to $5 per square foot) for housing, inevitably leads to crowding on the land. Again, we offer no panacea, yet are unwilling to accept the thought that "someone", Uncle Sam perhaps, owes the owners of such land their own estimates of its value. I believe that only long and arduous education will mitigate this picture. Leadership, even moral leadership, from the Congress would do much to help modify the instincts of the human animal. Reduction of building costs has been referred to earlier in this letter. I believe that all elements of the construction industry are earnestly attempting to achieve reductions wherever possible. We do not anticipate changes of sufficient magnitude to materially affect the housing position. Public housing is being bitterly opposed by "home builders" on the ground of the subsidies necessary to prodce and maintain it. These opponents do not admit the existence of "subsidies" in their own housing operations, yet they are very largely dependent upon provision at the expense of the public or the utility company of streets, water, sewer, light and other utility and public-service installations and activities. There are important instances in which these installations have been made, at the behest of private interests which have never used them, in many square miles of virgin territory where ill-conceived developments have been abandoned. Such operations undertaken in ignorance of, or in spite of, intelligent regional planning, can but constitute a general burden of increased cost upon housing. The Congress can do much, psychologically and financially, to encourage the good planning which can prevent such waste. The cost of operating and maintaining an individual home or a group of houses is very definitely influenced by the quality of the materials and the methods of construction by which they are created. Manufacturers of materials, some builders, many architects and engineers devote a great deal of time and study to the perfection of, and selection of, long-lasting products and methods. Study and analysis and advice in this field as applied to housing might be considered a proper function of a Federal agency concerned with housing. On fixed charges and profits we have no comment to offer. Within the corporate limits of cities, there is very little evidence that equity funds will be available due to the uncertainty of what the city ultimately will be and the lack of concerted movement by the citizens to create better and more stable conditions. It is a fair statement that there is very little equity money available for in-town construction, because of the fact that the cities are in such condition as to make the investment of capital very uncertain. Encouragement of intelligent planning in metropolitan areas could change this picture quickly. The intermittent character of construction operations is due to (a) the general economic picture, nationally and locally; (b) climate. The first has been commented on above. As to the second, construction is genuinely controlled by climate in these sections where extremely cold weather actually prohibits building during from 2 to 5 or 6 months of the year; the cost of modern methods of overcoming cold weather would, generally, be prohibitive in residence construction. In milder sections, lack of continuity of construction is probably due to long-established habit-of-mind-to the mere fact that sap rises in the spring. Perhaps this can be overcome by a general campaign of education and encouragement. Labor has a real and important stake in this problem; witness their agitation for a yearly wage for construction. The high hourly rates necessary to give construction mechancis even a modicum of the annual income to which their skills should entitle them, is one of the factors tending to keep high the costs of homes. I am confident that the architectural profession will support every soundly conceived method of improving this situation. I believe restrictions on construction operations fall into three classes: (a) Those due to legal controls, such as zoning ordinances and building codes, and negatively, perhaps, to pusilanimous use of the police power in the public interest. (b) Those due to restrictive price agreements and the like. (c) Those due to activities of organized labor, such as limitation of apprenticeships and basicly unreasonable jurisdictional determinations. Zoning is pretty intimately tied up with the broad planning referred to earlier in this letter; active and intelligent planning will soon iron out unreasonable zoning difficulties. Codes are in serious need of modernization and the American Standards Association together with many important elements of the construction industry, including the American Institute of Architects, are already engaged in a campaign with this in view. We believe that existing law is sufficient to control the price situation mentioned. Curing the obvious ills of labor habit as it affects construction is a large order. We believe it will take place naturally as labor comes of age; we begin to hope that its adolescence has been hastened by the war. The whole tax structure of the country should be overhauled at the Federal, State, and local levels. With respect to local taxation, the fact that most of the revenue for cities comes from real property taxes is a real danger to our communities. Examination of the portfolios of real-estate brokers in many of our cities will indicate the serious condition existing with respect to taxes on real property. This should lead eventually to a wholesale demolition of much undesirable property, which would ultimately permit the fuller utilization of land and the creation of new structures in less crowded surroundings, thus insuring better light and air to the occupants. This organization is not yet prepared to make specific recommendations for desirable legislation. As mentioned previously in this letter, it is opposed to the thought of huge Federal appropriation for federally owned and operated_public housing, except perhaps as a last resort in economic depression, or for Federal redemption of worn-out real estate. It is in favor of Federal encouragement of local planning-of local courage in the use of the police power for condemnation of unsafe and insanitary buildings and for intelligent zoning and land use control. It conceives that this encouragement should be by way of a general reconstruction of the tax system, rather than by grant of funds, in order that local initiative may be revived, along more public-spirited lines than in the past. It hopes that the power and prestige of your committee may be able to succeed, where so many others have failed, in putting before the public the truth about public housing, so that the problems involved