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A p r i l 10, Chairman E c c l e s I m i l e Despres Attached i s a memorandum on r e h a b i l i t a t i o n o f r e s i d e n t i a l areas prepared a t my s u g g e s t i o n by R. R. F o s t e r of t h i s Division. Foster p o i n t s out t h a t a r e h a b i l i t a t i o n progran. p r e s e n t s wore d i f f i c u l t problems o f organization, c o o r d i n a t i o n , and f i n a n c i n g than does the c o n s t r u c t i o n of new d w e l l i n g s . Nevertheless, s i r n s of increased interest and a c t i v i t y i n t h i s f i e l d are m u l t i p l y i n g . Even though r e s u l t s a t f i r s t might be p a i n f u l l y slow, the Federal Government could do much t o encourage and f a c i l i t a t e r e s i d e n t i a l r e h a b i l i t a t i o n work. What i s most needed, perhaps, i s a r e v e r s a l of the USHA's a f f i r m a t i v e h o s t i l i t y towards r e h a b i l i t a t i o n p r o j e c t s . The l o c a l housing a u t h o r i t i e s , which are dominated by USEA, are s t r a t e g i c a l l y placed t o develop comprehensive r e h a b i l i t a t i o n p r o j e c t s , and s t a t u t o r y a u t h o r i z a t i o n e x i s t s f o r using UbUA funds f o r t h i s purpose. I n s t e a d , however, USKA*s r e h a b i l i t a t i o n work has been n e g l i g i b l e and i t has a c t i v e l y opposed r e h a b i l i t a t i o n p r o j e c t s sponsored by others Financing f a c i l i t i e s f o r p r i v a t e l y sponsored r e h a b i l i t a t i o n p r o j e c t s are inadequate. FHA insurance p r o v i s i o n s f o r t h i s type o f l e n d i n g are needlessly s t r i n g e n t , aad p r i v a t e l e n d i n g agencies, f o r t h i s and o t h e r reasons, are h e s i t a n t t o undertake t h i s type o f f i n a n c i n g . Moreover, the d i f f i c u l t i e s i n assembling p r o p e r t i e s f o r comprehensive r e h a b i l i t a t i o n o f neighborhoods are f o r m i d a b l e , and p r i v a t e i n t e r e s t s , i f they t h i n k abgut the matter at a l l , are more a l i v e t o the obstacles than t o . j p o t e n t i a l i t i e s . An a c t i v e promotional campaign undertaken simultaneously by several Government agencies, combined w i t h more l i b e r a l FHA insurance p r o v i s i o n s , might do a good deal t o awaken p r i v a t e lenders and business i n t e r e s t s i n v a r i o u s communities t o the p o t e n t i a l i t i e s i n t h i s l i t t l e - e x p l o i t e d f i e l d Attachment REHABILITATION OF RESID iHTIAL AREAS By 8* R* Foster SUMMARY Current s i t u a t i o n Rehabilitation of r e s i d e n t i a l areas o f f e r s one of the most important opportunities today* A v e i l coordinated program could r e sult i n increased construction a c t i v i t y , provide sound outlets f o r i d l e funds, and raise the standard of housing for a large number of families at l e v unit costs* Rehabilitation can be carried on i n r u r a l as v e i l as urban areas and v i t h varying degrees of private and public p a r t i c i p a t i o n * Like nev r e s i d e n t i a l building, r e h a b i l i t a t i o n i s very such a local problem, yet the Federal Government can help i n stimul a t i n g a msTimuii of private investment i n t h i s f i e l d , v i t h present l e g i s l a t i o n and at vary l i t t l e cost* Of the 18,000,000 urban dwelling units* 2,500,000 are indicated by recent surveys as needing major repairs and over 400,000 are u n f i t for use* Many of these can be repaired and restored at a fourth t o a h a l f of the cost of new construction. Also* a considerable portion of the 8,000,000 of the dwellings needing minor repairs can be repaired* Rehabilitation can include such more than the repair and modernisation of dwellings* I t can mean r e h a b i l i t a t i o n o f whole neighborhoods i n which street realignment, creation o f park spaces* rescuing, and adjustment of taxes go along with repair and improvement of the houses themselves* There have been numerous agencies sponsoring nev private r e s i d e n t i a l building and, more r e c e n t l y , publicly-financed a i m clearance, but there has been r e l a t i v e l y l i t t l e done toward promoting a comprehensive r e h a b i l i t a t i o n program* Since 19S4 the Federal Sousing Administration has insured* up t o 10 per oent, repair and improvement loans under T i t l e I on individual properties* and nov w i l l insure leans on groups of 16 or more properties under T i t l e I I * See* 207 ( r e n t a l housing) where the construction amounts t o at least 50 per cent of the amount of the loan* The rates end terms an both these types of loans are not as favorable as they should be* Local housing a u t h o r i t i e s