HUU -IJOu 11. 9 
Assessment of American Indian Housing 
 

Needs and Programs: 
 

Final Report 
 

HUD-7159 
NUU -UOu 71 ~q 

Assessment of American Indian Housing 
 

Needs and Programs: 
 

Final Report 
 

Prepared for: 
 

u.s. Department of Housing and Urban Development 
 

Office of Policy Development and Research 
 

Prepared by: 
 

G. Thomas Kingsley 
 

Virginia E. Spencer 
 

John Simonson 
 

Carla E. Herbig 
 

Nancy Kay 
 

Maris Mikelsons 
 

Peter Tatian 
 

The Urban Institute 
 

Center for Public Finance and Housing 
 

Washington, DC 
 

May 1996 
 

FOREWORD 
 

This final report ofthe HUD-commissioned Assessment ofAmerican Indian Housing Needs and 

Programs contains the most comprehensive and authoritative body ofinformation ever assembled 

on housing conditions and resources in Native American communities. It is the result of an 

unprecedented data collection effort, which included special tabulations ofCensus information, as 

well as surveys, site visits, and interviews with local leaders and housing officials. 

The principal findings ofthis carefully researched study confirm what many suspected already: the 

housing problems ofAmerican Indians and Alaska Natives, particularly in reservations and other 

Tribal Areas, are extreme by any standard. Forty percent ofNative Americans live in 

overcrowded or physically inadequate housing, compared to only 6 percent ofthe U. S. 

population. The report also highlights important variations in the nature, distribution, and relative 

severity ofhousing needs and resources among Tribal Areas. 

HUD's Indian housing programs-though ill-adapted in their original design and often 

cumbersome in practice-have produced tens ofthousands ofunits of affordable rental housing 

and homeownership opportunities for American Indians and Alaska Natives. However, these 

achievements have been dwarfed by the burgeoning need ofmany Native American communities 

and limited by the inability ofthese programs to respond adequately to the diversity ofhousing 

conditions and needs in Indian country. Such programs must also accommodate the legitimate 

demands for self-determination made by Native American tribes as sovereign nations. 

A combination of effective public investments and support for the development ofvital private 

housing market mechanisms will be essential to meeting the housing needs of American Indian 

and Alaska Native communities. HUD has proposed a fundamental reinvention ofits Indian 

housing programs that recognizes both the diversity of Tribal Areas and the need for approaches 

tailored to their unique problems, resources, and forms oftribal governance. The Department's 

proposals to gradually consolidate funding into formula grants would return much more discretion 

to local leaders, allowing them to design housing strategies that fit their own circumstances. 

Assessment ofAmerican Indian Housing Needs and Programs represents a major milestone in 

Federal efforts to more effectively address the housing problems ofNative Americans. By 

bringing the serious housing needs ofAmerican Indians and Alaska Natives into sharp focus, this 

report provides all of us with a forceful reminder of our Nation's trust obligations to the first 

Americans. HUD will make the data sets compiled for this report available to researchers, tribal 

officials, and other concerned citizens, in whose hands such information can be a valuable tool for 

local planning and education efforts. 

ACKNOWLEDGMENTS 

The Assessment of American Indian Housing Needs and Programs was a large and 

complex research project. As such, many people made important contributions to its completion. 

G. Thomas Kingsley served as overall project director during implementation and report 

preparation and was lead researcher on the analysis of housing conditions and needs (Chapters 

2 and 3). Virginia E. Spencer generally directed the assessment of program operations (Chapters 

4, 5, and 6), and John Simonson took the leading role in examining policy implications and 

analyzing the potentials for private mortgage financing in Indian country (Chapters 7 and 8). 

Other Urban Institute staff with major substantive responsibilities included Maris Mikelsons 

(who handled the sizeable tasks of data file preparation and quantitative analysis for the research 

on social, economic, and housing conditions), Carla Herbig (who designed and conducted all 

research on Indians residing in urban areas), Peter Tatian (who was lead analyst of HUD 

management data for the program assessment), and John Marcotte (who designed the survey 

sample). Jeffrey Mosley, Catherine Wright, Kara Hartnett, and Matthew VanderGoot assisted in 

data preparation and analysis. Herbig served as administrative coordinator for the project 

throughout, Tim Ware formatted, assembled and produced all project reports, and Scott Forrey 

provided copy-editing. 

Margery A. Turner directed the project during the deSign phase. Other members of the 

design team included Simonson, Spencer, and Herbig of the Urban Institute along with Michael 

Shea and Nancy Kay of Aspen Systems Corporation. 

Survey operations were primarily the responsibility of Aspen Systems Corporation, working 

under the general guidance of Spencer and Herbig. Nancy Kay served as survey director for 

Aspen as well as contributing to the research on program operations. Staff directly involved in 

conducting field surveys included: Kay, Christine Baron, and Laura Scherzer (Aspen Systems 

Corporation); Herbig, Spencer, Simonson, and Kingsley (Urban Institute); and Phillip Mayfield, 

Judith Katz, and Monte Franke (OKM Associates). Mayfield also administered a special survey 
Assessment of American Indian Housing Needs and Programs: Final Report iii 

on the Comprehensive Grant Program. Telephone surveys of Indian Housing Authorities were 

conducted by Aspen's telephone survey unit under the direction of Marie Pogozelski. 

While the authors of this report bear the responsibility for the quality of the final product, 

they acknowledge their considerable debt to all who provided valuable support at various stages. 

