you will favorably consider these recommendations when the Subcommittee reviews the pending legislation.

Yours truly,

THOMAS P. BENNETT, Director of Congressional Relations.

(The two statements referred to in this letter were submitted to the committee at an earlier date and may be found at pages 1209 and 1283 of this volume.)

о