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5/28/75 - National Association of Regional Councils
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1133416
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5/28/75 - National Association of Regional Councils
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Carla A. Hills Speeches
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1975
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The original documents are located in Box 1, folder "5/28/75 - National Association of
Regional Councils" of the Carla A. Hills Speeches at the Gerald R. Ford Presidential
Library.
Copyright Notice
The copyright law of the United States (Title 17, United States Code) governs the making of
photocopies or other reproductions of copyrighted material. Gerald Ford donated to the United
States of America his copyrights in all of his unpublished writings in National Archives collections.
Works prepared by U.S. Government employees as part of their official duties are in the public
domain. The copyrights to materials written by other individuals or organizations are presumed to
remain with them. If you think any of the information displayed in the PDF is subject to a valid
copyright claim, please contact the Gerald R. Ford Presidential Library.
Digitized from Box 1 of the Carla A. Hills Speeches at the Gerald R. Ford Presidential Library
FINAL
NATIONAL ASSOCIATION OF REGIONAL COUNCILS
BOSTON, MASSACHUSETTS
MAY 28, 1975
I AM VERY HAPPY TO BE HERE TODAY. You ARE MY PARTNERS
IN A CHALLENGING AND DIFFICULT ENDEAVOR -- THE IMPLEMENTATION
OF THE 1974 HOUSING AND URBAN DEVELOPMENT AcT.
THAT STATUTE REPRESENTS A MAJOR SHIFT IN FEDERAL
INVOLVEMENT IN HOUSING AND URBAN DEVELOPMENT. THE EMPHASIS
HAS CHANGED FROM HOUSING PRODUCTION FOR PRODUCTION SAKE, TO
PLANNED URBAN PRESERVATION AND COMMUNITY DEVELOPMENT, You
PLAY A CRUCIAL ROLE IN ACHIEVING THAT STATUTORY PURPOSE OF
PLANNED DEVELOPMENT.
OUR NEW LEGISLATION EMPHASIZES LOCAL GOVERNMENT
DECISION-MAKING.
LOCAL GOVERNMENTS ARE AFFORDED SUBSTANTIAL FLEXIBILITY
IN UTILIZING THEIR COMMUNITY DEVELOPMENT FUNDS, SIMILARLY,
LOCAL COMMUNITIES ARE GIVEN BROAD DISCRETION IN DECIDING
THE MIX OF NEW, REHABILITATED AND EXISTING HOUSING BEST
SUITED TO MEETING THE NEEDS OF THEIR LOWER-INCOME FAMILIES, FORD
GENALO F. LIBRARY
-2-
BUT, WITH THIS NEW EMPHASIS ON LOCAL DECISION-MAKING
COMES INCREASED LOCAL RESPONSIBILITY FOR RATIONAL PLANNING,
As A CONDITION TO RECEIVING COMMUNITY DEVELOPMENT
GRANTS, A CITY MUST SUBMIT A COMPREHENSIVE PLAN ASSESSING
ITS NEEDS, RESOURCES, PRIORITIES AND ULTIMATE GOALS IN
COMMUNITY DEVELOPMENT.
IT MUST ALSO SUBMIT A HOUSING ASSISTANCE PLAN. THAT
HOUSING ASSISTANCE PLAN, WHICH WE CALL A. HAP, MUST ASSESS:
1. THE CONDITION OF THE COMMUNITY'S
EXISTING HOUSING STOCK; AND
2. THE HOUSING NEEDS OF THE LOWER-
INCOME PERSONS RESIDING OR EXPECTED
TO RESIDE IN THE COMMUNITY,
ON THE BASIS OF THIS ASSESSMENT, THE COMMUNITY MUST
SPECIFY ITS PLANS FOR MEETING THE IDENTIFIED NEEDS OF ITS
LOWER-INCOME FAMILIES.
2 FORD
-3-
IN MEETING THOSE NEEDS, THE COMMUNITY MUST SEEK TO
PRESERVE OR REVITALIZE EXISTING NEIGHBORHOODS, PROMOTE
GREATER HOUSING CHOICES FOR LOWER-INCOME FAMILIES, AND
AVOID UNDUE CONCENTRATIONS OF POOR PEOPLE.
