Native American Housing: Information on HUD's Housing Programs for Native Americans

Published by the Government Accountability Office on 1997-03-28.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                 United States General Accounting Office

GAO              Report to the Subcommittee on VA,
                 HUD, and Independent Agencies,
                 Committee on Appropriations, House of

March 1997
                 NATIVE AMERICAN
                 Information on HUD’s
                 Housing Programs for
                 Native Americans

          United States
GAO       General Accounting Office
          Washington, D.C. 20548

          Resources, Community, and
          Economic Development Division


          March 28, 1997

          The Honorable Jerry Lewis
          The Honorable Louis Stokes
          Ranking Minority Member
          Subcommittee on VA, HUD,
            and Independent Agencies
          Committee on Appropriations
          House of Representatives

          Despite the Department of Housing and Urban Development’s (HUD)
          investment of $4.3 billion (in constant 1995 dollars) over the last decade,
          housing problems for low-income Native Americans are still more severe
          than for other Americans as a whole. In tribal areas,1 where three-quarters
          of a million American Indians and Alaska Natives live, the Urban Institute
          recently reported that 40 percent of the households live in overcrowded or
          physically inadequate housing, compared to only 6 percent of the U.S.
          population.2 Providing safe and decent housing at a reasonable cost in
          tribal areas is difficult because of the austere and remote nature of the
          setting. Moreover, the need for this housing is growing as Native
          Americans increase in number and more of them return to their

          In the Subcommittee’s June 18, 1996, report accompanying the fiscal year
          1997 appropriations bill, you requested that we evaluate HUD’s housing
          programs for Native Americans. As agreed with your offices, this report
          addresses the following questions:

      •   What have been the funding history and measurable results of the housing
          programs administered by HUD for Native Americans in or near tribal
      •   What are the significant factors that complicate and make costly the
          provision of housing assistance to Native Americans in or near tribal

           Tribal areas include reservations for American Indians, villages of Alaska Natives, and other special
          types of areas so designated by the U.S. Census.
           In 1993, HUD commissioned a study by The Urban Institute Center for Public Finance and Housing
          that resulted in the May 1996 report entitled Assessment of American Indian Housing Needs and
          Programs. The purposes of this study were to (1) evaluate the housing problems and needs of
          American Indians and Alaska Natives, (2) assess the effectiveness of existing federal housing programs
          in meeting those needs, and (3) compare alternative approaches and suggest ways in which federal
          policy could improve housing for Native Americans.

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                   •   What could be the initial impact of the recently enacted Native American
                       Housing Assistance and Self-Determination Act of 1996 on HUD’s oversight
                       of housing assistance to Native Americans living in or near tribal areas?
                   •   To what extent does gaming occur in tribal areas, what is its profitability,
                       and does HUD take revenues from gaming into account when allocating
                       funding to Indian housing authorities?

                       From fiscal year 1986 through fiscal year 1995, HUD provided $4.3 billion
Results in Brief       (constant 1995 dollars) for housing and community development in tribal
                       areas. Of this amount, HUD provided $3.9 billion to approximately 189
                       Indian housing authorities3 to develop and maintain affordable housing
                       and assist low-income renters. In this period, the authorities used the
                       funds to construct over 24,000 single-family homes, operate and maintain
                       existing housing, and encourage other development. Over the decade, HUD
                       also provided direct block grants totaling over $424 million to eligible
                       tribes for community development and mortgage assistance.

                       Many factors complicate and make costly the development and
                       maintenance of affordable housing for Native Americans. These factors

                   •   the remoteness and limited human resources of many Indian housing
                       authorities and the Indian communities they serve,
                   •   land-use restrictions and the inhospitality of the land,
                   •   the difficulty that contractors and Indian housing authorities have in
                       complying with statutory requirements to give hiring preference to
                       Indians, and
                   •   vandalism and neglect, which draw on scarce maintenance funds.

                       HUD  believes that, initially, its workload could increase as it monitors
                       tribes’ compliance with the new Indian housing legislation set to take
                       effect on October 1, 1997. The new act changes the way the Department
                       provides housing assistance to Native Americans by requiring block grants
                       to each of the over 550 federally recognized tribes in the continental
                       United States, Alaska, and Hawaii instead of categorical grants to the 189
                       Indian housing authorities that currently exist. Therefore, the number of
                       entities that HUD has to oversee and assist could increase significantly.
                       Moreover, to qualify for the block grants, tribes must submit housing plans
                       for HUD’s approval. Although the law requires HUD to conduct only a limited

                        An Indian housing authority is a business entity established by a tribal government, organized under
                       tribal or state law, to develop and manage assisted housing units.

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             review of the tribes’ plans, HUD officials believe that this activity will, for
             the first year at least, be a labor-intensive function for HUD field offices.

             Of the 356 Indian tribes in the continental United States alone, 177
             operated 240 gaming facilities as of July 1996.4 According to 1994 and 1995
             data submitted by 85 of these tribes, their gaming revenues after expenses
             totaled about $1.5 billion. HUD officials told us that they do not take gaming
             revenues directly into account when allocating funds because, in addition
             to these revenues, HUD would need to know other business revenues and
             federal assistance available to each tribe in order to determine a fair
             allocation. However, tribes generally can use gaming revenues for many
             purposes, including education, health facilities, and housing. Therefore, to
             the extent that HUD takes a tribe’s general economic well-being and
             housing needs into account, it is indirectly factoring gaming revenues into
             its funding allocation decisions.

             The United States Housing Act of 1937 established the Public Housing
Background   Program to provide decent, safe, and sanitary housing for low-income
             families. For many years, this act was interpreted to exclude Native
             Americans living in or near tribal areas. In 1961, however, HUD and the
             Bureau of Indian Affairs (BIA) determined that Native Americans could
             legally participate in the rental assistance for low-income families
             authorized by the 1937 act and issued regulations to implement this
             determination. In 1988, the Indian Housing Act established an Indian
             housing program separate from public housing under the Housing Act of
             1937 and prompted HUD to issue regulations specific to this program. With
             the recently enacted Native American Housing Assistance and
             Self-Determination Act of 1996 (regulations are scheduled to take effect on
             October 1, 1997), the Congress completed the process of separating Indian
             housing from public housing.