have been set up i n some 500 c i t i e s but so f a r have done p r a c t i c a l l y no r e h a b i l i t a t i o n work exoept i n connection v i t h the "equivalent elimination" provisions of the U* S* Housing Act • Lending i n s t i t u t i o n s generally have been reluctant t o loan for r e h a b i l i t a t i o n * A few i n d i v i d u a l s hare undertaken r e h a b i l i t a t i o n work, but t h e i r operations have been r e l a t i v e l y H a l t e d exeept i n t h e ease of Arthur W* Binns • His s f f o r t s over 10 years have r e s u l t e d i n the r e p a i r end remodeling of some 500 dwellings i n P h i l a d e l p h i a which he r e n t s t o negroes a t from #3 t o $5 per roesi per month* w i t h no Government subsidy* The n a t i o n a l Association of Real Estate Boards has a committee, w i t h Binns as chairman, which i s urging l o c a l r e a l e s t a t e groups t o launch r e p a i r and improvement programs w i t h p r i v a t e f i n a n e i n g i some of these are g e t t i n g under way* Program Federal agencies through a concerted program can a s s i s t i n overcoming two b i g obstacles i n the way of r e h a b i l i t a t i o n work, ( a ) inadequate f i n a n c i n g and (b) lack o f means f o r coordinated a c t i o n by l o c a l groups involved i n b l i g h t e d and slum areas—hose owners, l e n d ing agencies, and c i t y a u t h o r i t i e s * The Federal Housing Administration should be induced t o sake even more l i b e r a l the terns on insured loans f o r r e p a i r and improvement work* Many o l d p r o p e r t i e s i n established neighborhoods when repaired and remodeled are as good s e c u r i t y as much of the s p e c u l a t i v e l y b u i l t new construction* A l s o , FHA should push t h s p r o gram more aggressively by a c t i v e promotional work, p a r t i c u l a r l y i n f i e l d o f f i c e s d i r e c t l y i n touch w i t h lending i n s t i t u t i o n s * The Home Owners* Loan Corporation should expand t o other c i t i e s immediately i t s very valuable program f o r carrying out neighborhood r e h a b i l i t a t i o n p l a n s , such as t h a t f o r the 38-block Waverly p r o j e c t i n Baltimore* Since most of t h e l o c a l housing a u t h o r i t i e s are ( u n f o r t u n a t e l y ) l i t t l e more than s u b s i d i a r i s s of t h e United States Housing A u t h o r i t y , and know l i t t l e e l a e than what USHA t e l l s them, the l a t t e r agensy should be persuaded or required t o a l t e r i t s negative p o l i c y i n regard t o r e h a b i l i t a t i o n snd a c t i v e l y sponsor i t * The l o c a l housing a u t h o r i t y can be t h e f e e a l agency i n a c i t y f o r c a r r y i n g out a broad coordinated program but w i l l not do so t o any extent unless USHA* s present a t t i t u d e i s r a d i c a l l y changed* The Federal Heme Loan Bank Board, Federal Deposit Insurance Corporation, snd t h s Federal Reserve System can a i d by bringing t o t h e a t t e n t i o n o f t h e i r members ways i n which they can e f f e c t i v e l y t a k e p a r t i n l o c a l r e h a b i l i t a t i o n programs t o prevent spread of b l i g h t , provide b e t t e r housing a t minimum costs, and protect t h e security behind t h e i r loans and r e a l e s t a t e holdings i n troublesome areas* There should be continued pressure on a l l lending i n s t i t u t i o n s t o recognise t h e p o s s i b i l i t i e s , i n f a c t i n some instances ths n e c e s s i t y , f e r making r e h a b i l i t a t i o n loans en more favorable terms* The opportunity i n rehab i 1 i t at i on i s a large one • I t o f f e r s even more d i f f i c u l t problems than new r e s i d e n t i a l building, but interest i n the subject i s increasing and i t appears that much private investment can be stimulated i n the near future by action through established agencies, both local and Federal* URBAN REHABILITATION Background o f problem Moat of the current interest and promotional a c t i v i t y i n housing i s along two lines* (a) New private construction* primarily t o house an increasing or s h i f t i n g population, at an average cost of $5,000 or less per unit including lands (h) new public construction, whieh replaces slums at about the same average cost per unit • 1 / Such public construction does not add t o the number of units available, as an equal number of slum imits are demolished* Relatively l i t t l e has been done as yet by e i t h e r private or public agencies about the important f i e l d of r e h a b i l i t a t i o n , i . e . , the r e p a i r , modernisation* and improvement of houses or even whole neighborhoods now i n poor condition* This work often can be done at from 1500 t o #2*000 a unit i n c i t i e s * I n many, but