THUS, ALTHOUGH LOCAL COMMUNITIES ARE GIVEN GREAT
FLEXIBILITY IN USING FEDERAL HOUSING AND DEVELOPMENT
FUNDS, THEY ARE ALSO GIVEN RESPONSIBILITY TO PLAN FOR
THE USE OF THOSE FUNDS,
MANY OF THE PROBLEMS WHICH COMMUNITIES MUST ADDRESS
IN THEIR COMMUNITY DEVELOPMENT AND HOUSING ASSISTANCE
PLANS EMANATE FROM BEYOND THEIR OWN BORDERS.
A METROPOLITAN AREA MAY INCLUDE MANY SMALL TOWNSHIPS,
CITIES, OR COUNTIES, THE PROCESS OF ITS GROWTH AND
DEVELOPMENT MAY IGNORE THE ARTIFICIAL LINES ON A MAP
DELINEATING THE CONSTITUENT COMMUNITIES. COMMERCIAL
ACTIVITY IN ONE TOWN MAY CREATE INCENTIVES FOR PARTICULAR
RESIDENTIAL OR COMMERCIAL USES AT THAT TOWN'S PERIPHERY.
A NEW PLANT IN ONE LOCALITY MAY CREATE HOUSING NEEDS IN
NEARBY COMMUNITIES. THE UNDUE CONCENTRATIONS OF POOR
PEOPLE IN A CENTRAL CITY MAY ONLY BE CAPABLE OF MITIGATION
ON A REGION-WIDE BASIS,
GERAU A. FORD LIBRA
-4-
REGIONAL DEVELOPMENT, LIKE THE LAW, IS A SEAMLESS
WEB. THE ACTION OF ONE COMMUNITY NECESSARILY AFFECTS
ITS NEIGHBORS, AND THE NEIGHBORS' RESPONSE NECESSARILY
AFFECTS THE INDIVIDUAL COMMUNITY.
IT IS CLEAR THAT A COMMUNITY'S PLAN, DRAWN WITHOUT
REFERENCE TO REGIONAL PLANNING, IS A PROGRAM DRAWN IN A
VACUUM, BOUND FOR DISASTER IN A REAL WORLD,
THE 1974 Act TAKES ACCOUNT OF THIS REALITY WITH THE
A-95 REVIEW OF LOCAL COMMUNITIES' APPLICATIONS BY AREA-
WIDE AGENCIES SUCH AS YOURS. THIS IS AN ESSENTIAL
ELEMENT OF THE REQUIRED PLANNING PROCESS,
A COMMUNITY'S DEVELOPMENT PLAN MUST BE CONSTRUCTED
"IN ACCORDANCE WITH AREA-WIDE PLANNING POLICIES". AND,
BEFORE A GRANT CAN BE MADE TO A COMMUNITY, ITS COMMUNITY
DEVELOPMENT PLAN AND ITS HAP MUST BE SUBMITTED FOR REVIEW
AND COMMENT TO AN AREA-WIDE AGENCY, ANY OBJECTION BY
THAT AREA-WIDE AGENCY REQUIRES RESPONSE BY THE APPLICANT
COMMUNITY.
GERALD P. Policy
-5-
THUS, THE AcT ITSELF EMBODIES A CONCEPT OF REGIONALISM,
NECESSITATED BY THE MODERN REALITIES OF REGIONAL GROWTH AND
DEVELOPMENT.
THIS REGIONAL PLANNING AND REVIEW ELEMENT HAS CREATED
SOME PRACTICAL PROBLEMS, FOR EXAMPLE, WHEN WE WERE
NEGOTIATING THE 45-DAY PERIOD FOR AREA-WIDE REVIEW OF
COMMUNITY DEVELOPMENT APPLICATIONS, WE WERE FACED WITH WHAT
SEEMED TO BE A HOBSON'S CHOICE.