Most important, we express our appreciation to the many individuals in Indian country 

(tribal chairpersons and staff, Indian Housing Authority directors and staff, American Indian and 

Alaska Native households), who gave so generously of their time in responding to our questions 

in the surveys and in providing guidance to help us understand and more appropriately interpret 

the conditions that define what is clearly a critical issue for Federal policy. 

Second, we recognize the considerable assistance given us by Dom Nessi, Director of 

HUD's Office of Native American Programs, and his staff. They offered information and insights 

that proved invaluable to our understanding of conditions, program operations and policy 

alternatives. We also much appreCiate the role played by John Goering who served as HUD 

Government Technical Representative through all phases of the work. His diligent oversight and 

valuable guidance had a substantial impact on the result. He was ably assisted by his colleagues 

in HUD's Office of Policy Development and Research, Todd M. Richardson and Ndye Jackson. 

Important contributions were also made by National American Indian Housing Council 

(NAIHC) staff and consultants Morris Carpenter, George Gaasvig, Wayne Sims, and Luke Toyebo 

who helped in the design of survey instruments, accompanied and facilitated the work of the field 

survey investigators, and commented on preliminary findings and conclusions. NAIHC Executive 

Director Ruth Jaure also arranged for full reviews of the report after it was completed. We thank 

Juliet King of her staff for many insightful comments. We are particularly grateful to Robert 

Gauthier, Executive Director of the Salish and Kootenai Housing Authority, for his thorough review 

of the report. His comments added clarity and helped us avoid miSinterpretations. 

Finally, we give considerable credit and thanks to the many advisors (experts on Indian 

issues and representatives of key American Indian institutions) who helped in various phases of 

this project. The AdviSOry Panel that reviewed the project's design and advised on 

implementation included: Rick Anderson, David Baldridge, Stephen Cornell, Donna Fairbanks, 

Gayle Kildal, Richard Mitchell, Ma~orie Reyna, Gregory Richardson, and C. Matthew Snipp. 

Several of these advisors were called upon to review and comment on preliminary findings and 

conclusions. In this regard, we particularly wish to thank C. Matthew Snipp, Stephen Cornell, and 

Richard Mitchell. 
TABLE OF CONTENTS 
 

FOREWORD .......................................................... I 
 

ACKNOWLEDGMENTS ................................................ ii 
 

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. xi 
 

I. 	 HOUSING PROBLEMS AND NEEDS ............................... xiv 
 

Social and Economic Trends and Contrasts ....................... xiv 
 

Housing Problems in Tribal Areas ........... ,.................. xvi 
 

AlAN Housing Problems in Metropolitan and Other Environments. . . . . .. xviii 
 

II. 	 PROGRAM ASSESSMENT ..................................... xix 
 

HUD Programs in Tribal Areas ................................. xix 
 

Performance in Housing Development and Management .......... , .. xx 
 

Variations in Local Institutional Performance . . . . . . . . . . . . . . . . . . . . .. xxiv 
 

Other Housing Programs and Recent Innovations . . . . . . . . . . . . . . . . .. xxiv 
 

III. 	 DIRECTIONS FOR POLICY .................................... xxvi 
 

Reforming Federal Housing Assistance ............... '.' . . . . . . . .. xxvi 
 

Stimulating Private Investment in Indian Housing .................. xxix 
 

CHAPTER 1 - PURPOSE AND APPROACH ................................. 1 
 

APPROACH: THE OVERALL STUDY ................................ 2 
 

USE OF THE CENSUS AND HUD INFORMATION SYSTEMS. . . . . . . . . . . . . .. 4 
 

U.S. Census Data Sources and Definitions ........................... 4 
 

Limitations of Census Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 7 
 

HUD Management Information Systems ............................. 8 
 

Data Base Integration. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .. 9 
 

SURVEYS AND OTHER INFORMATION SOURCES. . . . . . . . . . . . . . . . . . . . .. 10 
 

Field Surveys: Indian Housing Authority (IHA) Officials 
 

and Tribal Leaders and Staff . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 10 
 

Field Surveys: The Household Survey . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 13 
 

IHA Telephone Surveys ......................................... 14 
 

Interviews and Case Studies: Indians in Urban Areas .................. " 15 
 

STRUCTURE OF THE REPORT 	 .................................... 16 
 

Part I--Housing Problems and Needs ............................... 16 
 

Part II--Program Assessment ..................................... 16 
 

Part 1I1--Policy Directions ........................................ 17 
 

Assessment of American Indian Housing Needs and Programs: Final Repott v 

AMERICA'S INDIAN POLICY: AN OVERVIEW .......................... 18 
 

The Sovereign-to-Sovereign Relationship and Trust Land . . . . . . . . . . . . . . . .. 18 
 

Removal and "Indian Territory" .................................... 19 
 

Allotment and Assimilation ....................................... 20 
 

The Indian "New Deal" . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 21 
 

Termination and Relocation ...................................... 22 
 

Self-Determination ............................................. 22 
 

Special Circumstances of Alaska Natives ............................ 23 
 

Conclusions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 23 
 

REFERENCES ................................................. 24 
 

PART I - HOUSING PROBLEMS AND NEEDS 

CHAPTER 2 - POPULATION GROWTH, SOCIAL AND ECONOMIC CONDITIONS, AND 

SPATIAL PATTERNS ............................................ 25 
 

POPULATION TRENDS: DECLINE AND RESURGENCE. . . . . . . . . . . . . . . . . .. 25 
 

THE GEOGRAPHY OF INDIAN COUNTRY . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 28 
 

