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The next is "Effect of Amendment to United States Housing Act of 1937 Allowing Federal Loans up to 100 percent until July 1, 1939" (Exhibit II, hereinabove set forth).

The next is a letter to Congressman Williams, dated May 4, 1938, on various questions of tax exemption, cost of sites, and the like (Exhibit X).

Then a list of the local housing authorities as of May 3, 1938 (Exhibit XI), and then the material which I believe is on your desk this morning, as to municipalities that are unable to furnish a 10percent capital subsidy (Exhibit XII).

(Exhibits XI and XII are as follows:)

EXHIBIT XI

UNITED STATES HOUSING AUTHORITY-LIST OF LOCAL HOUSING AUTHORITIES AS OF MAY 3, 1938

Alabama:

Andalusia: Andalusia Housing Authority.

Anniston: Anniston Housing Authority.

Birmingham: Housing Authority of the Birmingham district.

Colbert County: Colbert County Housing Authority.

Gadsden: Greater Gadsden Housing Authority.

Mobile: Mobile Housing Board.

Phenix City: Phenix City Housing Authority.

Red Level: Red Level Housing Authority.
Selma: Selma Housing Authority.

California:

Los Angeles County: The Housing Authority of the County of Los Angeles. Oakland: Oakland Housing Authority.

San Francisco, city and county: The Housing Authority of the City and County of San Francisco.

Connecticut:

Bridgeport: Housing Authority of the City of Bridgeport.
Norwalk: Norwalk Housing Authority.

Waterbury: Waterbury Housing Authority.

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Daytona Beach: Daytona Beach Housing Authority.
Jacksonville: Housing Authority of Jacksonville.

Miami: Miami Housing Authority.

Orlando: Housing Authority of the City of Orlando.

Pensacola: The Housing Authority of the City of Pensacola.

Sarasota: Sarasota Housing Authority.

St. Petersburg: The Housing Authority of the City of St. Petersburg.

Tampa: Housing Authority of the City of Tampa.

Georgia:

Athens: Athens Housing Authority.

Augusta: Augusta Housing Authority.

Rome: Housing Authority of the City of Rome.

Savannah: Savannah Housing Authority.

Hawaii: Hawaii Housing Authority.

Illinois:

Alexander County: Alexander County Housing Authority.

Chicago: Chicago Housing Authority.

Gallatin County: Gallatin County Housing Authority.

Peoria: Peoria Housing Authority.

St. Clair County: St. Clair County Housing Board.
Springfield: Springfield Housing Authority.

Indiana:

Alexandria: Alexandria Housing Authority.
Anderson: Anderson Housing Authority.
Bluffton: Bluffton Housing Authority.

Brazil: Brazil Housing Authority.

Decatur: Decatur Housing Authority.

Indiana-Continued.

Delaware County: Delaware County Housing Authority.

Dunkirk: Dunkirk Housing Authority.

Fort Wayne: Fort Wayne Housing Authority.

Greenfield: Greenfield Housing Authority.

Huntington: The housing authority of the city of Huntington.

Jeffersonville: Housing authority of Jeffersonville.

Kokomo: Kokomo Housing Authority.

Lawrenceburg: Lawrenceburg Housing Authority.
Marion: Marion Housing Authority.
Muncie: Muncie Housing Authroity.

New Albany: Housing authority of New Albany.
Newcastle: Newcastle Housing Authority.
Richmond: Richmond Housing Authority.

Vincennes: Housing authority of city of Vincennes.
Kentucky:

Covington: Covington Municipal Housing Commission.
Frankfort: Frankfort Housing Commission.

Lexington: Lexington Municipal Housing Commission.
Louisville: Municipal housing commission.

Newport: Newport Municipal Housing Commission.
Louisiana:

New Orleans: Housing Authority of New Orleans. Maryland:

Annapolis: Annapolis Housing Authority.

Baltimore: Housing Authority of Baltimore city. Massachusetts:

Boston: Boston Housing Authority.

Cambridge: Cambridge Housing Authority.

Chelsea: Chelsea Housing Authority.

Chicopee: Chicopee Housing Authority.