WE FELT THAT BOTH THE LAW AND THE PRACTICAL NECESSITY
FOR COORDINATED REGIONAL PLANNING NECESSITATED STRICT
ADHERENCE TO THE REQUIREMENT THAT NO APPLICATIONS BE ACCEPTED
WITHOUT A-95 COMMENTS ATTACHED.
ON THE OTHER HAND, WE ALSO KNEW THAT THE NEWNESS OF THE
PROGRAM, THE REQUIREMENTS OF CITIZEN PARTICIPATION, THE CITY
ENVIRONMENTAL RESPONSIBILITIES, AND THE HAP REQUIREMENT MADE
IT VERY DIFFICULT FOR CITIES TO MEET OUR DEADLINE FOR FILING
APPLICATIONS EVEN WITH THE RELATIVELY SHORT 45-DAY MAXIMUM
A-95 REVIEW PERIOD WE WERE NEGOTIATING,
&
FORD
-6-
IT WAS INEVITABLE THAT MANY CITIES WOULD ASK YOU FOR
AN EVEN SHORTER TURN-AROUND PERIOD.
ALL OF YOU CAME THROUGH SPLENDIDLY IN MEETING THAT
DIFFICULT DEADLINE, NOT ONE ENTITLEMENT CITY MISSED ITS
DEADLINE, OF THE VERY FEW EXTENSIONS GRANTED, NONE
INVOLVED AN A-95 DELAY, YOUR PERFORMANCE DEMONSTRATES
THE MAGNIFICENT CAPACITY OF YOUR ORGANIZATIONS TO PROVIDE
AN ESSENTIAL SERVICE TO YOUR COMMUNITIES ON A VERY SHORT
TIME FRAME.
BUT, THE SHORT TIME AFFORDED FOR A-95 COMMENT THIS
YEAR SHOULD NOT BE TAKEN AS MINIMIZING THE CRUCIAL ROLE
WHICH THAT PROCESS PLAYS IN OUR REVIEW OF GRANT APPLICATIONS
AND HAP's UNDER THE NEW LAW.
DURING THIS FIRST YEAR WE FOUND THAT FEW OF US WERE
PERFECT. MOST OF YOU DID MORE THAN THE ABSOLUTE MINIMUM
OF SAYING "WE LIKE THE APPLICATIONS OF ALL THE CITIES IN
OUR REGION".
GERAU FORD
-7-
AND, SOME OF YOU DID AN EXCELLENT JOB, EVEN ON SHORT
NOTICE, OF GATHERING A RANGE OF COMMENTS AND PROVIDING A
GOOD ANALYSIS OF LOCAL APPLICATIONS,
BUT THE AcT REQUIRES EVEN MORE. You HAVE BEEN GIVEN
A DIFFICULT CHARGE WHICH YOU MUST MEET IF THE PLANNING
ELEMENT OF THAT LEGISLATION IS TO BE EFFECTIVE,
I KNOW THAT THERE MAY BE. A TEMPTATION AT TIMES TO
ADOPT A "LIVE AND LET LIVE" ATTITUDE ON LOCAL APPLICATIONS
FOR FEDERAL GRANTS. IT MAY SEEM EASIER FOR EACH COMMUNITY
REPRESENTED IN AN A-95 AGENCY TO PROTECT ITS OWN APPLICATION
BY FAVORING A POLICY OF NOT CRITICIZING THE APPLICATION OF
ITS NEIGHBORS,
To DO so, HOWEVER; WOULD ONLY CHEAT YOURSELVES. THE
1974 AcT AFFORDS YOU THE OPPORTUNITY TO UNDERTAKE COMPREHENSIVE
COMMUNITY DEVELOPMENT. FOR LOCAL DEVELOPMENT PROGRAMS TO
BE EFFECTIVE, THEY MUST BE PART OF A REGIONALLY COORDINATED
APPROACH, A CRAZY QUILT OF CONFLICTING LOCAL DEVELOPMENT
PLANS WITHIN AN INTEGRATED METROPOLITAN AREA WILL BRING WITH
IT CONFUSION, DUPLICATION, AND WASTE, AND FRUSTRATE ANY HOPE
OF RATIONAL COMMUNITY DEVELOPMENT,
A.