Introduction .................................................. 28 
 

Region ..................................................... 28 
 

Area Types .................................................. 28 
 

Types of Tribal Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 29 
 

THE SPATIAL PATTERN OF THE AlAN POPULATION AND ITS RECENT 
 

GROWTH ................................................... 32 
 

The Current Pattern . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 32 
 

Patterns of Growth and Decline, 1980-1990 ........................... 38 
 

Migration and Implications for the Future . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 41 
 

SOCIAL AND ECONOMIC CONDITIONS .............................. 44 
 

Age Structure and Household Composition ........................... 44 
 

Education Status, Labor Force, and Employment . . . . . . . . . . . . . . . . . . . . . .. 46 
 

Poverty and Income . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 49 
 

Gaming in Tribal Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 51 
 

DIVERSITY ACROSS TRIBAL AREAS ................................ 52 
 

Summary of Findings So Far ..................................... 52 
 

The Extent of Diversity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 53 
 

Factors Influencing Diversity: Hypotheses ............................ 53 
 

Analysis .................................................... 58 
 

Interpretation and Typology ...................................... 58 
 
Assessment of American Indian Housing Needs and Programs: Final Report vi 

DIVERSITY OF CONDITIONS IN URBAN AREAS . . . . . . . . . . . . . . . . . . . . . . .. 61 
 

Where do Urban Indians Live . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 61 
 

Contrasting Characteristics. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 61 
 

Contrasts in Different Types of Metropolitan Areas. . . . . . . . . . . . . . . . . . . . .. 62 
 

REFERENCES ................................................. 62 
 

CHAPTER 3 - HOUSING PROBLEMS AND NEEDS OF AMERICAN INDIANS AND 
 

ALASKA NATIVES .............................................. 66 
 

BASIC CHARACTERISTICS OF AlAN HOUSING ........................ 66 
 

DEFINING HOUSING PROBLEMS AND NEEDS: A FRAMEWORK ........... 68 
 

Characteristics Defining Housing Problems and Needs . . . . . . . . . . . . . . . . . .. 68 
 

Standards and Approach ........................................ 70 
 

THE HOUSING PROBLEMS OF AMERICAN INDIANS AND ALASKA NATIVES: 
 

NATIONAL SUMMARY ........................................... 75 
 

The National Context. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 75 
 

AlAN Housing Problems Nationally--Census Indicators . . . . . . . . . . . . . . . . . .. 76 
 

Estimates of Total Housing Problems in Tribal Areas . . . . . . . . . . . . . . . . . . .. 79 
 

TRIBAL AREA HOUSING PROBLEMS: REGIONAL VARIATIONS ............ 81 
 

All Households with Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 81 
 

Affordability Problems in Tribal Areas ............................... 82 
 

Overcrowding and Facility Problems ................................. 84 
 

Summary .................................................... 84 
 

THE IMPACT OF HUD HOUSING ASSISTANCE. . . . . . . . . . . . . . . . . . . . . . . .. 85 
 

HUD's Housing Production Programs ............................... 85 
 

Housing Problems in Assisted vs. Unassisted Units . . . . . . . . . . . . . . . . . . . .. 86 
 

DIVERSITY IN HOUSING PROBLEMS ACROSS TRIBAL AREAS ............ 87 
 

Analysis .................................................... 87 
 

The Typology and Housing Problems and Needs . . . . . . . . . . . . . . . . . . . . . .. 88 
 

VARIATIONS IN THE HOUSING PROBLEMS OF URBAN INDIANS ........... 90 
 

Contrasts in Housing Conditions for Urban Indians. . . . . . . . . . . . . . . . . . . . .. 90 
 

Homeless and Access to Housing Assistance in Urban Areas .............. 90 
 

PROSPECTS AND POLICY IMPLICATIONS. . . . . . . . . . . . . . . . . . . . . . . . . . .. 91 
 

Prospects ................................................... 91 
 

Policy Implications ..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 93 
 

REFERENCES ................................................. 95 
 
Assessment of American Indian Housing Needs and Programs: Final Report vii 

PART 1/ - PROGRAM ASSESSMENT 

CHAPTER 4 - AMERICA AND INDIAN HOUSING POLICY: BACKGROUND AND 
 

APPROACH TO ASSESSMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 100 
 

FOUNDATIONS OF AMERICA'S INDIAN HOUSING POLICY ............... 100 
 

THE CURRENT PROGRAMS AND HOW THEY WORK. . . . . . . . . . . . . . . . . .. 104 
 

Program Framework. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 104 
 

Institutional Relationships and Responsibilities . . . . . . . . . . . . . . . . . . . . . . .. 106 
 

HUD's Production Programs: Rental and Mutual Help .................. 107 
 

The BIA's Production Program: HIP ............................... 109 
 

Tenant-Based Assistance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 110 
 

Block Grant Programs ......................................... 111 
 

Financing Assistance .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 112 
 

Recent Changes in Indian Housing Programs ........................ 113 
 

PROGRAM FUNDING ........................................... 114 
 

APPROACH TO ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 115 
 

Assessing HUD Production Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 116 
 

