and departments, it is certainly our opinion, that the secretary of a department which itself included most of the basic direct functions in this field would have much more effectiveness and weight in that coordinatinng role than a staff person at the White House.

Second, with respect to the equally important function, as we see it, of the Secretary of the Department, of promoting coordination in the field with State and local governments and private groups, in our opinion this could not be done with effectiveness by a White House staff officer.

AREA REDEVELOPMENT ADMINISTRATION PROGRAMS

Senator RIBICOFF. Many of the functions of the Area Redevelopment Administration appear to parallel those of their various programs in HHFA. Do you think ARA should be transferred to the proposed Department?

Mr. KEITH. I would say on that, Mr. Chairman, that in our opinion there certainly is a close parallel in the functions. At the time the ARA legislation was originally proposed, our organization recommended that it be incorporated in the Housing and Home Finance Agency. Assuming that the ARA program is going to be a continuing program and I gather that has not been determined by Congress yet— but if it is, I would say that we think it would be quite logical to include that program with its loan and grant activities which are very similar to those in HHFA in this proposed Department.

Senator RIBICOFF. In other words, if we are really going to reorganize, let us try to avoid as much duplication as we can. Mr. KEITH. That is correct, I would agree.

COLLEGE HOUSING PROGRAM

Senator RIBICOFF. Now, along the same line, on page 3 you mention college housing. Is this not basically a college dormitory construction program? Should college housing be in this new Department or should college housing go into the Office of Education in HEW where they handle all the problems that have to do with construction of college facilities? Should college housing be in this Department or should college housing be in the Office of Education?

Mr. KEITH. Well, I could see, Mr. Chairman, some logic in associating the various educational programs in one department. It is my recollection that the reason for placing the college housing loan program in the HHFA in the first instance was primarily a financing reason, the familiarity of the HHFA with the type of financing that is involved in the college housing loan program.

Senator RIBICOFF. With the new education laws going through and already passed the Office of Education already has this experience. It does the financing, of construction of college facilities now.

What again worries me is the proliferation of the same type of activity and program throughout the Government. We have not made up our minds, but I just want to get your reaction as an experienced man in this field.

Mr. KEITH. As I say, Mr. Chairman, I can see logic in associating like programs in the higher education field under one direction.

EXHIBIT 19

[Source: "Impact of Federal Urban Development Programs on Local Government Organization and Planning," Subcommittee on Intergovernmental Relations, Senate Committee on Government Operations, 88th Cong., 2d sess., May 30, 1964 (committee print).]

K. COLLEGE AND HOSPITAL HOUSING LOANS

DESCRIPTION OF PROGRAM

Title IV of the Housing Act of 1950, as amended (12 U.S.C.A. 1749), authorizes Federal loans for the purpose of financing the construction, rehabilitation, or purchase of housing and related facilities for student and faculty of institutions of higher learning, and housing for student nurses and interns at approved hospitals with teaching functions. The program is administered by the Community Facilities Administration (CFA) of the Housing and Home Finance Agency. Net loan reservations made in fiscal year 1963 amounted to $288.5 million.

COORDINATION WITHIN THE FEDERAL GOVERNMENT

CFA maintains formal relationships with: (1) The Office of Education, which certifies the eligibility of educational institutions for housing loans; (2) the Public Health Service, which coordinates housing loans to hospitals with the HillBurton hospital construction program; and (3) the Federal Housing Administration, which determines the need for housing for married students and faculty under the CFA program.

EFFECTS ON THE ORGANIZATION OF GOVERNMENTS IN AREAS RECEIVING AID

Types of units affected.-Section 404 (b) of the above law authorizes loans to public and private nonprofit institutions of higher learning, or to nonprofit corporations, student housing cooperatives, and State agencies established for the purpose of providing student or faculty housing.

Area of jurisdiction. The geographic jurisdiction of partipicating local agencies or institutions is whatever has been established under State law.

Cooperation between jurisdictions. No effort is made to either encourage or discourage the joining together of individual units into larger, more comprehensive units. Where they have been joined, as in some State university system, there is no penalty.