-8-
NEXT YEAR WE WILL BE LOOKING LARGELY TO YOU TO IMPLEMENT
OUR LEGISLATION'S EMPHASIS ON REGIONAL PLANNING.
IF ANY OF YOU ARE CONCERNED THAT THE A-95 PROCESS IS
VIEWED LIGHTLY BY HUD, LET ME DISABUSE YOU OF THAT NOTION
RIGHT NOW. WASHINGTON LOOKS HARD AT YOUR COMMENTS IN
JUDGING THE LOCAL PLANS AGAINST THE REALITIES OF REGIONAL
DEVELOPMENT.
AND, IF ANY OF YOU VIEW YOUR FUNCTION MORE AS LEGISLATIVE
LOG-ROLLING THAN SUBSTANTIVE AREA-WIDE PLANNING, YOU HAVE
SERIOUSLY MISCONCEIVED THE VERY IMPORTANT ROLE THRUST UPON
YOU BY THE 1974 AcT.
LET ME GIVE YOU AN IMPORTANT EXAMPLE OF YOUR ROLE IN
THE PROCESS OF REVIEW OF GRANT APPLICATIONS AND IN THE
ALLOCATION OF SECTION 8 LOW INCOME HOUSING ASSISTANCE.
As YOU KNOW A HAP IS A REQUIREMENT BOTH FOR A
DEVELOPMENT GRANT APPLICATION, AND IN THE ALLOCATION OF
SECTION 8 HOUSING ASSISTANCE PAYMENTS,
FORD
CIBRALD
-9-
THE STATE OF THE ART IN WRITING HOUSING ASSISTANCE
PLANS COULD NOT HAVE BEEN EXPECTED TO BE PERFECT THE FIRST
YEAR, AND, MANY OF THE HAPs SUBMITTED WERE FAR LESS THAN
PERFECT. NOR WAS HUD's REVIEW PERFECT. OUR PERFORMANCE
WILL BENEFIT FROM A YEAR'S EXPERIENCE UNDER THE NEW
PROGRAM.
MANY UNEXPECTED ISSUES SURFACED.
ONE OF THOSE ISSUES CONCERNS COMMUNITIES' ASSESSMENTS
OF THE HOUSING NEEDS OF THEIR LOWER-INCOME FAMILIES, THE
HAP REQUIRES CITIES TO IDENTIFY THOSE NEEDS, THE RESOURCES
AVAILABLE TO MEET THEM, AND THE GOALS OF THE COMMUNITY IN
DOING SO,
IT WILL BE THE RARE INSTANCE WHERE A COMMUNITY WOULD
BE ABLE TO MEET ALL OF ITS PERCEIVED HOUSING NEEDS IN THE
FIRST YEAR WITH SECTION 8 RENTAL ASSISTANCE. NONETHELESS,
THE HAP STATEMENT OF NEEDS IS BY NO MEANS AN ACADEMIC
EXERCISE, A REALISTIC ASSESSMENT OF LOWER-INCOME HOUSING
NEEDS IS A NECESSARY PREREQUISITE NOT ONLY TO A FAIR
ALLOCATION OF SECTION 8 RENTAL ASSISTANCE, BUT ALSO TO
RATIONAL LOCAL AND REGIONAL PLANNING
a
FORD
-10-
THE AcT REQUIRES A COMMUNITY TO INCLUDE IN ITS HAP
THE HOUSING ASSISTANCE NEEDS OF LOWER-INCOME PERSONS
"EXPECTED TO RESIDE IN THE COMMUNITY". THE LEGISLATIVE
HISTORY OF THIS PROVISION MAKES IT CLEAR THAT THOSE
"EXPECTED TO RESIDE" INCLUDE WORKERS IN PLANNED OR EXISTING
EMPLOYMENT FACILITIES IN THE COMMUNITY, THE HOUSE REPORT
STATES THAT "CLEARLY, THOSE ALREADY EMPLOYED IN THE
COMMUNITY CAN BE EXPECTED TO RESIDE THERE."