in this term may be judged in the light of fact rather than by clichés snatched at random from the welter of invective and counterclaim which has characterized the subject since its beginnings. The American Institute of Architects and its many individual members who have real knowledge of housing are ready to cooperate with you in every way which may be helpful in clarifying the history of its past and in charting its course for the future. Please call on us. Very sincerely yours, D. K. ESTE FISHER, Jr., Washington Representative, American Institute of Architects. CITIZENS' HOUSING COUNCIL OF NEW YORK, Inc., Mr. MEYER JACOBSTEIN, Special Committee on Post-War Economic Policy and Planning, Senate Office Building, Washington, D. C. DEAR MR. JACOBSTEIN: In reply to your letter of February 1, written at the request of Senator Taft, enclosed is a copy of a report prepared by the subcommittee of the Citizens' Housing Council of New York, which sets forth its views on housing. This report was prepared at the request of Senator Taft and submitted to him in October 1944. We believe it has had the consideration of the subcommittee and should like it incorporated into the official record of the public hearings. We are sending, under separate cover, seven additional copies for the members of the Subcommittee on Housing and Urban Redevelopment. We should appreciate receiving copies of the hearings as soon as they are printed. Sincerely yours, JOSEPH ORendorff. (For Harold S. Buttenheim, President.) VIEWS OF CITIZENS' HOUSING COUNCIL OF NEW YORK SUBMITTED AT THE REQUEST OF THE SUBCOMMITTEE ON HOUSING AND URBAN REDEVELOPMENT OF THE UNITED STATES SENATE COMMITTEE ON POST-WAR ECONOMIC POLICY AND PLANNING A. ORGANIZATION OF THE FEDERAL AGENCY (1) All housing and urban redevelopment functions should be consolidated in a single permanent agency. As a wartime measure, all the Federal agencies concerned with the housing and home-financing program are consolidated by Executive order into the National Housing Agency. There are many reasons why this pattern should continue in the post-war period. The Congress should consolidate all housing and urban redevelopment functions in a single permanent agency, rather than establish separate agencies for particular functions. First, coordination of related activities will be more effectively developed if managerial responsibility is concentrated in the hands of a single agency with power to effectuate consistent policies as to the entire housing and urban redevelopment program. Although the program will include various technically distinguishable activities, their focus must inevitably be in the carrying out of a general over-all program as defined legislatively by the Congress. Coordination at the top is essential to assure that administration of the different activities will be animated by this single objective. A single agency can prevent one or another activity from getting out of line with the congressional program more effectively than can the individual heads of autonomous agencies. Second, the establishment of a single agency responsible for executing all aspects of the program will reduce the likelihood of jurisdictional disputes among the administrators of the various activities. This reason needs little elaboration. Experience has, indeed, demonstrated the importance of avoiding duplication and overlapping for effective administration of closely related programs. In a program so vital, economically and socially, to post-war reconstruction, it is imperative to create an administrative pattern which will so far as possible stimulate the teamwork and efficiency essential to the realization of congressional policy. Third, the Congress can more certainly hola a single agency accountable for the correct and efficient implementation of its program than it can a number of independent agencies. Failure or success in carrying out the program will, therefore, be more quickly and more specifically apparent. Again, the Congress will be more capable of assessing accurately the achievement of the purposes of its program if the program as a whole can be viewed as a coordinated administrative operation. Congressional action to modify or extend the program will thus be based upon a broad perspective of the entire field of housing and urban redevelopment rather than upon judgments as to the efficiency of single segments of the program. Fourth, the creation of a single agency with over-all responsibility for administering a national housing and urban-redevelopment program will facilitate effective executive supervision. It is becoming increasingly important to correlate all separate functions and activities within such a broad field as this at the executive level. Only then can there be any assurance that the President can deal precisely and energetically with the ultimate issues of administrative policy for which he is finally responsible. None of the foregoing should be construed as a recommendation of centralized administration at the national level of the details of local programs. Quite the opposite seems, in fact, the more desirable pattern. There should be a maximum of flexibility in administration from the standpoint of Federal-local relations. Delegation to local housing authorities of power to plan, construct, and operate housing and redevelopment projects, within the national standards established by congressional sanction, should be implemented in the statute. 1 (2) The agency should be known as the Department of Housing and Urban Redevel opment, or by a similar name denoting its function. (3) The agency should be headed by a single administrator rather than a board. Good administrative practice requires a single responsible executive for any enterprise. The only occasion for a board to act as the head of an agency is the need of deliberation or representation of different interests in the performance of quasi-judicial or quasi-legislative functions. Even in such a case the board should act through a single responsible executive under its supervision. In this case the general policies should be laid down in the act by the Congress and the judicial and policy-determining aspects of the agency's administration will be no more serious than those of any regular department of the Government. With a single administrator there can be no "passing the buck" in the development and execution of a program. Expeditious action will not be blocked by clashes of personality or the necessity of corralling votes for each decision. Competing claims of different aspects of the program will be decided on a uniform basis instead of by jockeying for position. The President, the Congress, and the public will be able to hold a single person responsible for results and to