             According to the May 1996 report by the Urban Institute, the housing
             needs of Native Americans are growing. Their population rose sixfold over
             the past four decades to over 2 million in 1990, 60 percent of whom live in
             tribal areas or in the surrounding counties. Compared to non-Indians,
             Native Americans are more family-oriented—37 percent of Native
             American households are married couples with children versus 28 percent
             of non-Indian households. Compared to non-Indians, Native Americans
             have a higher unemployment rate (14 percent versus 6 percent), a smaller

              See Profile of Indian Gaming (GAO/GGD-96-148R, Aug. 20, 1996). We are currently updating this
             report with an analysis of more complete financial data.

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                          number of workers in “for-profit” firms per thousand people (255 versus
                          362), and a higher share of households with very low incomes (33 percent
                          versus 24 percent). Moreover, Indian housing conditions are much worse
                          than housing conditions in other areas of the country: 40 percent of Native
                          Americans in tribal areas live in overcrowded or physically inadequate
                          housing, compared to 6 percent of the U.S. population.

                          Through its Native American Programs headquarters office and its six field
                          offices, and with the help of approximately 189 Indian housing authorities
                          (IHA), HUD administers the majority of the housing programs that benefit
                          Native American families in or near tribal areas. Several significant
                          differences exist, however, between HUD’s assistance to these families and
                          to families (non-Indian and Indian) living in urban and other areas. First,
                          HUD’s support for Native Americans derives, in part, from the nation’s
                          recognition of special obligations to the Native American population and is
                          reflected in treaties, legislation, and executive orders. Second, the federal
                          government deals with recognized tribes directly in a
                          sovereign-to-sovereign relationship, rather than through the general
                          system of state and local government. This status allows tribes to establish
                          their own system of laws and courts. Third, the BIA often holds in trust a
                          considerable amount of land for a tribe as a whole; thus, this land is not
                          subdivided into many private holdings as occurs in the rest of the country.5
                           This trust arrangement has frustrated the development of private housing
                          markets in tribal areas and has long been seen as providing special
                          justification for government assistance in housing production.

                          Under current regulations, IHAs administer most of the low-income
HUD Provides Most         housing assistance that HUD provides to Native Americans. But HUD also
Funding for Housing       provides some housing assistance directly to tribes and individuals.
Assistance Through        Funding provided through housing authorities is used to

Indian Housing        •   develop housing for eventual ownership by individual families through the
Authorities               Mutual Help Program, under which families lease and then buy their home
                          by making payments to an IHA of approximately 15 percent of their income
                          and must cover their own routine operating and maintenance expenses;
                      •   develop and maintain rental housing for low-income families through the
                          Rental Housing Program, under which, as with the public housing
                          program, low-income families rent housing from the IHA at a cost of
                          30 percent of their adjusted income;

                           BIA also provides a relatively small amount of funding, approximately $20 million annually, through
                          its Housing Improvement Program for improving existing housing.

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•   modernize and rehabilitate established low-income housing through the
    public housing modernization program; and
•   subsidize IHAs to defray operating expenses that rental income does not
    cover and provide rental vouchers for low-income families.

    Funding available to tribes and individuals includes

•   loan guarantees for home mortgages,
•   block grants through the HOME Investment Partnership Program for
    tribes to develop affordable housing in tribal areas, and
•   community development block grants to enhance infrastructure and other
    economic development activities.

    Figure 1 shows the funding for fiscal year 1995 for these programs, and
    table 1 describes the programs’ results.

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Figure 1: Funding for Major Housing
and Community Development                                                                 Rental Housing Program $121
Programs for Native Americans, Fiscal
Year 1995 (Dollars in Millions)                                                           13.17%
                                                                                          Operating subsidies $71

                                                                                          Section 184 loan guarantees $3

                                                                    22.82% •              Mutual Help Program $123

                                          • 22.45%
                                                                            •             8.53%
                                                                                          Community Development Block
                                                                        •                 Grant Program $46


                                                                                          HOME program $14

                                                                                          Modernization program $161

                                        Source: Based on data from HUD’s Office of Native American Programs.

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Table 1: Results of Major Housing and
Community Development Programs for      Dollars in millions
Native Americans, Fiscal Year 1995                                 Funding for
                                        Program                       FY 1995 Significant results
                                        Mutual Help                      $123 1,289 units planned
                                        Rental Housing                    121 495 units planned
                                        Modernization of                  161 Funded modernization activities such as
                                        low-income                            replacing roofs and converting and
                                        housing                               enlarging many of the 82,000 units
                                                                              managed by IHAs
                                        IHAs’ operating                    71 Subsidized IHA expenses for preventive
                                        subsidies                             maintenance, planning, rent collection,
                                                                              tenant counseling and contracting
                                        Section 184 loan                     3 Provided guarantees for 477 units
                                        HOME                               14 Provided grants to 12 Native American
                                        Investment                            tribes to construct 303 new houses,
                                        Partnership                           rehabilitate 191 houses, and acquire 54
                                        Program                               houses
                                        Community                          46 Approved projects for housing
                                        Development                           rehabilitation, infrastructure, buildings
                                        Block Grant                           (such as community buildings), and
                                        Program                               economic development
                                        Total                            $539 2,434 units planned

                                        As shown in figure 2 and table 2, over the past decade HUD provided a total
                                        of $4.3 billion for these programs, which have produced or planned to
                                        produce a total of 24,002 housing units. Additional information on the
                                        funding and the programs is contained in appendix I.

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Figure 2: Funding for Major Housing
and Community Development                                                                   12.61%
Programs for Native Americans, Fiscal                                                       Operating subsidies $548
Years 1986-95 (Constant 1995 Dollars in
Millions)                                                                                   0.07%
                                                                                            Section 184 loan guarantees $3

                                                                                            HOME program $54

                                                                                            Community Development Block
                                                                                            Grant Program $370


                                                                      37.12% •              Mutual Help Program $1,612


                                                              19.13% •                      Rental Housing Program $829

                                                                                            Modernization program $926

                                          Source: Based on data from HUD’s Office of Native American Programs.