EFFECTS ON STATE AND LOCAL GOVERNMENTAL PLANNING PROCESSES

Functional and comprehensive planning.-CFA requires consistency with State and local plans to the extent necessary to comply with State or local laws and ordinances. This requirement is put in the loan agreement. If the loan applicant is a college or university, CFA representatives strongly urge the applicant to develop a long-range master plan for campus development. Long-range planning is encouraged by financing arrangements which man be made under a "planned schedule of construction" rather than a project-by-project approach. Partially as a result of the college housing program, public and private colleges have been getting together to assess their respective roles in meeting future demands for enrollment. This as least a rudimentary form of functional planning for higher education facilities.

Relation between planning and action programs.—The legal supplement to the loan application requires a certification that all required State and local approvals and permits have been or will be obtained. Many of the projects under this prorgam are in urban renewal areas and are covered by the workable program and other requirements under the urban renewal procedures. Otherwise this loan program has no special requirements of its own for reviews or approvals from State and local agencies having related planning or operating responsibilities.

Federal review of planning.-The only Federal concern for the adequacy of State and local plans is for the soundness of the individual project. A site inspection is made and contacts are maintained with URA and FHA to determine soundness in relation to renewal plans and the mortgage market. There is special concern with review of the college or university master plan where one exists, but very little Federal concern with the comprehensive community plan.

EVALUATION OF ORGANIZATION AND PLANNING REQUIREMENTS

The current administrative persuasions on behalf of long-range campus planning and public-private enrollment planning testify to the desirability of such activities. These activities are important in replacing a project-by-project approach with a more adequate system approach. Campuses would certainly be more rationally developed if planned on a long-range basis; and enrollments can be provided for with less guesswork if the projected capacities of all institutions are considered together.

DOCUMENTATION

U.S. Community Facilities Administration, "College Housing Loans," Fact Sheet. Washington U.S. Housing and Home Finance Agency, February 1962.

U.S. Community Facilities Administration, "College Housing Program Information for Applicants," CFA-500. Washington: U.S. Housing and Home Finance Agency, July 1960. U.S. Community Facilities Administration, "Application for Loan Assistance,' " under title IV of the Housing Act of 1950, as amended. Washington: U.S. Housing and Home Finance Agency, July 1960 (including supplements 1, 2, and 3).

U.S. Housing and Home Finance Agency, "Community Facilities Manual," section 21-1-4. Washington: looseleaf, continuously updated.

"Memorandum of Agreement between the Community Facilities Commissioner, U.S. Housing and Home Finance Agency, and the U.S. Commissioner of Education, Department of Health, Education, and Welfare." Washington: May 15, 1956.

U.S. Housing and Home Finance Agency, "Community Facilities Manual," sec. 21-1-4 (Washington looseleaf, continuously updated).

ROLE OF FHA IN NEW DEPARTMENT

Senator RIBICOFF. In your opinion, would the vesting of all statutory authority for housing programs in the Secretary of the proposed department interfere with the effective operation of the FHA program?

Mr. KEITH. I would certainly say no. I see no reason to expect that it would interfere in any sense. There has been apprehension expressed in the past by some quarters that this might occur. But I think that apprehension has been voiced primarily by groups who would really prefer to see the FHA as an entirely separate and independent public agency.

On the contrary, it has always been our view that the most effective place for the FHA is within an overall coordinated and integrated program from the standpoint of meeting local housing needs.

I was interested to see, to note, Mr. Chairman, that the president of the National Association of Home Builders, I gather, testified in favor of this move, of the establishment of the Department before this committee yesterday.

ROLE OF THE STATES IN URBAN AFFAIRS

Senator RIBICOFF. The Commission on Intergovernmental Relations has made it clear they feel that the establishment of this new department does not imply any disregard or diminution of the constitutional powers and responsibilities of the States under our Federal system of Government. Do you agree?

Mr. KEITH. I would certainly say that it would not interfere with the

Senator RIBICOFF. But you see no harm in expressing this in the bill if the committee should decide to recomend the creation of such a Department. You would have no objection to including something like that, would you?

Mr. KEITH. No; I would not.

Senator RIBICOFF. And how would you feel about a clause that would state that in the discharge of the responsibilities the new Sec

retary shall consult with the Governors and other State officials from time to time with the view to encouraging and assisting the States to assume their proper constitutional responsibilities in partnership with the national and local governments in meeting the housing and urban development needs of the Nation?