net a l l , instances, r e h a b i l i t a t i o n results i n a net addition t o the housing supply* I f only 1 per cent of the valuation of r e s i d e n t i a l properties were spent annually f o r repairs and improvements, i t would mean an expenditure of nearly a b i l l i o n dollars a year* Actual expenditures f o r repairs and modern!sat ion work have averaged considerably less than t h i s * i n spite of the stimulus of a t o t a l of nearly a b i l l i o n d o l l a r s of T i t l e I repair leans insured by PHA since 1934* and FHA*s extensive promotional work* Considering that more than 80 per cent of a l l dwelling units i n the country are frame construction* adequate painting and repairs would appear t o require more than 1 per cent of the value per year* I t can probably be stated as a truism t h a t f o r a large portion of our housing plant the owners have never spent enough t o keep i t i n proper repair* l e t alone modernise i t * Banks and other i n s t i t u t i o n s holding mortgages on properties i n blighted or slum stress should, of course, be interested i n ways and means of arresting the spread of b l i g h t and bringing about improvement l / On 165 USHA projects, including 65,000 dwelling units now under construction, t o t a l development cost averages #4*880* ranging from #2,800 i n c e r t a i n Southern c i t i e s t o as high as #6,200 i n some Northern c i t i e s * with a minimum of cost. Tho Federal Government should he interested i n any a c t i v i t y which improves the housing of the country* particul a r l y for medium- and low-income families* and at the esse time increases employment and private spending* One of the chief problems i s t o coordinate the e f f o r t s of a l l agencies involved i n any l o c a l i t y t o get concerted action on a number of fronts* The recommendations made i n t h i s memorandum aim t o get such coordination* using t o the f u l l e s t extent possible* existing agencies and l e g i s l a t i o n * with a minimise of cost or administrative problems. Recent developments i n r e h a b i l i t a t i o n work There are isolated instsnoee of r e h a b i l i t a t i o n work by private interests* perhaps the outstanding example being that by Arthur W. Binns i n Philadelphia* Over a period of 10 years he has purchased some 500 old brick dwellings* mostly row houses* spent from $1*000 t o $1,500 each to reeondition and modernise them* and rented them t o negroes at from $5 to $5 per room per month—and with a return on the investment " . . . i n exeess of 10 per cent a f t e r depreciation oharges of 5^ per annum* a l l taxes and a l l operating and aaintenanee costs". l / Many of the units had been boarded up or were uninhabitable* nenoe the r e h a b i l i t a t i o n work raised the standard e f housing net only by improving the q u a l i t y of the individual units but by making additional units available a t lew rents* Mr* Binns was favored by a special tax situation i n Philadelphia which made i t possible t o buy some of these houses for as l i t t l e as $80 or $100 each, and his operations probably could not be duplicated elsewhere* However* even w i t h a larger i n i t i a l outlay* i t i s apparent that there are p r o f i t a b l e p o s s i b i l i t i e s for private enterprises i n t h i s kind of work* The p r i n c i p a l d i f f i o u l t y i s t h a t not enough individuals with Mr* Binns* vision* energy* end persistence are interested; but there w i l l be more as the p o s s i b i l i t i e s beoome more widely demonstrated • D i f f i o u l t y i n obtaining financing has been one of Binns' ohief problems* Unable t o borrow from beaks or other lending i n s t i tutions* a t f i r s t he borrowed from members of his own family and from friends* Even a f t e r demonstrating a p r o f i t a b l e operation over a period ef years he had d i f f i o u l t y i n obtaining loans* at any i n t e r e s t rate* u n t i l reeently* A great deal of exhortation and aetual demonstration of the p o s s i b i l i t i e s of making sound r e h a b i l i t a t i o n loans w i l l be needed t o get banks and other lenders even t o investigate t h i s f i e l d as an o u t l e t f o r funds* at favorable interest rates and terms* The Rational Association of Real Estate Boards i s a c t i v e l y sponsoring r e h a b i l i t a t i o n work* and an increasing number ef l o c a l 1 / Freehold* A p r i l T s * 1959 and Architectural Forum* September 1939* groups are being formed to carry oat tha work. I n Kansas C i t y , "Civic Housing I n c . " , a limited dividend corporation, i s being sat up t o provide low rent housing by renovating old c e n t r a l l y loeated properties* The directors include bankers, u t i l i t y executives, merchants, and r e a l estate