THUS, A HAP MUST TAKE INTO ACCOUNT THE HOUSING NEEDS
OF A PROPORTION OF LOWER-INCOME PERSONS ALREADY COMMUTING
TO EXISTING PLACES OF EMPLOYMENT WITHIN THE COMMUNITY, AS
WELL AS THOSE WHO MAY BE EXPECTED TO TAKE EMPLOYMENT. IN
JOBS YET TO BE CREATED THERE,
OBVIOUSLY, NOT EVERY LOWER-INCOME WORKER IN A TOWN
CAN BE EXPECTED TO LIVE THERE,
ON THE OTHER HAND, THE Act CREATES A CLEAR OBLIGATION
ON THE PART OF COMMUNITIES TO PROVIDE REASONABLE RESIDENTIAL
OPPORTUNITIES FOR THEIR OWN LOWER-INCOME WORKERS, THE Act
EXPRESSLY FAVORS A POLICY OF PROVIDING LOWER-INCOME FAMILIES
WITH AN OPPORTUNITY TO LIVE WHERE THEY WORK.
R.
FORD
$
-11-
A WIDE RANGE OF CONSIDERATIONS JUSTIFY THIS POLICY.
THERE ARE HIGH ENERGY AND ENVIRONMENTAL COSTS TO MASS
COMMUTING. As MORE AND MORE INDUSTRIES AND COMMERCIAL
FACILITIES LEAVE THE CORE CITIES FOR SURBURBAN LOCATIONS,
THE JOBS AND HOMES OF LOWER-INCOME WORKERS ARE BECOMING
INCREASINGLY DISTANT. COSTS OF SUCH MOVEMENTS ARE THUS
IMPOSED DISPROPORTIONATELY ON THOSE WHO CAN LEAST AFFORD
THEM.
THERE ARE OTHER INEQUITIES, Too OFTEN, SUBURBAN
COMMUNITIES ENJOY THE TAX ADVANTAGES OF EMPLOYMENT CENTERS
WITHOUT BEARING THE SOCIAL AND FISCAL BURDENS OF PROVIDING
HOUSING FOR THEIR LOWER-INCOME EMPLOYEES.
AND, THERE ARE THE STATED OBJECTIVES OF THE 1974 Act --
TO PROVIDE GREATER CHOICES OF HOUSING OPPORTUNITIES TO
LOWER-INCOME FAMILIES AND TO AVOID UNDUE GEOGRAPHICAL
CONCENTRATIONS OF SUCH FAMILIES,
THUS, ALTHOUGH THE LEGISLATIVE PURPOSE IS CLEAR, WE
MUST BE EQUALLY CLEAR IN INFORMING APPLICANTS OF THEIR
OBLIGATIONS IN THIS REGARD.
P. FORD
-12-
WE ARE IN THE PROCESS OF TELLING COMMUNITIES WHOSE
INDUSTRIES EMPLOY A SIGNIFICANT NUMBER OF LOWER-INCOME
WORKERS, THAT THE HOUSING NEEDS OF SUCH WORKERS MUST BE
ADDRESSED. WE HAVE JUST PROVIDED OUR FIELD STAFF WITH
GUIDELINES ON HOW TO ASSESS AN APPLICANT COMMUNITY'S
MEASUREMENT OF THE HOUSING NEEDS OF ITS LOWER-INCOME WORKERS,
WE HAVE ALSO PROVIDED SOME GUIDANCE AS TO WHAT ARE THE AVAIL-
ABLE SOURCES OF DATA UPON WHICH TO MAKE THAT DETERMINATION.
OUR SUGGESTED FORMULA IS, HOWEVER, A ROUGH MEASURE,
AND AT PRESENT CAN ONLY BE APPLIED IN CITIES WITH POPULATIONS
EXCEEDING 50,000 IN THE LARGER SMSAs. ACCORDINGLY, AND
BECAUSE OF THE LATENESS OF OUR FORMULATION, WE HAVE OFFERED
COMMUNITIES THE OPTION OF USING OUR FORMULA, DEVISING THEIR
OWN REASONABLE METHODOLOGY, OR, FOR THIS FIRST YEAR ONLY,
INDICATING WHAT STEPS THEY WILL TAKE NEXT YEAR TO IDENTIFY
A MORE APPROPRIATE NEEDS FIGURE.
