Statement  of  the  Council  of  Housing  Producers

The  Council  of  Housing  Producers  is  an  organization  made  up  of  twelve  of
the  largest  housing  producers  in  the  United  States.  In  1970  the  members  of  the
Council  produced  in  excess  of  55,000  units  of  residential  construction.  Since  its
inception  in  1968,  the  Council  has  been  concerned  with  the  problems  of  low
and  moderate  income  housing ;  sources  of  equity  funding  and  mortgage  capital :
more  feasible  utilization  of  land :  changes  needed  in  building  codes  and  zoning
regulations ;  construction  techniques :  product  research  and  development  of
building  materials ;  federal,  state  and  local  taxation  policies ;  and  other  con-
straints and  issues  of  concern  which  affect  housing  production  in  the  United
States.
As  producers  of  housing.  Council  members  are  all  closely  involved  with
environmental  questions.  The  members  have  an  awareness  to  the  environ-
mental matters  which  affect  our  ecology  and  take  them  into  account  in  the
planning  of  their  developmental  programs.  The  Council  is  in  full  support  of
the  basic  goal  of  environmental  protection  which  the  sponsors  of  the  bill  are
endeavoring  to  achieve.  It  is  concerned,  however,  about  the  means  by  which
S.   1032  seeks  to  achieve  that  goal.   Specifically,

The  bill  is  excessively  broad  in  its  coverage ;

The  bill  may  be  subject  to  abuse ;  and

The  bill  remits  important  technical  and  policy  decisions  to  courts  which
probably  lack  the  technical  knowledge  and  experience  necessary  to  make
valid  judgments.