operators* A measure authorising areation of "urban redevelopment corporations" has passed the Hew York State Legislature, and i t i s expected Governor Lehman w i l l sign i t * These would be limited dividend corporations subject t o regulation by a local planning coanmission or similar body and having the r i g h t of eminent domain t o assemble properties a f t e r obtaining control of 60 per cent of the assessed valuation of property w i t h i n a selected area* The United States Chamber of Commerce also have been urging r e h a b i l i t a t i o n of r e s i d e n t i a l areas* i n part aa a substitute for publie housing* Tha FHA has recently made provision under Sec* 207 of the National Housing Act for insuring leans t o finance remodeling and r e h a b i l i t a t i o n work on groups of properties i n blighted neighborhoods* Some of t h i s work may be done, but i t i s apt to be somewhat limited since i t depends primarily on the i n i t i a t i v e of Interested lending i n s t i t u t i o n s * Also, the requirement t h a t construction work must smount t o 50 per eent of the mortgage w i l l prevent the refinancing of existing mortgages on eld properties requiring only small amounts of repair and renovation work* The HOLC i s the one Federal agency doing something comprehensive about t h i s d i f f i c u l t job—the r e h a b i l i t a t i o n of blighted areas* I t w i l l soon issue a preliminary report of the study made by i t s technicians in cooperation w i t h the Baltimore Housing Authority, r e s u l t i n g i n a plan for r e h a b i l i t a t i o n of an area of 58 bloeka known aa the Haverly section i n Baltimore* Much of the preliminary work has been done, and active work w i l l s t a r t t h i s spring* I f t h i s plan can be carried through even the f i r s t of the suaoasslve stages now planned. I t w i l l serve as a most valuable example of c i t y rebuilding—with a maximum p a r t i c i p a t i o n by private owners and lending agencies, i n cooperation with tha c i t y a u t h o r i t i e s * Banks and other lending i n s t i t u t i o n s can e e l l a f f o r d t o study c a r e f u l l y the principles and techniques developed f o r t h i s p r o j e c t , even though the problems and t h e i r solutions w i l l be d i f f e r e n t i n every c i t y * I n t h i s study HOLC has gone much further i n getting down to fundamentals of proper land use than any other agency dealing w i t h urban housing* Other agencies The Federal Homo Loan Bank Board, Federal Deposit Insurance Corporation, and the Federal Reserve System* either j o i n t l y or i n d i v i d u a l l y , may do much t o c a l l t o the attention of t h e i r member lending organisations the need f o r looking c a r e f u l l y into r e h a b i l i t a t i o n work as a means of making sound, p r o f i t a b l e loans; of protecting the security behind loans on properties i n declining areasj and of improving the value of r e a l estate held* There i s an increasing number of examples of actual work accomplished and techniques for carrying out r e h a b i l i t a t i o n projects which can be made available t o the looal i n s t i t u t i o n s to assist them i n meeting local problems* The cooperation of the American Bankers Association and the U* S* Building and Loan League should be obtained i n promoting i n t e r e s t i n t h i s f i e l d among t h e i r member i n s t i t u t i o n s * Why has not more r e h a b i l i t a t i o n work been done? > I t i s d i f f i c u l t for an individual t o de much unless his neighbors also j o i n * I n mixed owner-occupied end tenant neighborhoods, the problem of multiple and absentee ownership makes group action very d i f f i c u l t * Few individuals have the seal t o attempt a large-scale r e h a b i l i t a t i o n program and almost invariably have found i t d i f f i c u l t * i f not impossible, to obtain financing* I n areas largely of rented dwellings, individual landlords often cannot do much improvement or repairs, as they csnnot raise rents, and tax valuations may be increased as a r e s u l t of the improvement* I n many c i t i e s high property taxes are as important an obstacle t o r e h a b i l i t a t i o n work as structure repair costs, l e g a l d i f f i c u l t i e s i n assembling groups of properties* or the many other problems encountered* Rehabilitation can be done much more successfully i n some situations than i n others* I f the substandard houses i n blighted and slum areas are cf frame construction, i t i s net always economically possible t o r e h a b i l i t a t e them, even with some subsidy* This i s t r u e especially of row houses* On the other hand, brick row houses usually lend themselves t o repair and improvement, i f they ean be assembled I n groups, or a