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Table 2: Results of Major Housing and
Community Development Programs for          Constant 1995 dollars in millions
Native Americans, Fiscal Years                                                  Funding for
1986-95                                     Program                              FY 1986-95 Significant results
                                            Mutual Help Program                      $1,612 15,721 units completed
                                            Rental Housing                              829 8,281 units completed
                                            Modernization of                            926 Rehabilitated housing units to meet
                                            low-income housing                              HUD’s standards and upgraded
                                                                                            IHAs’ management, financial, and
                                                                                            accounting control systems
                                            IHAs’ operating                             548 Subsidized IHAs’ expenses for
                                            subsidies                                       managing the 82,000 assisted units
                                                                                            and provided funding for various
                                                                                            management activities
                                            Section 184 loan                              3 Provided guarantees for 477 units in
                                            guarantees                                      1995,the program’s first year
                                            HOME Investment                              54 Provided 59 grants to construct,
                                            Partnership Program                             rehabilitate, and acquire houses
                                            Community                                   370 Supported housing programs and
                                            Development Block                               homeownership assistance; the
                                            Grant Program                                   construction of community facilities,
                                                                                            such as roads, water, and sewer
                                                                                            facilities and community buildings;
                                                                                            and economic development activities
                                            Total                                    $4,342 24,002

                                            The cultural and geographic environment of tribal areas differs from
Providing Housing                           mainstream America and causes HUD and IHAs to encounter unique
Assistance for Native                       challenges and costly conditions as they administer and provide housing
Americans Is                                programs for Native Americans. Because there are over 550 separate
                                            Indian nations, with unique cultures and traditions, not all of these
Challenging and                             conditions are equally prevalent throughout tribal areas, nor do they have
Costly                                      a common impact on developing and maintaining housing. Among the
                                            challenges and conditions highlighted in our discussions with officials of
                                            HUD and several IHAs, as well as in the May 1996 study by the Urban
                                            Institute, are

                                        •   the remoteness and limited human resources of many IHAs and the Native
                                            American communities they serve;
                                        •   the lack of suitable land and the inhospitality of the climate;
                                        •   the difficulty contractors and IHAs have in complying with statutory
                                            requirements to give hiring preference to Native Americans; and

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                                       •   the pressure that vandalism, tenants’ neglect, and unpaid rent put on
                                           scarce maintenance funds.

Remote Reservations Limit                  The extent and pattern of Native American landholding are very different
Infrastructure and                         today from what they were at the beginning of the 19th century. During
Availability of Human                      that century, the land area over which Indians had sovereignty and which
                                           was available for creating reservations was often reduced to small pieces
Resources                                  in isolated areas.

                                           The remoteness of some tribal areas has created significant problems for
                                           housing development. In contrast to metropolitan areas, where basic
                                           infrastructure systems (sewers, landfills, electricity, water supply and
                                           treatment, and paved roads) are already in place, remote tribal areas
                                           require a large capital investment to create these systems to support new
                                           housing. Table 3 shows the investment needed at the Gila River Housing
                                           Authority in Sacaton, Arizona, to build a single-family home. According to
                                           HUD officials, the cost of site improvements—creating and connecting to
                                           the “off-site” infrastructure—is 43 percent higher than for a public housing
                                           project in an urban area near the Gila River Indian Reservation.

Table 3: Typical Costs of Building a
New Gila River Home and Connecting                                                                                       Percent of
It to Needed Services                      Expense Category                                                       Cost        total
                                           Administration                                                       $4,522           6
                                           Homeowner counseling and training                                       803           1
                                           Planning and surveys                                                  7,693          10
                                           Site improvements and off-site infrastructure                        16,780          22
                                           Construction of dwelling                                             39,049          50
                                           Dwelling equipment (e.g., ranges and refrigerators)                     707           1
                                           Structures for storage and vehicles                                   8,000          10
                                           Total                                                               $77,554         100

                                           Source: HUD’s Southwest Office of Native American Programs.

                                           The remoteness of many of the tribal areas also increases the cost of
                                           transporting supplies, raises labor costs, and reduces the availability of
                                           supplies and of an “institutional infrastructure” of developers and
                                           governmental and private entities. For example, transporting a drilling rig
                                           over many miles and hours into the desert to a tribal area in California is
                                           far more costly than if the well had been needed in a less remote area. In

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addition, in its study of Native Americans’ housing needs, the Urban
Institute found that private housing developers, contractors, and suppliers;
governmental planners and building inspectors; private financial
institutions; and nonprofit groups6 are all less available in remote tribal

The limited human resources of many IHAs also contribute to the high cost
of developing and maintaining housing. HUD’s Deputy Assistant Secretary
for Native American Programs told us that housing authorities that recruit
their staff from a small tribal population often have difficulty finding
qualified managers to administer multimillion-dollar housing grants. This
problem is made worse when coupled with the statutory requirement to
give Indians first consideration for such jobs. According to the Deputy
Assistant Secretary, because many Indian applicants lack formal
education, the time they need to become familiar with specialized housing
operations can be longer than that needed by applicants from the larger
pool enjoyed by a public housing authority in an urban area.

The executive director at the Gila River Housing Authority echoed these
views when he described his inability to hire skilled and dependable tribal
members. He pointed out that many skilled members have personal
problems caused by drugs and alcohol, causing the housing authority to
search outside the tribal area for much of its labor force. He also said that
because members of the available semiskilled workforce need a significant
amount of training before they are employable, he cannot afford to hire
them. Moreover, some of the tribe’s laborers are drawn to cities away from
the reservation, he explained, because of the greater employment
opportunities and higher wages there.

This lack of skilled human resources is costly. HUD officials told us that as
a general rule in the construction industry, labor costs should not exceed
50 percent of the total cost, but in tribal areas labor costs can run as high
as 65 percent because contractors generally have to bring in skilled
workers and pay for lodging or commuting costs.

 Most of the few nonprofits that do exist are either just beginning operations or have operated less
than 2 years in tribal areas. In its preliminary investigation for a HUD-funded study due out this month,
the National American Indian Housing Council has identified only six nonprofit organizations that
provide housing assistance to tribes.

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Land-Use Restrictions and   Although the dominant visual impression in many tribal areas is a vast
the Inhospitality of the    expanse of unused land, a lack of available land is, in fact, a constraint that
Land Complicate the         many IHAs face as they develop low-income housing. Factors that limit the
                            availability of land for housing include the trusts in which BIA holds the
Development and             land that, until this year, limited leases to 25 years in many instances.
Maintenance of              Special environmental and other restrictions also exist. For example, in
Low-Income Housing          planning for development, IHAs and tribes avoid archaeological and
                            traditional burial sites because cultural and religious beliefs preclude
                            using these sites for housing. In many cases, sufficient tribal land exists for
                            housing, but environmental restrictions prohibit the use of much of it for
                            housing. The Urban Institute’s survey of IHAs revealed that, overall,
                            wetlands restrictions, water quality considerations, and contaminated soils
                            add to the cost of housing in tribal areas.