Holyoke: Holyoke Housing Authority.

Lowell: Lowell Housing Authority.

New Bedford: New Bedford Housing Authority.

Michigan:

Detroit: Detroit Housing Commission.

Mississippi: (Has enabling legislation but no local authorities).
Montana:

Billings: Billings Housing Authority.

Nebraska:

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Asbury Park: Asbury Housing Authority.

Camden: Camden Housing Authority.

Montclair: Housing Authority of the Town of Montclair.

Newark: Newark Housing Authority.

North Bergen: North Bergen Housing Authority.
Orange: Orange Housing Authority.

New York:

Buffalo: Buffalo Municipal Housing Authority.

Lackawanna: Lackawanna Municipal Housing Authority.
New York City: New York City Housing Authority.

Port Jervis: Housing Authority of the City of Port Jervis.

Schenectady: Municipal Housing Authority of City of Schenectady.
Syracuse: Syracuse Housing Authority.

Utica: Utica Housing Authority.

Yonkers: Municipal Housing Authority of the City of Yonkers. North Carolina:

Ohio:

Wilmington: Housing authority for the city of Wilmington.

Akron: Akron Metropolitan Housing Authority.

Cincinnati: Cincinnati Metropolitan Housing Authority.
Cleveland: Cleveland Metropolitan Housing Authority.
Columbus: Columbus Metropolitan Housing Authority.
Dayton: Dayton Metropolitan Housing Authority.
Toledo: Toledo Metropolitan Housing Authority.
Warren: Warren Metropolitan Housing Authority..

Youngstown: Youngstown Metropolitan Housing Authority.
Zanesville: Zanesville Metropolitan Housing Authority.

Pennsylvania:

Allegheny County: Allegheny County Housing Authority.
Allentown: Allentown Housing Authority.

Bethlehem: Bethlehem Housing Authority.

Brackenridge: Brackenridge Housing Authority.
Chester: Chester: Chester Housing Authority.

Delaware County: Delaware County Housing Authority.
Erie: Erie Housing Authority.

Harrisburg: Harrisburg Housing Authority.

McKean County: McKean County Housing Authority.
McKeesport: McKeesport Housing Authority.
Miffin County: Miffin County Housing Authority.
New Kensington: New Kensington Housing Authority.
Philadelphia: Philadelphia Housing Authority.
Pittsburgh: Pittsburgh Housing Authority.
Reading: Reading Municipal Housing Authority.
Scranton: Scranton Housing Authority.

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Austin: Housing authority of the city of Austin.
Big Spring: Big Spring Housing Authority.
Brownville: Brownville Housing Authority.

Corpus Christi: Corpus Christi Housing Authority.
Dalls: Dallas Housing Authority.

El Paso: El Paso Housing Authority.

Fort Worth: Housing authority of the city of Fort Worth.
Houston: Houston Housing Authority.

Pelly: Pelly Housing Authority.

San Antonio: San Antonio Housing Authority.

Temple: Temple Housing Authority.

Waco: Waco Housing Authority.

Virginia: (Enabling legislation to go into effect June 20, 1938).

West Virginia:

Charleston: Charleston Housing Authority.

Fairmont: Fairmont Housing Authority.
Huntington: Huntington Housing Authority.
Keyser: Keyser Housing Authority.

Martinsburg: Martinsburg Housing Authority.
Morgantown: Morgantown Housing Authority.
Mount Hope: Mount Hope Housing Authority.
Parkersburg: Parkersburg Housing Authority.
Wheeling: Wheeling Housing Authority.
Wisconsin: Superior: Superior Housing Authority.

Total number of existing local housing authorities, 140.

EXHIBIT XII

MUNICIPALITIES ARE UNABLE TO FURNISH A 10 PERCENT CAPITAL SUBSIDY

There has been considerable interest in the question of local contributions toward the capital cost of housing projects. Approaching this matter from a realistic rather than a theoretical point of view, it is clear that the municipalities in this country (because of their lack of power or their financial condition) are unable to participate in the construction of housing projects by providing capital subsidies in the form of cash or land. The United States Housing Authority has found, from its own experience, that cities are not able to provide this 10 percent as an outright cash subsidy.

