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For the reasons outlined above, it is recommended that these temporary demountable wartime housing units and trailers which we consider undesirable, especially from the point of view of the fire hazard created, be imported only to the extent that the problem is not met by the remedies we have suggested. It is conceivable that because of delay in conversion of one and two-family houses and the rehabilitation of boarded-up tenements, we may require the temporary use of small numbers of these units at certain carefully selected locations where they cannot possibly create serious hazards to the surronding population. Approximately 13 acres of right-of-way required for Major Deegan Expressway in the Borough of the Bronx could be made available for these demountable houses or trailers. This property must be acquired by the city and State for the highway program and it could be used temporarily for emergency housing. This part of the program should also be placed under the New York City Housing Authority.

It is apparent that one of the most serious difficulties in the way of releasing this program, especially as to the immediate emergency, lies in the shortage of building materials. Full consideration of this subject would require a separate report of considerable length. The solution of this basic problem obviously must be Nation-wide, but it is essential that the needs of so large a community as this be strongly emphasized. For this reason, we urge that you as mayor discuss fully with the proper Federal officials the breaking of material bottlenecks.

We conclude with a summary of the methods we have recommended of taking care of the people who must be housed. If the committee can be of further service to you in carrying out these recommendations, command us.

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Additional public housing from unappropriated balance of original $300,000,000
State loan fund..

90,000

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OPA rental adjustments on all-year-round houses in Rockaways..

2,300

OPA rental adjustments to allow conversion of summer bungalows in Rockaways,
Coney Island, and other beaches..

8,000

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Quonset huts.

10,000

Converted Army camps..

25,000

3,000

Demountable houses, trailers, and other temporary units.

10,000

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Total..

43,300

140,000

Robert Moses (Chairman), Edmond B. Butler, Richard E. Dougherty,
Frederick H. Ecker, Thomas G. Grace, Sidney Hillman, John P.
Hogan, John Reed Kilpatrick, Martin Lacey, Edward C. Maguire,
George V. McLaughlin, Howard McSpedon, Charles G. Meyer,
Clarence G. Michalis, Saul Mills, Donelan J. Phillips, Joseph
Platzker, Mrs. James Shaw, Louis Skidmore, Ernest L. Stebbins,
Edward Weinfeld.1

Hon. WILLIAM O'DWYER,

Mayor-Elect of the City of New York.

DEAR GENERAL: It is not a light matter to disagree with so distinguished a membership as composed your committee on housing. While I am in agreement with certain parts of the report, I find myself unable to concur with the majority on fundamental issues relating to rehabilitation of old law tenements, conversion

1 General concurrence, with dissent in separate report on the question of conversion of one- and two-family dwellings, rehabilitation, extent of temporary program and, in part, on long-range permanent program.

of one- and two-family private dwellings, the proposed limited use of all available temporary housing, and the lack of certain recommendations as to the long-range housing program over a 10-year period. Were my disagreement not grounded upon basic public policy matters, but related only to administration and procedures, I assure you that I would have submerged my views to those of the majority.

We agree that decent and adequate permanent housing is the only real solution to the problem. However, it is clear that permanent housing on the scale required cannot be made available for at least 2 years.

Since adequate housing cannot be made available, it carries with it the presumption that any substitute is inadequate, and accepted only on the basis of dire need and its temporary use. What the majority fails to recognize is the difference between temporary housing to be torn down as a matter of course when the emergency ends, and the breaking down of standards of buildings that have been permanent-too permanent-disgracing the city's name and breeding disease and crime for many years. Their abolition became a part of the recognized policy of the State beginning with the passage of the tenement-house law in 1901 and modernized by the multiple-dwelling law of 1929.

A number of sources are suggested to alleviate the present desperate condition. I shall discuss the question of temporary war housing units first from the point of view of what is available, and how far they will go toward meeting the emergency.

TEMPORARY HOUSING FOR VETERANS

The report indicates that an absolute minimum of 40,000 families, mostly veterans, require housing immediately. The program which was initiated, following your conference with the Governor, will, according to press reports, be limited to Manhattan Beach, Fox Hills, Miller Field, and Fort Tilden barracks, and will provide for 3,000 veterans and their families-clearly inadequate in the light of the need.