                            In the Western desert, once low-income housing is developed, the severity
                            of the climate can complicate maintenance. The effects of the high salt and
                            mineral content in the water and soil were evident at the Gila River
                            Housing Authority, where water damages water heaters and copper and
                            cast iron pipes. The executive director told us that the average life of a hot
                            water heater costing $300 is about 6 months. To remedy the problem with
                            the corrosion of plumbing, the Gila River IHA has begun placing plumbing
                            in ceilings for better access and converting to plastic piping. The high
                            mineral content in the water also damages water circulation systems of
                            large fans called “swamp coolers,” used for summer cooling. The executive
                            director told us that because of calcium buildup, the IHA must replace the
                            coolers annually. He also explained that the soil’s high salt content causes
                            housing foundations and sewer systems to deteriorate. Figures 3 and 4
                            illustrate the damage caused to swamp coolers and foundations.

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Figure 3: Corroded Swamp Cooler at
the Gila River Indian Reservation,

                                     Page 13    GAO/RCED-97-64 Native American Housing

Figure 4: Deteriorated House
Foundation at the Gila River Indian
Reservation, Arizona

Complying With Indian                 Certain statutes, including the Indian Self Determination and Education
Hiring Preference and                 Assistance Act and the Davis-Bacon Act,7 are intended to protect and
Davis-Bacon Act                       provide opportunities for specific groups. However, IHA officials and HUD
                                      officials whom we contacted believe that these statutes can make
Requirements Adds                     developing housing in tribal areas more costly because they have the the
Additional Burden to IHAs             effect of raising the cost of labor in comparison to local wage rates or
                                      restricting the supply of labor.

                                      The Indian Self Determination and Education Assistance Act of 1975
                                      requires IHAs to award contracts and subcontracts to Indian organizations
                                      and Indian-owned economic enterprises. IHA executive directors find that
                                      complying with the requirement is difficult and believe that it adds to
                                      contractors’ time and cost to bid on work for IHAs. The officials said that
                                      factors that undermine the requirement include a lack of qualified Indian
                                      contractors in the area, the creation of fraudulent joint ventures that are
                                      not owned or managed by Indians, and the occasional need to use
                                      qualified firms outside the region that do not understand local conditions.

                                       The Davis-Bacon Act provides that workers in certain trades involved in federal construction
                                      contracts be paid wages determined by the Secretary of Labor to be prevailing in the area of

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                        Under the Davis-Bacon Act, firms that contract with IHAs for housing
                        development must pay wages that are no less than the wage rates
                        prevailing in the local area. However, HUD officials told us that this
                        requirement generally increases IHAs’ cost of developing housing in tribal
                        areas. The increased cost occurs because the applicable Davis-Bacon wage
                        rate is often based on HUD’s wage surveys of large unionized contractors
                        who are based in larger metropolitan areas; therefore, the rate is about
                        $10.00 per hour higher than the wage rate prevailing in the local tribal
                        area. Officials of the Chemehuevi Housing Authority, in California, told us
                        that because of high Davis-Bacon wage rates, their cost to develop a single
                        family home ranges between $85,000 and $98,000. Using the prevailing rate
                        of approximately $6.50 to $8.00 per hour, they estimate the development
                        cost to be between $65,000 and $80,000. .

Neglect and Vandalism   If housing units are abused through neglect or vandalism and not
Draw on Maintenance     well-maintained on an ongoing basis, costly major repairs can be needed.
Budgets That Are        These avoidable repairs put pressure on maintenance budgets that are
                        shrinking because of the high rate of unpaid rent in tribal areas. Moreover,
Shrinking Because of    maintaining assisted housing for Native Americans is an increasingly
Unpaid Rent             difficult challenge because of its age—44 percent of the stock was built in
                        the 1960s and 1970s.

                        For housing units in HUD’s Rental Housing Program for Native Americans,
                        the Urban Institute reported that 65 percent of the IHA officials responding
                        to its telephone survey identified tenants’ abuse and vandalism of vacant
                        homes as the factors contributing most to maintenance costs. The Urban
                        Institute also reported that fewer than 10 percent of the officials identified
                        any of the survey’s other contributors to maintenance costs, including
                        poor materials, poor construction, and a lack of preventive maintenance.
                        For units under the Mutual Help Program (which are owned or leased by
                        the residents), the Urban Institute reported that IHA officials cited
                        residents’ neglect to perform needed maintenance as accounting for
                        30 percent of poor physical conditions of this segment of the housing

                        Our discussions with IHA officials reinforce these findings. The executive
                        director at the Gila River Housing Authority told us that vandalism by
                        juveniles was a major problem for him and that because the tribal area
                        borders Phoenix, Arizona, it is more susceptible to gang activity and
                        violence. Chemehuevi Housing Authority officials pointed out that once a
                        family that has neglected to perform expected maintenance moves out and

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                                         the tribe turns the housing back to the IHA, the housing authority often
                                         incurs a large and unexpected rehabilitation cost before it can lease the
                                         unit to another family. Figure 5 shows the effects of vandalism at the Gila
                                         River Indian Reservation.

Figure 5: Effects of Vandalism at the
Gila River Indian Reservation, Arizona

                                         The high level of unpaid rent among assisted Native American families has
                                         exacerbated the problem of accomplishing needed maintenance. Routine
                                         and preventive maintenance is an operating expense that an IHA pays for
                                         with rental income and an operating subsidy that HUD provides to help
                                         defray expenses. However, according to HUD, appropriations for these
                                         subsidies have not been sufficient to cover all operating expenses not
                                         covered by rental income. Therefore, shortfalls in rental income will
                                         generally result in less funds to spend on maintenance.

                                         In recent years, these shortfalls have been at high levels for both the
                                         Rental Housing and the Mutual Help programs. For example, the Urban
                                         Institute reported that at the end of 1993, 36 percent of all tenants in the
                                         rental program were delinquent in their rent payments, and the cumulative

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                           accounts receivable for tenants’ rent averaged $208 per rentable unit. In
                           contrast, the average delinquency rate in public housing is only 12 percent.

                           To counter shortfalls in rental income, some IHAs enforce strong eviction
                           policies. Others, on the other hand, are either unwilling or unable to do so.
                           They attributed their ineffective policies to such factors as tribal court
                           systems that do not support evictions, the conflict of such policies with
                           tribal culture, and their own lack of forceful management. Regardless of
                           the reason, these shortfalls coupled with insufficient operating subsidies
                           likely will lead to deferred maintenance and higher costs for major repairs
                           in the future.