This 10 percent can be raised locally through the sale by a local housing authority of part of its bonds. These bonds evidence a loan (in addition to the 90 percent United States Housing Authority loan) payable from the revenues and subsidies

on the housing project. This is the method now being used by all of the local housing authorities in order to raise all or a part of their 10 percent.

However, the raising of this 10 percent necessarily requires time and involves delays. The proposed amendment, therefore, recommends temporary relief from this requirement so as to speed up actual construction. After July 1, 1939, the existing requirement for a 10 percent participation will be automatically reinstated under the terms of the proposed amendment.

In the consideration of the proposed amendment, the question has been raised whether the municipalities can now provide this 10 percent in the form of a subsidy. The United States Housing Authority is convinced that cities are unable to provide these funds as a subsidy. To obtain funds to donate to a housing authority, it would generally be necessary for the municipality to issue and sell its general obligation bonds payable from general taxes.

Unfortunately, the cities do not have the power to issue such bonds. In the 33 States having housing legislation, none of the cities (except in Colorado) have the statutory authority to issue bonds to raise funds for the purpose of donating them to housing authorities. In other words, new legislation would be necessary in all of these States. At this time, the legislatures of only two States are in session. This means that if 10 percent were required as a local capital grant, nothing could be done until the convening of these State legislatures in 1939 or later. As a result, the necessary State legislation could not even be considered (apart from the question of whether it would be enacted) until almost a year from now. In short, if the 10 percent local participation were required in the form of a subsidy, no public housing construction could be expected in this country until 1939 or 1940. Even then, there would be gloomy prospects for a substantial volume of housing construction, because most municipalities would be unable to obtain or exercise this power of raising 10 percent as a donation toward the development of a housing project. This is due either to their lack of borrowing power under existing debt limitations or to their financial condition.

For your information, there is attached a chart showing the existing constitutional and statutory debt limitations and restrictions. From this chart, it appears that constitutional and statutory debt limitations govern in most municipalities. In 30 States, municipalities and political subdivisions are subject to constitutional debt limitations and in 17 other States they are subject to statutory debt limitations, which are often as unchangeable and long-standing as similar constitutional provisions. It, therefore, appears that virtually all local governments are now operating under some form of debt limitation." It is common knowledge that many of these municipalities have exhausted (or come close to exhausting) their borrowing powers, particularly in view of local relief requirements.

In addition, many State constitutions contain limitations on the amount of local taxes which can be levied. These limitations will often prevent a municipality from issuing additional tax bonds due to the fact that the maximum tax limit has been reached.

It should also be noted that tax obligations of a municipality can generally be issued only after a vote of the people. This would materially delay the commencement of housing construction.

It is all very well to speak of amending these constitutions and limitations in order to increase borrowing power, remove tax restrictions, and to avoid delays in raising the local 10 percent as a subsidy. The process of amendment of constitutions is admittedly very slow and generally impracticable. Such an alternative is certainly out of the question if serious consideration is to be given to expediting housing construction in order to relieve unemployment.

It might also be said that the 10 percent local participation could be in the form of cash. But how many cities have cash lying idle in their treasuries? The practical fact is that such cities do not have the cash, for they have been suffering from increasing demands on city revenues, decreasing tax collections, and the continuing requirements of providing relief.

These same municipalities which are unable to furnish a capital grant are ready and able to provide annual subsidies in the form of tax exemption. This is a form of assistance which is even more effective in achieving the objective of low rentals. If we are to have an effective public housing program in America, we must face practical realities and obtain this form of local subsidy which is the only feasible means of obtaining substantial continuing local donations.

Limitations on local debt-Constitutional and statutory debt limits; general provisions as of Jan. 1, 1936 [In the second column constitutional provisions are indicated by "C" followed by a date or dates referring to the latest revision of the organic law. the later date refers to an amendment. The letter "S" is for statutory, referring to what purport to be more or less comprehensive bond acts, ant acts. In the third column the debt limit is expressed in terms of a percentage of the assessed valuation.]

Where 2 dates are given for 1 State and dates refer to the more import

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