block at a time* Certain types of construction simply are not suitable f o r repair and modernisation, e * g * , the old "dumbbell" tenement buildings i n Hew York City and long narrow "railroad f l a t s " found i n many c i t i e s * Rehabilitation i s less d i f f i c u l t where there i s a large supply of old* vacant structures on which t c operate than i n places l i k e the D i s t r i c t of Columbia* Here the pressure of population on housing i n the lower rent brackets, p a r t i c u l a r l y i n negro sections, i s so great that there are p r a c t i c a l l y no vacant structures on which t o operate, values ere held up a r t i f l e l a l l y , and costs of repair and improvement work are high* The A l l e y Dwelling Authority has dene some very e f f e c t i v e r e h a b i l i t a t i o n vork i n connection with some of i t s projects 1 ut has been unable t o undertake any very extensive program f o r the above reasons and beeause of l i m i t e d funds* The problem i s not always one of reclaiming a densely populated area* i n which congestion of the buildings i s a factor i n the blighted condition* I n some c i t i e s the areas are blighted beeause they are too t h i n l y populated and the people housed i n shacks out i n suburban fringes* This sort of t h i n g i s seen i n some c i t i e s that were oversubdivided i n the l a s t b u i l d i n g boom* l i l i e s of s t r e e t s , sidewalks, and u t i l i t i e s have been put i n w i t h only ocosuiional dwellings, b u i l t o r i g i n a l l y by speculative developers as "come-ons* t o s e l l adjacent l o t s * T y p i c a l l y , most of the l o t s are t a x delinquent, and maintenance of streets and u t i l i t i e s excessively costly* Here the solution may be t o concentrate on p a r t i c u l a r areas and encourage further development there* Others, p a r t i c u l a r l y those not having a heavy investment i n water or sewer lines underground, might be abandoned f a l l o w e d t o r e v e r t t o t h e i r best use, such as park, f o r e s t , or farming* The taxes would have t o be w r i t t e n o f f , but a t the same time maintenance and police and f i r e protection expense would be reduced* Government agencies can help t o overcome many of the d i f f i c u l t i e s , the l o g i c a l agency often being the l o c a l housing a u t h o r i t y * A few housing a u t h o r i t i e s are t r y i n g t o do something about t h i s themselves i n addition t o the s t r a i g h t slum clearance under the US HA loan and annual subsidy program* Perhaps i n time more w i l l see t h a t i f they r e a l l y meet the challenge of the power and r e s p o n s i b i l i t y they have as the housing authority for t h e i r c i t y , there i s no reason why they cannot do a very thoroughgoing job of improving housing conditions by a broad approach, embracing many l i n e s of a c t i v i t y * Unfortunately most of the l o c a l housing a u t h o r i t i e s so f a r set up are l i t t l e more than subsidiaries of the USHA, so thoroughly infused w i t h the USHA philosophy—and so l i t t l e exposed t o any other l i n e of thinking about housing prob lens—that t o date public housing has been l i t t l e e l s e than the USHA program of t e a r ing down slums, building new, and subsidising rents* The l o c a l a u t h o r i t i e s think i n terms of i n d i v i d u a l projects rather than a comprehensive city-wide plan f o r improving housing f e r as many people as possible* This appears t o be so, regardless of the varying nature of housing problems i n any c i t y * Such a l i m i t e d pelley can do l i t t l e more than scratch the surface of the needs of even the slue dwellers and does nothing f o r intermediate income groups whose main housing need i s not a now house so much as i t i s a b e t t e r house and* o f t e n more important, a b e t t e r neighborhood p a t t e r n . I n many areas the housing problems are only i n part those growing out of s t r u c t u r a l f a u l t s or lack of sanitary f a c i l i t i e s * widely c i t e d as measures of substandard housing Here important a t times are the problems growing out of improper land use—bad street layout* crowding* poor a i r * lack of sunlight* laok of reereation f a c i l i t i e s * and inadequate f a c i l i t i e s f o r t r a n s portation t o work* Many of these can be correeted by other less oostly means than slum clearance as now carried out* Sinee the biggest opportunities f o r r e h a b i l i t a t i o n are i n large c i t i e s and since i n the worst areas p a r t i c i p a t i o n of the l o c a l housing a u t h o r i t y or some other Government agency i s nearly always needed* ways must be found t o get the l o c a l a u t h o r i t i e s into t h i s f i e l d * Considering the r e l a t i o n of the USHA t o the l o c a l housing a u t h o r i t i e s * the USHA thus beeomes a key agency f o r obtaining action The problem i s t o persuade or require USHA t o inolude rehabilitation in i t s program*!