                           By establishing a block grant mechanism to replace all housing assistance
Native American            that tribes currently receive indirectly through their IHAs and HUD—except
Housing Assistance         for the funding set aside for Native Americans in the Community
and Self-                  Development Block Grant Program—the act allows greater discretion for
                           tribes to address their housing needs. Moreover, block grants will ensure
Determination Act of       that Indian housing is separate from public housing not only
1996 Could Initially       administratively in HUD’s line organization—as the 1988 legislation
                           accomplished—but also financially.
Increase HUD’s
Workload                   The new statute stipulates that tribes will not receive less housing
                           assistance under the new law than they did in fiscal year 1996 for the
                           modernization of existing rental housing and operating subsidies to pay
                           for expenses not covered by rental income.8 Among other provisions, the
                           new statute also provides the following:

                       •   The existing housing authority or some other entity designated by a tribe
                           must administer the block grant funds and develop 1-year and 5-year
                           housing plans for HUD’s approval. The 1-year plan must present (1) a
                           statement of housing needs, (2) the financial resources available to the
                           tribe, and (3) a description of how the available funds will be used to
                           leverage additional resources.
                       •   In distributing the block grants, HUD shall consider, among other factors,
                           (1) the number of low-income housing units that a tribe already owns or
                           operates, (2) the extent of poverty and economic distress and the number
                           of Native American families, and (3) other objectively measurable
                           conditions specified by HUD and the tribe. These conditions could include
                           the relative affluence and other sources of income, if known, of the tribe.

                            This stipulation holds unless the total appropriation for all assistance is less than the amount received
                           in 1996 for modernization and operation.

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•   The Secretary of HUD shall monitor block grant recipients—who must
    submit performance reports to the Secretary—for compliance with the law
    and take corrective actions when a tribe or its housing entities do not
    comply with the program’s requirements.
•   A tribe can pledge future grant funds to secure a guaranteed loan and can
    lease land held in trust for up to 50 years.

    The new act could, at least initially, cause HUD’s oversight workload to
    increase. One reason for this is that the number of entities receiving
    funding will likely rise: Under current law, HUD funds only 189 IHAs, while
    under the new law, HUD may have to fund all 550 tribes independently.
    Both HUD and IHA officials we contacted believe that tribes will abandon
    some “umbrella” IHAs—those that serve more than one tribe—that have
    not performed well. And some tribes will simply choose to manage their
    own housing assistance programs.

    HUD’s  Deputy Assistant Secretary for Native American Programs believes
    that new requirements needing oversight, such as the housing plans, and
    tribes’ new opportunities, such as the borrowing program and ability to
    lease land for up to 50 years, will put added pressure on HUD’s field offices
    to work closely with the grant recipients. He said that during the first years
    after the new act is in effect, HUD will need to monitor all tribes or housing
    entities to determine their initial understanding of and compliance with
    the new statute and its provisions.

    Other HUD officials and Indian housing officials we contacted at two IHAs
    generally viewed the new legislation positively and said that the most
    attractive feature of the act is the new flexibility it offers for developing
    housing. They also cited the availability of a lease of 50 years—increased
    from the current 25 years—which will provide lenders an incentive to
    enter into mortgage agreements with Native Americans who lease land
    with the intention of building a home. The executive director of the
    National American Indian Housing Council said that the annual plans will
    require a kind of housing needs assessment that heretofore has not been
    done. She believes, moreover, that the new program’s success will depend
    on the extent to which HUD is effective in reviewing the required plans,
    monitoring the tribes’ implementation of the plans, and acting on potential

    Page 18                                  GAO/RCED-97-64 Native American Housing

                           About 177, or half of the 356 federally recognized tribes in the continental
Many Tribes Receive        United States operated gaming facilities as of July 1996. As we reported in
Gaming Revenues, but       August 1996,9 our analysis of financial statements submitted for fiscal
HUD Does Not               years 1994 and 1995 by the 85 tribes that responded by May 5, 1996, to the
                           National Indian Gaming Commission’s (NIGC) request for information
Consider Them              shows that Indian gaming activities provide an additional, and in many
Directly When              cases significant, source of revenues.10 These 85 tribes operated 110
                           gaming facilities and earned a total net income (after all expenses) of
Determining Housing        $1.5 billion.11
                           HUD  does not take these revenues into account directly as it assesses IHAs’
                           needs for federal housing assistance because the Department has not
                           obtained the financial information describing tribes’ gaming activities or
                           financial resources. Therefore, HUD cannot relate the revenues and assets
                           to tribes’ housing needs. Moreover, tribes’ income from gaming, as from
                           other sources, accrues directly to the tribes rather than the IHAs and can be
                           used to provide a wide range of economic assistance to tribal
                           communities. Thus, to the extent that gaming revenues enhance tribes’
                           overall economic well-being, HUD considers them indirectly in its funding

For Many Tribes, Gaming    The 85 tribes reported total revenues from their gaming facilities of
Revenues Are Significant   $3.8 billion, from which they derived their net revenues of $1.5 billion. Of
                           this amount, 74 tribes received about $1.2 billion in transfers from their
                           gaming facilities. The Indian Gaming Regulatory Act requires that tribes
                           use these transferred revenues for tribal, governmental, or charitable
                           purposes in accordance with a revenue allocation plan approved by BIA.
                           The allocation plan may also provide for the distribution of a portion of
                           the net income directly to individual tribal members.

                           Our analysis of the income transferred from facilities to the 74 tribes
                           shows that transfers ranged from about $17,000 to over $100 million. The
                           remaining 11 tribes did not receive transfers from their gaming facilities.
                           More than two-thirds of the 85 tribes received $10 million or less from

                            See Profile of Indian Gaming (GAO/GGD-96-148R, Aug. 20, 1996). We are currently updating this
                           report with an analysis of more complete financial data.
                             The NIGC was established under provisions of the Indian Gaming Regulatory Act (P.L. 100-497, 102
                           Stat. 2467) with specified authority over the conduct of gaming on tribal lands and the obtaining of
                           financial records summarizing the activities.
                             A total of 177 tribes operated 240 gaming facilities as of July 1996, but as of May 5, 1996, only 85 had
                           reported their financial results to the NIGC. Expenses do not include federal income taxes because
                           Indian tribes are not subject to them.