Assessment of Other Programs .................................. 117 
 

Perspective Related to the Timing of this Assessment .................. 118 
 

REFERENCES ................................................ 118 
 

CHAPTER 5 - HUD'S PRIMARY PRODUCTION PROGRAMS: RENTAL AND MUTUAL 
 

HELP ....................................................... 120 
 

Form of Data Presentation ...................................... 120 
 

THE ASSISTED HOUSING STOCK AND ITS SENEFICIARIES ............. 122 
 

Program Size and the Production Record Over Time . . . . . . . . . . . . . . . . . .. 122 
 

The Distribution of HUD-Assisted Indian Housing . . . . . . . . . . . . . . . . . . . . .. 125 
 

Differences in the Mix of Rental and Mutual Help Housing ............... 130 
 

Characteristics of the Current HUD-Assisted Housing Stock . . . . . . . . . . . . .. 131 
 

The Quality of I HA Housing ..................................... 135 
 

Resident Perceptions of IHA Housing .............................. 136 
 

Tribal Views and Cultural Preferences . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 138 
 

Program Beneficiaries ......................................... 139 
 

Summary and the Question of Demand for IHA Housing ................ 142 
 

DEVELOPING NEW HUD-ASSISTED HOUSING . . . . . . . . . . . . . . . . . . . . . . .. 143 
 

The Context . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 143 
 

The Development Process ...................................... 144 
 

Program Planning ............................................ 145 
 
Assessment of American Indian Housing Needs and Programs: Final Report viii 

Providing Land . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 146 
 

Providing Infrastructure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 147 
 

The Indian Preference Requirement ............................... 149 
 

Development Costs ........................................... 149 
 

Interpreting Standards and Costs ................................. 152 
 

OPERATING AND MAINTAINING THE ASSISTED HOUSING STOCK. . . . . . .. 153 
 

IHA Functions ............................................... 153 
 

Operating Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 154 
 

Receipts ................................................... 157 
 

Tenants Accounts Receivable (TARS) . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 158 
 

Tenant Selection ............................................. 159 
 

Maintenance Policies and Problems ............................... 160 
 

Modernization ............................................... 161 
 

Turnkey Conversion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 162 
 

INSTITUTIONAL PERFORMANCE .................................. 163 
 

National Administration and Oversight . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 163 
 

Local Implementation--IHAs and Tribes . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 164 
 

IHA Performance--ACA Ratings .................................. 166 
 

REFERENCES ................................................ 169 
 

CHAPTER 6 - ALTERNATIVE APPROACHES AND SUMMARY ASSESSMENT ..... 174 
 

ALTERNATIVE AND COMPLEMENTARY APPROACHES ................. 174 
 

Other Production Programs: The BIA's Housing Improvement Program ..... , 175 
 

Tenant-Based Assistance--Section 8 Certificates and Vouchers ........... 176 
 

Block Grants--ICDBG and HOME ................................. 177 
 

Financing Assistance: Sections 248 and 184 ........................ , 178 
 

Financing Assistance: Farmers Home Administration ................... 179 
 

Other Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 180 
 

INNOVATIVE APPROACHES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 180 
 

ASSESSMENT AND IMPLICATIONS ................................ 186 
 

REFERENCES ................................................ 191 
 
Assessment of American Indian Housing Needs and Programs: Final Report ix 

PART 11/- POLICY DIRECTIONS 

CHAPTER 7 - THE POLICY SETTING .................................... 193 
 

TRUST/FIDUCIARY OBLIGATIONS ................................. 194 
 

THEMES IN THE BROADER POLICY ENVIRONMENT ................... 196 
 

The Self-Determination/Self-Government Movement. . . . . . . . . . . . . . . . . . .. 196 
 

The Reinventing Government Movement . . . . . . . . . . . . . . . . . . . . . . . . . . .. 200 
 

CONSIDERING THE ADEQUACY OF FEDERAL FUNDING FOR INDIAN 
 

HOUSING .................................................... 201 
 

REFERENCES ................................................ 203 
 

CHAPTER 8 - REFORMING FEDERAL HOUSING ASSISTANCE ................ 205 
 

Attaching Fewer Federal Strings, but Rigorously Enforcing those that are 
 

Husbanding Existing Institutional Capacity--Roles for HUD and Other Federal 
 

BROAD ALTERNATIVES FOR FEDERAL HOUSING ASSISTANCE .......... 205 
 

Basic Alternatives ............................................ 206 
 

The Block Grant Approach ...................................... 208 
 

POLICY DIRECTIONS .,. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 210 
 

Consolidating Existing Programs into a Block Grant Framework ........... 210 
 

Attached ................................................. 211 
 

A Phased Transfer, Linked to Capacity Building. . . . . . . . . . . . . . . . . . . . . .. 213 
 

Husbanding Existing Institutional Capacity--Roles for the IHAs ............ 215 
 

Agencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 220 
 

An Equitable Approach to Allocating Funds . . . . . . . . . . . . . . . . . . . . . . . . .. 222 
 

Expanding Indian Access to Housing Assistance Outside of Tribal Areas .... 224 
 

CONCLUDING COMMENTS ...................................... 225 
 

REFERENCES ................................................ 226 
 

CHAPTER 9 - EXPANDING THE MORTGAGE LENDING 
 

IN INDIAN AREAS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 228 
 

THE ECONOMIC BENEFITS OF PRIVATELY FINANCED HOUSING ......... 228 
 

BARRIERS TO PRIVATE MORTGAGE LENDING IN INDIAN AREAS. . . . . . . .. 230 
 

Identifying the Barriers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 230 
 