improve the situation by the simple expedient of getting a better man if the vital public service intended is not being efficiently rendered. (4) The agency should be an executive department with representation on the Cabinet. The strategic and enormous needs and possibilities of a program of housing and urban redevelopment in our post-war economy demand that the administrator of the program have the status of a Cabinet officer. This is a program that will be heard from. It is bound to have great significance in the economic reconstruction of the country after the war, both immediately and permanently, and its importance in terms of social policy is far reaching. There are many specific advantages to be gained from the presence of the program's administrator in the Cabinet. For example, it would facilitate the President's and the Nation's understanding of the congressional program of postwar reconstruction as an integrated whole. In addition, it would provide unusual and useful opportunities for an exchange of ideas among other members of the Cabinet whose responsibilities are related to the program. The status of the agency as an executive department and the Cabinet status of its administrator, or Secretary, would serve to bring home to the public and to all agencies of Government a realization of the importance of the program of housing and urban redevelopment. (5) The administrative sections of the statute. Legislation should not incorporate detailed provisions as to either administrative structure or operating techniques. These elements of effective administration can, however, be enhanced by a clear definition of legislative objectives and by broad statements of the administrative functions to be performed. A single law encompassing all Federal functions of housing and urban redevelopment would of course be the ideal legislative pattern. To this end, the Congress may well consider the consolidation of all related laws in this field. With respect to such a general housing and urban redevelopment statute, it will be important to establish clearly the over-all public policy which the statute is designed to serve. Such a statement of policy should include reference to all aspects of the congressional program. It should be drafted in terms broad enough to grant the administrative agency the necessary powers, and precise enough to give it direction in the performance of its functions. The major functional divisions of activity should also be specified in the statute as follows: I. Public housing. II. Financing and insurance. III. Urban redevelopment. The character and limits of each function might well be defined in the statute with the framing of details of administrative organization and procedure delegated to the administrator. It would be wise to state clearly the allocation of existing agencies (powers, personnel, property) to each of the foregoing functional divisions established as follows: I. Federal Public Housing Authority. II. Federal Home Loan Bank System, Federal Savings and Loan Association, Federal Savings and Loan Insurance Corporation, Home Owners' Loan Corporation, Federal Housing Administration, RFC Mortgage Company, Federal National Mortgage Association. III. (No existing agencies perform this function). B. PUBLIC HOUSING The Federal program of aid for low-rent housing, whereby subsidy is provided in some form to make up the difference between the rent required to meet all charges and expenses and the rent the rehoused family can afford to pay, was inaugurated principally as an emergency measure. The program had its beginnings in 1933, when the Public Works Administration was given public housing functions at least as much for the purpose of increasing construction to alleviate the depression, as for the purpose of meeting the needs of low-income families. In 1937, however, the public housing function of Government was established on a permanent basis in the United States Housing Authority, which later became the Federal Public Housing Authority of the consolidated war agency, the National Housing Agency. The Federal Government has had a decade of successful experience with slum clearance and public housing. There has, of course, been resistance by certain private real estate interests. This resistance has recently crystallized into specific proposed substitutes for the public housing program, notably the issuance of relief in the form of rent certificates to slum dwellers. Such a proposal obviously would not clear the slums; in fact; it would entrench them, by speedily enhancing their profit. Tremendous Federal outlays would simply be siphoned into the pockets of the slum owners, without the building of a single new decent home. In addition, families otherwise self-supporting would have to subject themselves to the humiliation of applying for rent relief. Such proposed alternatives, upon analysis, bring into even sharper focus the merits of the current housing formula. The only sensible view is that the Federal Government's tried and proven program of aid to low-rent housing under the United States Housing Act should be maintained and developed to adequate proportions. (1) Additional appropriations by Congress are essential. As of December 31, 1942, $759, 101, 000 of the $800, 000, 000 appropriated by the Congress for low-rent housing and slum clearance was committed by contracts with local housing authorities. Senate Introductory 591 (76th Cong., 1st sess.) would have provided an additional appropriation of $800,000,000. On the basis of census figures and other reliable data, the present accumulated need for publicly assisted rental housing may be estimated as in the neighborhood of at least 3,000,000 units over a decade. Thus an appropriation of $800,000,000, which might at present prices and prewar income levels provide at most 200,000 dwelling units, would be minimal for commencement of the post-war program. Actually, the estimated needs warrant the appropriation of a far greater amount. (2) The United States Housing Act should be amended— (a) To modify the requirement of "equivalent elimination" of substandard dwellings as a prerequisite to the construction of federally aided housing units. The present "equivalent elimination” provision of the United States Housing Act, whereby new housing units must be matched, one by one, against the elimination of existing substandard units, is not keyed to a broad concept of slum clearance. It would be far more consistent with the objective of the program to demolish or rehabilitate an entire predominantly substandard area, even if there happen to be fewer dwelling units in the particular substandard area than there will be in the related new project. Moreover, an "area clearance" approach, rather than a "spot |