THE REAL PROBLEM HERE IS THAT WE ARE ASKING EACH
COMMUNITY TO GIVE AN ASSESSMENT NOT OF A PURELY LOCAL,
BUT RATHER OF A REGIONAL PHENOMENA, COMMUNITIES ARE ASKED
TO ASSESS EXPECTATIONS OF NEEDS THAT BY DEFINITION EXTEND
TO THE COMMUTERS LIVING ELSEWHERE IN THE REGION.
BEBAND ?
-13-
THE TASK OF COORDINATING LOCAL ASSESSMENTS OF THOSE
"EXPECTED TO RESIDE" IN EACH INDIVIDUAL COMMUNITY WITHIN
AN INTERDEPENDENT REGION IS ONE TO WHICH AREA-WIDE AGENCIES
LIKE YOUR OWN ARE PARTICULARLY SUITED.
UNLIKE THE FEDERAL GOVERNMENT, YOU CAN FINE TUNE THE
DISTRIBUTION OF HOUSING NEEDS WITH DUE DEFERENCE TO AVAIL-
ABLE LAND RESOURCES, GROWTH RATES, REGIONAL PLANNING
PRIORITIES, AND THE OTHER CHARACTERISTICS PECULIAR TO YOUR
REGION.
UNLIKE THE LOCAL GOVERNMENTS, YOU CAN TACKLE A REGIONAL
PROBLEM ON A REGIONAL BASIS, You HAVE GREATER RESOURCES
AND A BROADER PERSPECTIVE THAN YOUR INDIVIDUAL CONSTITUENT
COMMUNITIES. ALSO, YOU ARE NOT BOUND TO THE PAROCHIAL
CONCERNS OF ANY ONE COMMUNITY, SUCH AS PROTECTING ITS TAX
BASE OR EMPLOYMENT FACILITIES AT THE EXPENSE OF ITS NEIGHBORS,
ACCORDINGLY, THIS IS WHAT I WOULD LIKE TO SEE YOU DO.
DRAW AN AREA-WIDE HOUSING PLAN FOR YOUR METROPOLITAN AREA
WHICH IS FACTUALLY UNASSAILABLE IN ASSESSING THE HOUSING
NEEDS OF WORKERS IN RELATION TO THE LOCATIONS OF THEIR
EMPLOYMENT. THEN, USE YOUR METROPOLITAN PLAN AS THE A-95
a.
FORD
/
-14-
STANDARD AGAINST WHICH TO MEASURE LOCAL HAPs. IF YOU CAN
DO THIS, I CAN PROMISE YOU THAT HUD CAN AND WILL MAKE VERY
GOOD USE OF YOUR A-95 COMMENTS ON THE SUBMISSIONS OF YOUR
CONSTITUENT COMMUNITIES.
NEITHER OF OUR TASKS WILL BE EASY. THE PROBLEM OF
REGIONAL PLANNING IS FRAUGHT WITH CONTROVERSY AND COMPLEXITY.
THERE WILL BE COMMUNITIES WHICH WILL STRONGLY OPPOSE
EFFORTS TO PLACE THEIR INTERESTS IN THE LARGER MOSAIC OF
OUR METROPOLITAN AREAS, STRONG OPPOSITION WILL MEET EFFORTS
TO TAKE AWAY A TOWN'S ENJOYMENT OF THE BENEFITS OF ECONOMIC
DEVELOPMENT WITHOUT SHARING ITS BURDEN OF HOUSING THE LOW-
INCOME FAMILIES WHO ARE EMPLOYED BY ITS INDUSTRIES,
BUT RATIONAL METROPOLITAN DEVELOPMENT WILL BE FURTHERED,
AND I THINK EVENTUALLY OUR EFFORTS WILL BE APPLAUDED, THE
CHALLENGE IS OURS.
I HOPE YOU WILL JOIN ME IN MEETING IT.
? R. FORD