The Lender SUNey (Confirming and Understanding the Barriers) .......... 233 
 

RECENT INITIATIVES TO STIMULATE MORTGAGE LENDING ............ 236 
 

Public S'upport for Private Lending for Indian Housing .................. 236 
 

Recent Regulatory Initiatives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 237 
 
x Assessment of American Indian Housing Needs and Programs: Final Report 

Private Housing Finance Initiatives ................................ 238 
 

THE MARKET FOR PRIVATE FINANCING ............................ 239 
 

Current Conditions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 240 
 

The Potential Market .......................................... 245 
 

The Potential for Expanding AlAN Homeownership Outside of Tribal Areas. .. 247 
 

CONCLUSIONS AND POLICY DIRECTIONS .......................... 248 
 

Local Actions--Establishing Market Pre-Conditions . . . . . . . . . . . . . . . . . . . .. 249 
 

Local Actions--Ta~ing Advantage of the IHAs ........................ 251 
 

Directions for National Policy .................................... 252 
 

Concluding Comments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. 253 
 

REFERENCES ................................................ 254 
 

ANNEX A ......................................................... 258 
 
EXECUTIVE SUMMARY 
 

The Assessment of American Indian Housing Needs and Programs was initiated in 1993, 

under the sponsorship of the U.S. Department of Housing and Urban Development (HUD). The 

purposes of this study have been 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 regarding the housing of these Native Americans could be improved. 1 This is the first 

comprehensive national study of these issues, motivated by recognition of the need for a sounder 

empirical basis for policy considerations. Its charter has called not just for national averages, but 

for serious examination of how Indian housing problems vary in different locations and what such 

variations may imply for policy. 

The research began with analysis of census data on housing and other characteristics of 

the American Indian and Alaska Native (AlAN) population; analysis of data from HUD 

management information systems on program performance; and interviews with a broad range 

of Federal officials. To obtain deeper understanding, it also entailed: telephone interviews with 

officials of virtually all local Indian Housing Authorities (IHAs), the agencies that administer HUD 

programs in Tribal Areas nationwide (as used in this report, Tribal Areas include American Indian 

Reservations, Alaska Native Villages, and other special types of areas so designated by the U.S. 

lThis report presents the study's findings and conclusions related to each of these purposes. Two other reports 

have been prepared under this study: (1) Housing Problems and Needs of American Indians and Alaska Natives (by 

G. Thomas Kingsley, Maris Mikelsons, and Carla Herbig, Washington, D.C.: U.S. Department of Housing and Urban 

Development, 1996) which presents more detailed analyses supporting the summary findings on this topic presented 

in Part I of this report; and Housing Problems and Needs of Native Hawaiians (by Maris Mikelsons and Karl Eschbach, 

with Virginia E. Spencer and John Simonson, Washington, D.C.: U.S. Department of Housing and Urban Development, 

1996), containing the results of special analyses added to the study agenda in mid-1994, which are not reviewed in this 

report. 
Assessment of American Indian Housing Needs and Programs: Final Report xii 

Census); on-site, in-depth interviews with tribal leaders and IHA officials at 36 representatively 

sampled Tribal Areas; interviews and observation of housing conditions for a sample of 

households at the same sites; a small survey of private mortgage lenders; case studies and 

selected interviews concerning the housing of American Indians living in metropolitan areas; and 

recurrent consultations with independent national and regional experts on the problems and 

dynamics of the AlAN population. 

It is important to note that, while the U.S government makes housing assistance available 

to low-income Americans in all locations, the context for such assistance in Tribal Areas differs 

in at least three important respects. First, the basis for such support derives in part from the 

nation's recognition of special obligations to the AlAN population, reflected in treaties, legislation, 

and executive orders, long before Federal housing subsidies were provided to the general 

population. Second, the Federal government deals with recognized tribes directly in a sovereignto-sovereign relationship, rather than through the general system of State and local government. 

Third, a considerable amount of land in Tribal Areas is held in trust for the tribes as a whole, 

rather than being subdivided into many private holdings as occurs in the rest of the country; this 

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. 

The study results indicate that while progress has been made, the housing needs of 

American Indians and Alaska Natives continue to represent a major and distinctive challenge for 

public policy. Main findings and conclusions are: 

• The housing problems of American Indians and Alaska Natives remain 

considerably more severe than those of non-Indians in al/ parts of America. This 

is particularly so in reservations and other Tribal Areas where, according to Census 

data, 28 percent of AlAN households are overcrowded or lack plumbing or kitchen 

facilities (the comparable average for all U.S. households is only 5.4 percent). A 

sample survey conducted as a part of this study suggests that, adding in condition 

and other facility problems, the total overcrowded or living in inadequate housing 

in Tribal Areas is around 40 percent (the comparable U.S. average is 5.9 percent). 

For AlAN households living in other locations (metropolitan and nonmetropolitan) 

having to spend an excessive share of their income for housing (rather than 

physical deficiency) is the dominant problem. 

• The character of AlAN housing problems and, therefore, the best strategies 

for addressing them, vary importantly in different types of environments. Even 

among Tribal Areas, there is tremendous diversity, ranging from extremely isolated 

and poor tribes to somewhat better-off tribes located nearer metropolitan labor and 

housing markets. For a significant number, more emphasis on attracting private 
Assessment of American Indian Housing Needs and Programs: Final Report xiii 

mortgage lending and applying other market-oriented housing strategies appear 

warranted. 