/ I n f a e t USHA should develop f u l l y the p o s s i b i l i t i e s f o r publie aid t o housing i n urban areas* before undertaking* l a r g e l y f o r p o l i t i e a l reasons* i t s misguided e f f o r t s i n r u r a l housing* These e f f o r t s so f a r have served only t o muddy the waters i n the r u r a l f i e l d * f o r which other agencies are equipped t o operate much b e t t e r and at considerably lower cost* I t would be a great gain i f the present policy-making group i n USHA eould be persuaded t o incorporate r e h a b i l i t a t i o n i n i t s program and a e t l v e l y follow i t up through the l o c a l a u t h o r i t i e s * The U* S* Housing Aet authorises such work* so no new l e g i s l a t i o n i s needed. t j I f persuasion f a i l s * a "mandate" from Congress might be incorporated i n an amendment t o S*591 r e q u i r i n g t h a t * of any addit i o n a l appropriations* a specified part be used i n r e h a b i l i t a t i o n work* \ J A few dwellings have been repaired and renovated but only i n compliance w i t h the "equivalent elimination" clause i n the aet r e q u i r i n g the demolition or r e p a i r and improvement of dwellings equal i n number t o the new units b u i l t * Z j "Construction a c t i v i t y i n connection w i t h a low rent housing project may be confined t o the reconstruction, remodeling* or r e p a i r of e x i s t i n g buildings*" (U* S* Housing Act* Section 2* Article 5.) RURAL REHABILITATION Rural nonfarm Relatively few of the small towns and v i l l a g e s have housing a u t h o r i t i e s , and i n l i e u of soma suoh public agency acting as a "prima mover", any extensive repair and remodeling work depends for the most part on the i n i t i a t i v e of local individuals and c i v i e groups* I n these places there i s usually a higher proportion of home owners than i n the large c i t i e s , and even the rented properties are owned by l o c a l individuals* Thus, much of the responsibility for repair and improvement rests i n the home owning group* Here, lending i n s t i t u t i o n s oan help by getting l o c a l c i v i c groups t o aet and by providing necessary financing at reasonable rates* Farm USHA proposes " r u r a l slum clearance" on farms " • * at about $2,250 per dwelling, ranging from less than $2,000 i n the South t o about $2,600 i n the Eorth . . . Tenants of the new farm units w i l l be required to take care of the houses*•• and f o r suoh maintenance work w i l l be allowed an average credit of from $18 to #25 a year against the gross rent of the dwelling* Thus actual cash payments of an e n t i r e dwelling are expected t o range from about |S6 t o #60 a year i n the various projects*" For a Government-subsidised program, farm dwelling construct i o n costs of $2,000 t o #2,600 are f a r too high* The $2,250 average i s more than twice the average value of a l l farm houaes i n the United States i n 1950; i n some of the Southern States the 1930 average value was less than #500, and presumably i s even lower today* A large proportion of the bad housing on farms i s i n the South, where, fortunately, housing can be supplied at the lowest cost* The Farm Security Administration has provided good farm dwellings at h a l f the cost proposed by the USHA, and with no subsidy other than the reduead interest r a t e and supervision* Farm dwellings can be b u i l t f o r as low as |100 i n certain sections of the country, without subsidy other than supervision,by use of cheap l o c a l materials and contribution of most of the labor by the farmer himself* I t i s recommended that the present a m e n d m e n t t o S*591 allocating $200,000,000 of USHA loan funds f o r r u r a l housing be eliminated and that any farm housing program be administered through the Farm Security Administration! (1) under an enlarged BankheadJones Farm Tenant Purchase program; (2) farm r e h a b i l i t a t i o n loansi (S) sponsorship of s e l f - l s i p cooperatives f o r group building and repair of dwellings} or (4) a program t o supply, at from $30 t o $500 per f a m i l y , anything from a simple p r i v y , such as already provided i n eonsiderable volume by WPA* t o a complete e a t e r supply system and indoor t o i l e t f a c i l i t i e s * depending i n part on the climate and local oiroumstancea* - 10 - This might be i n the form of outright grants or favorable loan arrangements* Many more families could be helped than under the proposed USHA. farm housing program, and without the continuing annual subsidy* A p r i l 10, 1940.