The committee proposes the use of 5,000 Quonset huts at designated vacant land sites. My disagreement with the committee is because it limits the immediate emergency program to the Quonsets and fails to draw at once upon other temporary units available through the Federal Government, such as temporary housing, demountable housing, dormitory units, trailers, and other expedients. The committee's position is that this additional supply be used only "as a last resort" and after the other remedies proposed by them, such as rehabilitation of old law tenements, conversion of one- and two-family houses, summer residence possibilities at the seashore areas, and the like have been exhausted. This means delayed action.

There are presently available for use by the city of New York through Federal agencies 2,000 demountable housing units, 3,000 temporary housing units and 1,000 trailers. We have already lost much precious time since early September when the use of temporary housing was first advocated. With demands being made for all available temporary housing, by other cities faced with the same critical housing shortage as New York and by universities as well, if New York does not act quickly and at once, it will lose the opportunity to obtain these additional 6,000 units. The supply is rapidly dwindling. My recommendation, with all due deference to the majority of the committee, is that all temporary housing units available for use be applied for immediately and brought to the city as quickly as conditions permit, as the most expedient and feasible way of alleviating the present condition in the shortest possible time.

Much has been said about the undesirability of temporary housing. It must be conceded that it is not ideal, but we are dealing with a condition and not a theory. The temporary units have distinct advantages in that no substantial new materials are required, all component parts are already in existence available for reuse, and moreover, the limited supply of material which should be used for new and permanent construction is not drawn upon. Speed is a factor in its favor.

Another reason for taking issue with the majority on their pushing aside of some temporary housing in favor of proposals for rehabilitation and conversion is that their recommendations constitute a rejection of actual houses in favor of conjectural ones.

Certain statements have been made to cast doubt that the demountable and temporary units are desirable for reuse or that they can be erected speedily. We must be guided by fact and demonstrated experience. I have been informed by the Federal Public Housing Authority in answer to a direct inquiry by me

chat, as a result of their experience, temporary and demountable housing is reusable on new locations, that the program for reuse resulted in reclamation of virtually 100 percent of such housing and that houses at the new location are substantially as good, and in some instances, even appear better than the house at its old location. On the question of time, given an ideal combination of site, weather conditions, competency of the contractor, and availability of labor, the Federal Authority states, "it should be conservatively possible to have your first house on the new site within 45 days from the date of the contract award. With any good breaks, this period can be lessened by 2 weeks; with any bad breaks it would be necessarily increased."

It is to be remembered that these homes were used during the war period in another emergency to provide shelter for more than 320,000 war workers who carried on the battle of production in industrial areas of the country.

REHABILITATION OF OLD LAW TENEMENTS

The proposal with respect to the rehabilitation of old law tenements is not new, except in two respects one is the recommendation to raise the ceiling of the rental limitation from $8 per room per month to $12 per room per month. The other is somewhat more radical. It proposes instead of tax exemption on the new improvements for a period of 10 years, that "the entire building including improvements be exempt for a period of 3 years" and in addition, "the improvements be exempt for a further period of 7 years." The 3-year total exemption is even greater than that allowed to public housing or redevelopment company projects, which affect clearance of substandard areas and provide decent, clean, sanitary quarters.

I am opposed to the rehabilitation of old law tenements in areas heretofore or hereafter designated for clearance by the city planning commission. If permitted at all it should be confined to areas other than those marked for clearance. Any other policy will mean the perpetuation of buildings the city has repeatedly attempted to drive out of existence. Permitting owners to rehabilitate in areas already designated for clearance by the city planning commission means we delay our program, freeze undesirable neighborhood patterns, increase the cost of acquisition when clearance is finally undertaken. In other words, the city or a redevelopment company will pay at least twice for this particular type of slum perpetuation. It even affects future planning of new projects undertaken by the Housing Authority or investment capital. It is well known that excessive land costs have caused undesirable increases in density, coverage, and planning solely on economic grounds because of original high cost of acquisition of land and buildings.