• Housing produced under HUO's Indian housing programs does have defects, 

but its availability has substantially improved living conditions for thousands of 

families. This housing stock accommodates about one fourth of all AlAN 

households living in Tribal Areas. Against a backdrop of past overregulation, 

recent Feforms by HUD (streamlining rules and procedures, building in stronger 

performance incentives) should offer considerable promise in improving program 

management. However, two problems remain: (1) statutory restrictions stillprevent 

tribes with capable local administrators from using program resources as efficiently 

and equitably as should be possible; and (2) administrative deficiencies in a number 

of areas suggest that substantial improvements in management capacity will be 

needed before true program effectiveness can be achieved in those areas. 

• The most attractive direction for reforming Federal housing assistance in 

Tribal Areas over the long term should be to consolidate existing programs into 

more flexible mechanisms--grants that give tribes and their IHAs broader latitude 

in planning, funds allocations, and implementation to address local housing needs 

as they see them, but hold them more clearly accountable for performance. It 

should be emphasized, however, that the management capacity problems noted 

above must be addressed (through technical assistance and other means) before 

the tribes affected can gain the benefits that should arise from enhanced flexibility. 

For Native Americans with housing problems living in urban centers and other 

locations outside of Tribal Areas, emphasis should be on expanding their access 

to assistance within the framework of Federal housing programs provided for the 

general population. 

• Priority also appears warranted for policies that promote and facilitate 

enhanced private investment in Indian housing. The number of AlAN households 

at moderate- and higher-income levels is substantial, and homeownership rates for 

these groups are well below those for non-Indians at the same income levels. 

Private lenders and market intermediaries are beginning to recognize that expanded 

mortgage lending to AlAN households and communities may be a promising market 

opportunity. But policy support is needed to tra;nslate this opportunity into reality 

at sufficient scale. 
Assessment of American Indian Housing Needs and Programs: Final Report xiv 

I. HOUSING PROBLEMS AND NEEDS 

Social and Economic Trends and Contrasts 

Population growth and spatial patterns. The American Indian and Alaska Native 

population in the U.S. has been growing rapidly--a sixfold increase over the past four decades, 

reaching a level of 2.0 million in 1990. Most noteworthy is that the concentration of this 

population in and around reservations and other Tribal Areas is increasing. The 14 percent of 

all U.S.counties that contain Tribal Areas accounted for 60 percent of the U.S. AlAN population 

in 1990, and had captured 78 percent of its growth since 1980. The popular impression that the 

bulk of the Indian population is gradually shifting away from the reservations to metropolitan areas 

is a myth. 

A number of indications in this study suggest that cultural ties to Tribal Areas remain 

strong. For example, urban case studies indicate that many Indians living in urban areas retain 

ties to their tribes and hope to move back to the reservation when they retire. Also, in household 

surveys, the primary reason tribal members gave for living off the reservation was the necessity 

of obtaining employment, rather than any negative feelings about reservation life. Of those who 

live outside of a reservation, but in the same county, 71 percent said they would "prefer to live 

on the reservation." 

Of the 2.0 million 1990 total AlAN population, 37 percent lived in Tribal Areas themselves, 

and 23 percent lived in the surrounding counties. Another 31 percent were residents of 

metropolitan areas in the rest of the country (down from 33 percent in 1980). Only 9 percent lived 

in other non-metropolitan areas and the share in such areas was declining sharply (down from 

13 percent in 1980). 

Social and economic characteristics. Compared to non-Indians, the AlAN population 

is more family oriented, but more prone to economic distress. Nationally, more AlAN households 

are married couples with children (37 percent vs. 28 percent) and many more are large (5 or 

more person) families (20 percent vs. 11 percent). The AlAN population has a higher 

unemployment rate (14 percent vs. 6 percent), a smaller number of workers in "for-profit" firms 

per thousand population (255 vs. 362) and a higher share of households with very low incomes 

(VLI, one third vs. 24 percent).2 

2"Very low-income" households are those with incomes less than 50 percent of the median income in their local 

labor market areas. 
Assessment of American Indian Housing Needs and Programs: Final Report xv 

Variations in differing environments. These types of AlAN/non-Indian differences exist 

in all locations but they are most pronounced in Tribal Areas. For example, large families 

represent 27 percent of all AlAN households in Tribal Areas, but only 19 percent in their 

surrounding counties, and 16 percent in the rest of the U.S. (both inside and outside of 

metropolitan areas); VLI households represent 43 percent of the AlAN total in Tribal Areas, 30 

percent in the surrounding counties, and 28 percent in other metropolitan and non-metropolitan 

areas. Tribal Areas have an average of only 158 for-profit employees per 1,000 population, 

compared to 311 for Indians living elsewhere. 

Diversity of conditions across tribal areas. Even across Tribal Areas, however, there 

is much more diversity than is typically understood. To many outsiders, the stereotypical Indian 

reservation is a small, remote, and poor community with little access to employment or other 

opportunities that are offered in our predominantly urban society. This is an apt characterization 

for many of them, but not for all. In fact, out of the 508 inhabited Tribal Areas nationally: 

• 	 183 (accounting for 53 percent of the total AlAN Tribal Area population) are Large 

(have an AlAN population of 400 or more), and have one of two other 

characteristics: (1) they are Near Urban (located within 50 miles of an urban center 

with a population of at least 50,000), andlor (2) Open (having at least as many 

Indians as non-Indians living within their boundaries). These Areas, on average, 

have a fairly strong private employment base (217 for-profit workers per 1,000 

population) and a comparatively low share of households in the VLI group (35 

percent). 