                           Page 19                                                  GAO/RCED-97-64 Native American Housing

                                       gaming. Transfers to the tribes may not have occurred for several reasons,
                                       including a facility’s not having net income for the year-end, not having
                                       accumulated earnings from prior years, or retaining all of the year’s net
                                       income. About $300 million was retained by the gaming facilities. Figure 6
                                       shows the results of our analysis of the transfers.

Figure 6: Number of Tribes Receiving
Transfers of Gaming Income, Fiscal     50
Years 1994-95





                                                         12          12

                                       10                                                       8



                                              Less        Greater     Greater        Greater        Greater
                                              than or     than        than           than           than
                                              equal to    $5M,        $10M,          $20M,          $50M
                                              $5M         less        less           less
                                                          than or     than or        than or
                                                          equal to    equal to       equal to
                                                          $10M        $20M           $50M

                                       Note: Eleven tribes received no transfers of gaming income.

                                       Source: Based on the most recently filed financial statements for gaming facilities submitted to
                                       the NIGC for either 1994 or 1995.

                                       Our analysis of the distribution to individual tribal members shows that BIA
                                       had approved 34 of the reported 177 tribes with gaming facilities to
                                       distribute a portion of their net revenues directly to tribal members. The
                                       proportion of net revenues to be distributed ranged from 2 percent to
                                       69 percent.

                                       Page 20                                                                GAO/RCED-97-64 Native American Housing

HUD Is Not Required and    For the most part, housing needs are the primary factor that HUD is
Lacks the Data to Take     required to consider when allocating funds to IHAs for housing programs.
Gaming Revenues Directly   And tribes’ economic well-being, to the extent that HUD can determine it, is
                           the deciding factor when allocating community development funding to
Into Account               them. HUD provides this funding to IHAs on the basis of projected operating
                           expenses or applications for grant funds that demonstrate housing needs
                           in accordance with a specified formula used to allocate funding across all
                           housing authorities. By regulation, HUD also awards new housing
                           development funds to IHAs through a competitive process based on factors
                           such as housing needs, the length of time since last funding award,
                           occupancy levels of existing units, and the current mix and status of units
                           under construction.

                           For community development programs—such as the Community
                           Development Block Grant Program and the HOME Investment Partnership
                           Program—HUD provides funding directly to tribes instead of to IHAs. For
                           these programs, HUD officials explained that tribes compete for these funds
                           on the basis of the number of low-income persons needing assistance.
                           According to HUD officials, tribes that generate significant income from
                           tribal businesses (including gaming) generally do not have a large enough
                           number of low-income persons and, therefore, do not rank high enough to
                           receive funds in these programs. The household income of low- and
                           moderate-income beneficiaries of funds from the Community
                           Development Block Grant Program, for example, generally must not
                           exceed 80 percent of the median income for the area. In reporting these
                           income levels to HUD, the applicants are required to identify distributions,
                           if any, of tribal income (from gaming or other sources) to families,
                           households, and individuals.

                           The Deputy Assistant Secretary told us that none of these funding criteria
                           requires HUD to consider the specific amount and use of revenues that
                           tribes receive from gaming or other sources. However, we believe that
                           such information could be available to HUD if the Department took the
                           necessary actions to obtain it.

Under Block Grants, HUD    The Native American Housing Assistance and Self-Determination Act of
Could Compare Housing      1996 does not specifically require HUD to take gaming or other revenues
Needs With Business        into account for funding purposes. Nevertheless, the act requires HUD to
                           develop a housing assistance allocation formula that reflects the housing
Revenues If They Were      needs of Indian tribes and is based on (1) the number of low-income units
Known                      owned or operated pursuant to a contract between the Department and

                           Page 21                                 GAO/RCED-97-64 Native American Housing

                  IHAs; (2) the extent of poverty and economic distress within tribal areas;
                  and (3) other objectively measurable conditions specified by HUD, which,
                  we believe, could include business revenues.

                  HUD’s  Deputy Assistant Secretary for Native American Programs told us
                  that if HUD is required or chooses to use a tribe’s gaming revenues to offset
                  its need for housing assistance, then certain other information also would
                  need to be known and factored into the funding allocation decision. For
                  example, consistent treatment of all tribes would require that HUD also
                  know the amounts of significant tribal revenues from other sources, such
                  as land leases and mineral rights sales, as well as from other federal
                  programs that assist Native Americans.

                  We provided a draft this report to HUD, the National American Indian
Agency Comments   Housing Council, the Gila River Indian Housing Authority, and the
                  Chemehuevi Housing Authority for review and comment. We discussed
                  the report with officials of each agency, including the Deputy Assistant
                  Secretary for Native American Programs and the executive directors of the
                  Housing Council and the two IHAs. These officials commented that the
                  report accurately described the results of HUD’s Indian housing programs
                  and their special environmental and cultural conditions.

                  For information on Native American housing programs, including funding
Scope and         and results and the factors that complicate HUD’s delivery of those
Methodology       programs, we obtained data from various sources. We reviewed pertinent
                  legislation, HUD’s documentation on the programs, its regulations on Indian
                  housing, reports by its Office of Inspector General, and reports by the
                  Urban Institute’s Center for Public Finance and Housing. We discussed
                  issues with officials from HUD’s headquarters Office of Native American
                  Programs in Denver, Colorado, and field offices in Denver, Colorado, and
                  Phoenix, Arizona. We also interviewed HUD’s Rocky Mountain District
                  Inspector General for Audit and the Executive Director of the National
                  American Indian Housing Council. In addition, we visited the Gila River
                  Housing Authority, Sacaton, Arizona, and Chemehuevi IHA, Havasu Lake,
                  California, to meet with officials and gain a perspective of HUD’s Indian
                  housing programs and observe the condition of housing units.

                  We drew from our August 1996 report on Indian gaming for information on
                  the extent of gaming on tribal lands, its profitability, the revenue
                  distribution. To determine gaming’s impact on HUD’s funding allocation

                  Page 22                                  GAO/RCED-97-64 Native American Housing

decisions, we reviewed the regulations governing HUD’s funding of Indian
housing and we spoke with officials from HUD, primarily HUD’s Deputy
Assistant Secretary for Native American Programs.

We performed our work from August 1996 through February 1997 in
accordance with generally accepted government auditing standards.