So far as rehabilitation is concerned, the legislature passed a law urged by rehabilitation proponents a year ago. Its sponsors, undoubtedly sincere, issued optimistic statements about the number of units of housing that would result if the law were passed. The claim was made that thousands of units would result. The fact is that no one rehabilitated. Not a single tenement house owner came in, despite the hopes as expressed at that time by the sponsors. The majority of the committee in proposing an additional bonus in the form of complete tax exemption for 3 years, tax exemption on the improvements for another 7 years, and an increase in the rental ceilings, likewise make optimistic predictions that 10,000 new units will result. I venture the prediction that if unfortunately the legislature should yield to the demands for amendments, not much more will be produced than was realized under the existing law. Some will ask why oppose it?-and I answer a major public policy issue is involved in the proposal, both with respect to rehabilitation and conversion, that is, shall the crisis be used to permit the relaxation of standards and safeguards long fought for with respect to our permanent supply of housing. We must not use the housing crisis to yield to the pressure to accomplish this purpose. We must go forward and not backward. These slums and their rookeries must go and they should go in our time.

CONVERSION OF ONE AND TWO FAMILY DWELLING UNITS

Another proposal in the majority's report which I cannot accept is the one which calls for conversion of existing one- and two-family brick houses into three-family units and which would permit basement occupancy without complying with some of the safety requirements of the multiple dwelling law. The "comparatively small changes" in the multiple dwelling law recommended

actually involve breaking down fire protection standards, under which any dwelling which houses three or more families, and is more than two stories high, must have either two means of egress or be equipped with a sprinkler system in the halls and on the stairs. Thus another break-down of standards in the case of our permanent housing supply is proposed. It would partly undo one of the most important advances in fire standards made during the LaGuardia administration.

The form of occupancy now proposed is not new and actually was permitted until, in the LaGuardia administration, the present stricter requirements were imposed after several disastrous fires on the west side of Manhattan.

There has been much misconception about this proposal. Simply stated, it saves the owner an expense reliably estimated at $250 to install the fire protection features. This bill is a forgiveness bill of that item-nothing more or less. In other words, any owner can today comply with the law and effect the changes from which he is relieved by this proposal.

In this instance, too, I respectfully suggest that the committee is unduly optimistic in it estimates of 10,000 units by means of this forgiveness at the expense of adequate fire protection in our permanent housing. What basis is there for assuming that owners of single-family homes desiring privacy, or even two-family owners, will be induced to convert by this small gratuity? There is another feature to this proposal which merits consideration. I have endeavored, without success, to obtain an authoritative statement from the proper municipal department of the number of one- and two-story dwellings now illegally occupied. It is generally recognized that there are substantial violations of the law today in this respect. To the extent that such illegal occupancy does exist, to that extent will the potential supply which the majority believes will result from the amendment to the law be decreased. These dwellings afford no new housing accommodations. The principal effect of this change in the law would be to legalize a great deal of present illegal occupancy.

CAPITAL EXPENDITURE FOR TEMPORARY HOUSING

The recommendation by the majority for the outlay by the city of $25,000,000 to finance the temporary housing program-much as I favor the program-runs counter to sound governmental theory. This will take away from our citizens essential services for hospitals, schools, health, police, and fire protection, parks, and highways, all so much required. Our city, as is the case with most cities, can ill afford this diversion. The desperate housing crisis is a national one, arising from national causes connected with the war effort, restrictions on building, and the dislocation of hundreds of thousands of people. It is a condition which exists throughout the entire country and the responsibility for providing for veterans in temporary homes should, in the first instance, rest upon the Federal Government as a necessary cost of the war effort with supplementary responsibility upon the State. Immediate passage should be urged of the Mead bill for $190,000,000 to defray the cost of temporary housing. The passage of this bill does not necessarily mean that New York City will receive the $25,000,000 which the majority of the committee estimates as the cost for temporary housing. In addition, the full program of temporary housing recommended herewith, if adopted, will require additional funds. The State should supply a substantial amount and do it forthwith. The legislature meets within a period of several weeks and an appropriation of $50,000,000 for use by New York City and other cities in the State should be the first order of business. Once the need of a city for temporary housing is ascertained and financial aid granted by the State and Federal Governments, the administration of temporary housing should be at the local level of government and not by Federal or State Governments. This is in accord with well established and recognized policy of decentralization as the best means of administration.

Should the Federal and State Governments fail to give the needed financial assistance, which is quite unthinkable, only then should the city be called upon to expend its own capital funds. Pending action by the Federal and State Governments there need be no delay by the city in its temporary program. It should proceed at once, making commitments or advancing the necessary funds pending reimbursement. I respectfully suggest that you urge an amendment to the pending Mead bill which would permit reimbursement to a municipality which has had the initiative to proceed while legislation was pending.

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