• 	 Out of the first group, 46 (accounting for 25 percent of the total population) have 

all three of the characteristics mentioned (Large, Near Urban, and Open). These 

fare even better than the first group, with a for-profit employment ratio of 242 and 

a VLI share of 31 percent. 

• 	 The remaining 325 Areas are more often like the stereotype--remote and poor. 

They have an average of only 91 for-profit employees per 1,000 population and 

59 percent of their households are VLI. 

Generally, statistical analysis showed that the more open and nearer to an urban center 

a Tribal Area was, the stronger its economic position was likely to be. This relationship was far I 

from a perfect fit, however. Many other factors (including the effectiveness of tribal government, 

work force skills, the value of the Area's natural resource base, and others) undoubtedly also play 

a critical role. 
Assessment of American Indian Housing Needs and Programs: Final Report xvi 

The AlAN metropolitan population is concentrated in a limited number of areas rather 

than being evenly spread. Over 60 percent live in just 15 metropolitan areas. An unexpected 

finding is that, in these areas, a larger share of the AlAN population lives in the suburbs (59 

percent) than the non-Indian population (54 percent on average). It must be remembered, of 

course, that there is great divergence within the non-Indian population in this regard: AlAN 

households are much more likely to live in the suburbs than blacks or Hispanics, but less so than 

whites. Index measures show substantially less residential segregation for American Indians than 

for blacks and Hispanics. 

City/suburban differences. AlAN suburban residents are typically in a better position 

economically than their counterparts in the central cities, but they clearly have not achieved parity 

with the suburban average. In fact, AlAN/non-AlAN disparities are often greater in suburban 

locations. For example, the AlAN unemployment rate in the central cities of the 15 metropolitan 

areas is 11 percent (1.2 times that for non-Indians). The comparable suburban AlAN rate is much 

lower (8 percent) but that figure is 1.7 times the suburban non-Indian average. 

Housing Problems in Tribal Areas 

Census indicators show that the physical housing problems of Tribal Areas are extreme 

by national standards: 28 percent of AlAN households in these areas live in housing that is 

overcrowded and/or lacks kitchen or plumbing facilities--compared to a national average of only 

5.4 percent. (And Tribal Area problems in this regard are much more serious than those for AlAN 

households in other areas, as will be discussed below). The share of AlAN households in these 

areas that live in decent housing but have an affordability problem (housing expenses exceed 

30 percent of their income), however, is smaller than that for the general population (16 percent 

vs. 20 percent). 

There are important regional variations in the incidence of housing problems in Tribal 

Areas. Probably most important is that physical problems (overcrowding and facility deficiencies) 

are considerably higher in two regions than elsewhere: Alaska and Arizona-New Mexico, where 

63 percent and 61 percent, respectively, of all AlAN occupied units are affected. Overcrowding 

rates are still serious in the Tribal Areas of all other regions (much above the national averages 

for non-Indians) but the incidence of facility deficiencies is fairly low in most other regions except 

for these two. 

The pattern with respect to affordability problems, however, appears to be almost the 

reverse of that for physical problems. Oklahoma, for example, which has by far the lowest share 

of its units with physical problems, has among the highest shares with affordability problems (21 

percent). Unlike almost all others, the Tribal Areas of Oklahoma have large private land areas 
Assessment of American Indian Housing Needs and Programs: Final Report xvii 

within them and a land tenure system that has tended more to foster the emergence of private 

housing markets. 

Other physical housing problems (deficiencies in structural condition and 

heating/electrical systems) are not measured by the Census. The gap between the U.S. average 

and Tribal Area problems widens even further when these other deficiencies are considered. 

Based on a survey conducted by this study of a small sample of Tribal Area households, we 

estimate that, in total, roughly 40 percent are overcrowded and/or with one or more serious 

physical problems (the comparable national average is 5.9 percent). The comparable share for 

AlAN households in Tribal Areas that do not live in HUD assisted housing is 45 percent. 

Total units with physical problems. Official census figures show a total of 234,400 

occupied housing units in Tribal Areas nationally in 1990. The 40 percent average implies that 

93,800 of these units were overcrowded and/or had serious physical deficiencies. That number, 

however, is not adjusted to compensate for the major census undercount in Tribal Areas that 

occurred in 1990. If that adjustment is made, the total overcrowded and/or with serious physical 

deficiencies would be 105,200 units (81,600 of which had physical deficiencies). 

Diversity in housing problems and circumstances. Tribal Areas are as diverse in their 

housing characteristics as they are in their social and economic circumstances. While again there 

was much variation around these tendencies, statistical analysis shows that, generally, the more 

open a Tribal Area is and the closer it is to a large urban center: (1) the smaller its overall share 

of households with housing problems; and (2) the lower the share that have overcrowding and/or 

facilities problems; but (3) the higher the share that have affordability problems. To illustrate: 

• 	 For the 183 Areas that were Large and Open and/or Near Urban (as defined 

earlier), on average, just one third of all households had one or more housing 

problems: 12 percent had overcrowding and/or facilities problems, and 21 percent 

had affordability problems only. In these areas, housing strategies that rely more 

on private markets clearly warrant consideration. 