As arranged with your offices, we plan send copies of this report to other
appropriate Senate and House committees; the Secretary of HUD; the
Commissioner of Indian Affairs, BIA; and the Director, Office of
Management and Budget. We will make copies available to others on
request. Please call me at (202) 512-7631 if you or your staff have any
questions. Major contributors to this report are listed in appendix II.

Judy A. England-Joseph
Director, Housing and Community
  Development Issues

Page 23                                 GAO/RCED-97-64 Native American Housing
Appendix I

Funding and Results for Major Housing
Programs for Native Americans

                         The funding for and accomplishments of HUD’s housing and community
                         development programs for Native Americans have been steady or
                         increasing in proportion to the increases in the Department of Housing
                         and Urban Development (HUD) appropriations over the 1986-95 decade, as
                         discussed below.

                         HUD’s Indian Housing Development Program consists of two
Indian Housing           components—the Rental Housing Program1 and the Mutual Help Program.2
Development Program       From 1961, when Native Americans first began to receive assistance
Is the Primary Vehicle   under the Housing Act of 1937, through fiscal year 1995, HUD provided
                         Indian housing authorities (IHA) over $5 billion (in nominal dollars) for
for Funding              Indian housing programs and constructed over 82,000 units. About
                         one-third of the construction has taken place during the 10-year period
                         between 1986 and 1995. As shown in the figures below, over the 10-year
                         period, HUD provided almost $2.4 billion to 189 IHAs specifically to develop
                         housing for low-income families. With these funds, the IHAs have built or
                         planned to build over 24,000 housing units. Sixty-five percent of these
                         units, 15,721, were Mutual Help units and the remainder were Low-income
                         Rental units.

                          Under the Rental Housing Program, IHAs rent housing to eligible low-income families for a payment
                         that is the highest of 30 percent of the family’s adjusted income, 10 percent of its annual income, or the
                         portion of the family’s public assistance allocated specifically for housing.
                          Through its Mutual Help Program, HUD provides homeownership opportunities and financial
                         assistance to qualified low-income Native American families to purchase—after leasing for 15 to 20
                         years—decent, safe, and sanitary housing of modest design.

                         Page 24                                                 GAO/RCED-97-64 Native American Housing
                                     Appendix I
                                     Funding and Results for Major Housing
                                     Programs for Native Americans

Figure I.1: Indian Housing
Development Program’s Funding for    Constant 1995 dollars in millions
the Mutual Help and Rental Housing                     266

Programs, Fiscal Years 1986-95


                                                                                                                          168        165

                                     140    130                                                                     127
                                                                                                                                                123 121

                                                                              91                                                           93
                                      90                                                                                        84
                                                             79          78                   79

                                             1986      1987        1988        1989      1990       1991       1992        1993       1994       1995
                                             Fiscal years

                                                       Mutual Help Program

                                                       Rental Housing Program

                                     Source: Based on data from HUD’s Management Information and Retrieval System’s (MIRS)

                                     Page 25                                                       GAO/RCED-97-64 Native American Housing
                                      Appendix I
                                      Funding and Results for Major Housing
                                      Programs for Native Americans

Figure I.2: Indian Housing
Development Program’s Housing Units   Number of units reserved
Fiscal Years 1986-95                                      2533



                                                                                                             1785                   1783


                                      1400   1344                                                                         1348
                                                                                    856                                                    883
                                       900                       822
                                                                                                       672          647

                                                1986      1987          1988         1989        1990          1991        1992      1993         1994         1995
                                                Fiscal years

                                                          Mutual Help Program

                                                          Rental Housing Program

                                      Source: Based on data from HUD’s MIRS database.

                                      Under its housing modernization program, HUD provides funds to IHAs to
Modernization                         rehabilitate properties in deteriorated physical condition and to upgrade
Program Also                          the management and operation of existing Indian housing developments.
Supports IHAs’                        HUD allocates modernization funds under both the Comprehensive Grant
                                      Program (CGP) to IHAs that own or operate 250 or more units and the
Housing                               Comprehensive Improvement Assistance Program (CIAP) to IHAs with fewer
                                      than 250 units. Overall, since 1986, congressional appropriations to HUD for
                                      the modernization of all public housing have steadily increased, and IHAs
                                      have benefitted proportionately. However, as is shown in table I.1, after
                                      HUD implemented the CGP in fiscal year 1992, funding for CIAP declined, and
                                      in fiscal year 1995, funding for both programs declined.

                                      Page 26                                                                GAO/RCED-97-64 Native American Housing
                                        Appendix I
                                        Funding and Results for Major Housing
                                        Programs for Native Americans

Table I.1: Funding for the
Modernization Program, Fiscal Years     Nominal dollars in millions
1992-95                                 Program                       FY 1992             FY 1993           FY 1994            FY 1995
                                        CIAP                            $35.3               $25.9             $25.6              $22.5
                                        CGP                              86.3               137.3             146.4              138.9
                                        Total                          $121.6              $163.2            $172.0             $161.4

                                        Source: Based on data from HUD’s Letter of Credit Control System’s (LOCCS) database.

                                        Section 9 of the United States Housing Act of 1937, as amended, authorizes
Operating Subsidies                     HUD to subsidize the operation of low-income public housing projects.
Provide Funds for                       Because rental income may not be sufficient to cover all the expenses
IHAs’ Ongoing                           incurred by a housing authority in its operation and maintenance of rental
                                        housing, HUD provides such subsidies to IHAs through its Performance
Expenses                                Funding System on the basis of their projected operating expenses. The
                                        subsidy amount for an IHA is the difference between the projected estimate
                                        of operating costs and an estimate of income from rents and other
                                        sources. Overall, HUD has provided just over $500 million in operating
                                        subsidies to IHAs for Indian housing programs between 1985 and 1995. As
                                        shown in table I.2, since 1992 the trend in HUD’s funding for operating
                                        subsidies for the Mutual Help and Rental Housing programs has been
                                        upward, with a sharp increase (almost 34 percent) for the latter program
                                        between 1993 and 1994. Well over 60 percent of the operating subsidy
                                        funding HUD provided IHAs supported the Rental Housing Program.