Mr. KEITH. It would seem to me such a statement would be consistent with the objectives of S. 1599 as stated in the first paragraph. Senator RIBICOFF. The witness for the National Association of Realtors suggested that because of reapportionment, the States, more and more, would be taking on additional functions in the urban areas. I am not so sure of this and I do not know how long it would take. But I do know from my own experience in various forms of government that there is a basic need for overall cooperation at all levels of government.

I found as Governor that municipalities would come to the Governor's office for assistance and help with local problems. I also found that it was necessary to have all my various agency heads in the State government aware of what was needed and what was available on the Federal level so there would be cooperation, not duplication, and have the wisest and most economical use of State funds and Federal funds.

So basically I could see that there could be mutuality of assistance and help, and I would imagine that the Secretary of such a new Department would want to have close cooperation with the States and localities.

Mr. KEITH. I would certainly think so. I think the approach you have just outlined is a very sound and wise approach.

Senator RIBICOFF. In other words, if we do this, if the committee should decide to recommend to the Senate creation of such a Department, there has to be certain safeguards and certain assurances to make sure that there is this continuous cooperation and flow without any encroachment upon the constitutional rights of the States. Mr.KEITH. I would agree with that.

Senator RIBICOFF. Thank you very much. Senator Simpson?

RESPONSIBILITY FOR COORDINATING FEDERAL ACTIVITIES IN THE URBAN AREA

Senator SIMPSON. Mr. Chairman, just this question.

Mr. Keith, the June 22, 1964, report of the Advisory Commission on Intergovernmental Relations entitled "Coordination of the Federal Urban Development Program" disclosed there are 43 Federal urban development programs scattered through 5 departments and 8 independent agencies. Does your association come in contact with some of these? Have you any recommendation with respect to this?

Mr. KEITH. Well, as I indicated in my statement, Senator, it does not seem feasible to us to incorporate in one Department every Federal activity that has an impact on urban development. I think the proposal here is that the major operating programs be incorporated in a Department, but that the Secretary of the Department under the direction of the President, be given the responsibility of coordinating all the various Federal activities which have a bearing on local development in the urban area.

Senator RIBICOFF. Thank you very much, Mr. Keith, we are most appreciative. I think your organization does a fine job. There are so many organizations operating in your field, it would seem to me that your group does coordinate much of the thinking. I am aware of the good work it does. Thank you very much.

Mr. KEITH. Thank you very much, Mr. Chairman.

Senator RIBICOFF. The next witness is Mr. Matt Triggs, representing the American Farm Bureau Federation.

STATEMENT OF MATT TRIGGS, REPRESENTING THE AMERICAN FARM BUREAU FEDERATION

Mr. TRIGGS. Thank you very much.

My name is Matt Triggs, assistant legislative director for the American Farm Bureau Federation, with offices in Washington.

The American Farm Bureau is a general farm organization of 1,647,000 families located in all of the States except Alaska, members of 2,750 county farm bureaus.

We welcome the opportunity to present the views of the American Farm Bureau Federation relating to proposals to establish a Department of Housing and Urban Development.

From time to time in recent years support has developed for the creation of various new departments-a Department of Transportation, of Natural Resources, of Veterans' Affairs, of Science and Technology, of Education. We do not see anything in the present proposal, that is, S. 1599, which indicates any more reason for a new Department of Housing and Urban Development than for the creation of other departments suggested above.

The implication involved in the proposal for the new department is, however, of major concern to us.

FEDERAL ROLE IN URBAN AFFAIRS AND HOUSING

The implication is that the Federal Government is going to perform a much larger role in the future than it has in the past with respect to what appears to us to be primarily a private and a local responsibility-the planning and development of municipalities and the financing of such development.

We are impelled to this conclusion in part by reading "The Urban Complex," by HHFA Administrator, Robert C. Weaver. Mr. Weaver sets forth a comprehensive program of Federal responsibility for urban development most concisely capsuled by this question

Originally this Nation was developed largely by offering people absolute control over wide areas to facilitate the rapid improvement of the land. Now we are trying to recover control of the way land is used so as to achieve a proper type of development of our urban areas and of our whole country. * * * Thus we seek to recapture control of the use of land, most of which the Government has already given to the people.

The implication that the Federal Government is intended to take on an expanded and primary responsibility for local planning is indeed borne out by the new housing bill, S. 1354.

We recognize that S. 1354 is in the jurisdiction of another committee. But S. 1354 and S. 1599 are companion measures. S. 1354 takes giant strides to expand Federal authority for urban development.