exorbitant and grossly inflationary wage increases have been dramatically confirmed by a current survey of the actual work force rates paid here on conventionally financed high rise construction when compared with what would have been paid had the projects been subject to Davis Bacon. This survey, attached as Exhibit A, was prepared by the Miller and Long Co., Inc. one of the largest structural concrete subcontractors of this area and a Merit Shop company. The survey, covering over 300 employees in the nine workmen classifications common to this trade, reveals that a 37.9 percent increase in labor cost is the premium demanded by the current Davis Bacon wage decision. In all sanity, how can one Agency of the Federal Government (The Wage Stabilization Board and its C.I.S.C.) attain success in its purported goal of limiting wage increases to 5.5 percent while another (The Davis Bacon Section of the Labor Department) demands huge wage increases by the large open shop segment of the construction industry?

Efforts aimed at modification of the burdensome consequences inherent in treating commerical and high-rise residential construction identically, have met with little success. The ill-considered Mattapony decision of the Wage Appeals Board in 1965, holding that high-rise residential apartment construction in this area should be classified for purposes of wage determination, as general or commercial building rather than residential, still prevails. Differences in design load requirements, systems innovations (many of which were developed under HUD's Operation Breakthrough), method of construction, existing pay scales, and use of the structure are insufficiently persuasive to the Employment Standards Administration of the U. S. Department of Labor, when weighed against union shop rates maintained for general commercial construction. I submit, Mr. Chairman, that such a predisposition based on neither logic nor national housing policy, testifies to the immediate need for passage of S. 3654.

I appreciate this opportunity to discuss this problem in the context of two very timely legislative efforts affecting my industry.

Yours very truly,

Malah @GM

Malcolm 0. Garfink

President

MOG:crm

Enclosure

Payroll Information for the Peak Work Week by Classification of Workmen

HA FORM NO 2320-
UNE, 1970,

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
FEDERAL HOUSING ADMINISTRATION

APPROXIMATE COST:

DATE OF COMPLETION:

DATE CONSTRUCTION BEGAN:

OR PERCENTAGE OF COMPLETION:

Payroll Information for the Peak Work Week by Classification of Workmen

Classification

of
workmen

HA FORM 10 2320
40.1970

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
FEDERAL HOUSING ADMINISTRATION

APPROXIMATE COST:

DATE OF COMPLETION:

DATE CONSTRUCTION BEGAN:

OR PERCENTAGE OF COMPLETION:

Payroll Information for the Peak Work Week by Classification of Workmen

Classification

HA FORM NG 2320
JUNE, 1970

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
FEDERAL HOUSING ADMINISTRATION

DATE OF COMPLETION:

OR PERCENTAGE OF COMPLETION:

Payroll Information for the Peak Work Week by Classification of Workmen

Classification

I understand that this information will be released to the Department of Labor for
use in determining prevailing wage rates for residential construction under the
Davis-Bacon Act.
You may release identification of source of
above information.

6/14/72

Date

Please do not identify source of above information,
except where necessary in hearings on the issue of
the accuracy of statistical data compiled therefrom.

James thing

President
Signature and Title of Person Giving Information

Date

Signature and Title of Interviewer