Table I.2: IHAs’ Operating Subsidies,
Fiscal Years 1992-95                    Nominal dollars in millions
                                        Indian housing program
                                        needing operating subsidy               FY 1992       FY 1993         FY 1994          FY 1995
                                        Mutual Help Program                        $9.0             $10.0        $15.0           $17.0
                                        Rental Housing Program                     37.0              41.0         55.0            54.0
                                        Turn Key III Programa                       0.7               0.5           1.5               0.4
                                        Total                                     $46.7             $51.5        $71.5           $71.4
                                         The Turn Key III Program is the management component for “Turn Key” units and provides
                                        homeownership opportunities for low-income families using a lease purchase arrangement. HUD
                                        has not funded the development of “Turn Key” housing units since 1979.

                                        Source: Based on data from HUD’s LOCCS database.

                                        Page 27                                             GAO/RCED-97-64 Native American Housing
                      Appendix I
                      Funding and Results for Major Housing
                      Programs for Native Americans

                      Section 184 of the Housing and Community Development Act of 1992
Loan Guarantee        authorized the Indian Home Loan Guarantee Program to give Indian
Program Is Another    families and IHAs access to sources of private financing that might
Source of Funding     otherwise not be available without a federal guarantee. HUD uses the funds
                      to guarantee loans for constructing, acquiring, or rehabilitating one to four
                      family dwellings per loan. The guaranteed loans must be for homes that
                      are standard housing (i.e., conforming to HUD’s standards), located on
                      Indian trust lands, or in Native American tribal areas. The approval of
                      guarantees is based on applicants’ having a satisfactory credit record,
                      enough cash to close the loan, and sufficient steady income to make
                      monthly mortgage payments without difficulty. During fiscal year
                      1995—the program’s first year of operation—HUD used the program’s
                      appropriation of $3 million to guarantee $22.5 million in home loans in
                      tribal areas. This funding guaranteed 74 homeownership loans for
                      individuals and 403 loans administered by IHAs, with the loans ranging
                      from a low of $21,000 to a high of $175,000.

                      The National Affordable Housing Act of 1990 created HUD’s HOME
Home Investment       Investment Partnership to expand the supply of decent and safe affordable
Partnership Program   housing. HUD awards HOME funds competitively to federally recognized
Develops Affordable   Indian tribes and Alaska Native villages. These governments, in turn, make
                      loans or grants for rehabilitating, acquiring, or newly constructing both
Housing               owner-occupied and rental housing. Recipients must have a low income
                      (an adjusted family income must be 80 percent or less of the area’s median
                      income), and in the case of rental housing, some tenants must have very
                      low income (50 percent or less of the area’s median income). The HOME
                      program first became available to Native Americans in 1992. Since then,
                      under the program HUD has awarded a total of $51 million to Indian tribes,
                      resulting in 560 new units constructed, 1,400 units rehabilitated, and 178
                      existing units purchased.

                      In 1978, HUD began providing IHAs with Indian Community Development
Indian Community      Block Grants as a set-aside3 in the overall Community Development Block
Development Block     Grant for cities and towns across the country. The block grant program’s
Grant Program         objective is to help IHAs and tribes develop viable communities that
                      include decent housing, suitable living environments, and economic
Provides Needed       opportunities—primarily for persons of low and moderate income. HUD’s
Funds                 regulations provide for two categories of grants, “imminent threat grants”
                       Before 1990, the allocation of Indian Community Development Block Grant funds was generally at the
                      discretion of the Secretary of HUD and represented 1 percent of the total Community Development
                      Block Grant. As part of the amendments to the Housing and Community Development Act of 1974 in
                      the National Affordable Housing Act of 1990, the 1-percent ratio became a requirement.

                      Page 28                                              GAO/RCED-97-64 Native American Housing
                                Appendix I
                                Funding and Results for Major Housing
                                Programs for Native Americans

                                and “single-purpose grants.” For the first type, the HUD Secretary can set
                                aside up to 5 percent of each year’s allocation for noncompetitive,
                                first-come, first-served grants to eliminate problems that pose an imminent
                                threat to public health and safety. The second type, single-purpose grants,
                                constitutes the remainder of the funding; HUD provides these grants on the
                                basis of annual competition governed by requirements and criteria set
                                forth in a “notice of funds availability” published in the Federal Register.

                                As funding for the total Community Development Block Grant Program
                                has increased, so has the amount set aside for Native Americans. This
                                amount has grown in real terms from $36 million in fiscal year 1986 to
                                $46 million in fiscal year 1995.

Table I.3: Funding for Indian
Community Development Block     Constant 1995 dollars in millions
Grants, Fiscal Years 1986-95    Fiscal year                                                                  Amount
                                1986                                                                           $36.1
                                1987                                                                             35.0
                                1988                                                                             32.0
                                1989                                                                             32.5
                                1990                                                                             30.3
                                1991                                                                             34.8
                                1992                                                                             36.5
                                1993                                                                             41.9
                                1994                                                                             45.1
                                1995                                                                             46.0
                                Total                                                                         $370.2
                                Source: Based on data from HUD’s LOCCS database.

                                For fiscal year 1995, the set-aside for grants addressing imminent threats
                                was $1.5 million, with $44.5 million remaining for single-purpose grants.

                                Nationally, HUD received 217 applications from tribes/tribal organizations
                                for 267 separate projects in 1995. As shown in table I.4, of those approved,
                                the most requested projects were for infrastructure and
                                buildings—accounting for about 87 percent of all the projects approved
                                and funded. The three types of projects that directly address
                                housing—new development, rehabilitation, and land to support new
                                housing—received a very small portion of the funding: $5 million, or about
                                13 percent, of the grant funds approved.

                                Page 29                                        GAO/RCED-97-64 Native American Housing
                                      Appendix I
                                      Funding and Results for Major Housing
                                      Programs for Native Americans

Table I.4: Types of Projects Funded
With Indian Community Development     Dollars in millions
Block Grants, Fiscal Year 1995        Type of project                               Number approved        Amount funded
                                      Infrastructure                                              37                   $15
                                      Non-housing building                                        50                    20
                                      New housing development                                       0                    0
                                      Housing rehabilitation                                        8                    3
                                      Land for housing                                              6                    2
                                      Total                                                      101                   $40
                                      Source: Based on data from HUD’s LOCCS database.

                                      Page 30                                        GAO/RCED-97-64 Native American Housing
Appendix II

Major Contributors to This Report

                       Lawrence J. Dyckman, Associate Director
Resources,             Eric A. Marts, Assistant Director
Community, and         Leslie A. Smith
Economic               Luis Escalante, Jr.
                       Willie D. Watson
Development Division

(385646)               Page 31                              GAO/RCED-97-64 Native American Housing
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