• 	 For the remaining 325 Areas, 62 percent had one or more housing problems: 52 

percent had overcrowding and/or facilities problems, and only 10 percent had 

affordability problems only. In these areas, market-oriented housing strategies are 

less likely to be workable. 

These marked variations in the magnitudes and types of local housing problems suggests 

that any single nationally imposed housing strategy for Tribal Areas is likely to prove unworkable. 

Area-specific conditions should determine the best mix of policy tools to be applied. While some 
-------------------------------------------- Assessment of American Indian Housing Needs and Programs: Final Report xviii 

general themes are likely to be applicable in most areas, specific program approaches need to 

be locally tailored to be feasible in the Area at hand. 

In a sizeable number, attempts to address a larger share of low-income housing problems 

through assistance in the private housing market appear promising (rather than relying solely on 

traditional government production programs which typically cost more per household 

accommodated). In many Tribal Areas, there are significant numbers of households with incomes 

that should enable them to purchase decent homes if private mortgage financing was being made 

available as it is in the rest of the country. 

AlAN Housing Problems in Metropolitan and Other Environments 

Physical problems. In the rest of the U.S., the share of AlAN households with 

overcrowding and/or plumbing/kitchen facility problems is considerably less severe than in Tribal 

Areas, but still well above the 5.4 percent average for the general population: 14 percent in 

counties surrounding Tribal Areas, and 9 percent in other metropolitan and non-metropolitan 

areas. 

Affordability problems. The dominant housing problem for AlAN households in these 

environments, however, is affordability. The share who live in decent housing but have an 

affordability problem is 27 percent in the surrounding counties, 29 percent in other metropolitan 

areas, and 27 percent in other non-metropolitan areas--compared to the national average of 20 

percent. 

Homelessness. Household surveys indicate that in Tribal Areas, the lack of sufficient 

housing is reflected in severe overcrowding rather than actual homelessness; i.e., virtually all 

people who have no shelter of their own are taken .in by relatives or other tribal members. 

Homelessness per se is a serious problem, however, for the AlAN population in urban areas. 

The survey generally considered the most reliable indicates that AlAN individuals account for 2.3 

percent of all homeless people nationally--an incidence rate three times that for the population 

as a whole. 

Homeownership rates for higher-income AlAN households are unusually low, particularly 

considering that such a high percentage of them are family households (those that normally find 

ownership most desirable). While 48 percent of all AlAN households nationally are in the 

moderate- and higher-income ranges (incomes above 80 percent of the local median), ownership 

rates for these groups are significantly below those of non-I ndians at similar income levels in most 

parts of the country (for example, 66 percent vs. 75 percent in metropolitan areas). 
Assessment of American Indian Housing Needs and Programs: Final Report xix 

II. PROGRAM ASSESSMENT 

HUD Programs in Tribal Areas 

A broad array of Federal housing assistance programs is made available in Tribal 

Areas--together budgeted at levels totaling $585 million in 1993. This assistance is dominated, 

however, by two HUD programs which accounted for 88 percent of the Tribal Area total: the 

Rental program--which operates like public housing--and the Mutual Help program--a 

homeownership (lease-purchase) program in which buyers make monthly payments and, unlike 

the Rental program tenants, must cover their own operating and maintenance expenses. Both 

programs are administered by the 187 IHAs--agencies whose boards are appointed or elected 

by the tribes they serve. HUD administers the programs through its central Office of Native 

American Programs (ONAP) and its six regional field offices (FONAPs). 

Scale of HUD programs. By the end of 1993, a total of nearly 100,000 units had been 

funded under these two programs since they began in the mid-1960s (75,400 were built and in 

management, 8,900 were paid-off Mutual-Help units, and the remainder were still in planning or 

construction). Of those in management, 27,200 (36 percent) were Rental units, the rest being 

produced mostly under Mutual Help. A high level of budget authority provided in the late 1970s 

allowed these programs' output to peak in the early 1980s (1980-84 average of 3,800 units 

completed per year). Production levels have since declined (3,000 over 1985-89, and 2,000 over 

1990-93). 

While small in comparison to Federal housing programs operating nationwide, these 

programs have had a significant impact in Indian country. There were 60,700 AlAN occupied 

HUD assisted units in Tribal Areas in 1990. This number is the equivalent of 26 percent of all 

AlAN households in those areas and 42 percent of those with low incomes (beiow 80 percent of 

the local median).3 

Equity in past allocations. There is considerable variation across Tribal Areas, in the 

share of local low income households assisted by IHA programs--some have housed a much 

higher percent of their income-eligible populations than others. HUD has recently adopted an 

allocation system that relies more on U.S. Census data, and this should reduce the extent of such 

inequities in the future. 

3These shares are based on official Census figures for the total number of households and low-income households 

in Tribal Areas. However, a post-Censal survey indicated that the official figures undercounted the total population in 

Tribal Areas by 12.2 percent. If adjustment is made for the undercount, the HUD contribution equals 23 percent of all 

households and 37 percent of all low-income households. 
Assessment of American Indian Housing Needs and Programs: Final Report xx 

Beneficiaries. IHA programs are serving the types of beneficiaries for which they were 

intended. The average annual income of the tenants in the Rental program is $8,800--90 percent 

of all such tenants have very-low incomes (about the same percent as in the national public 

housing program). The average income for Mutual Help occupants is higher: $18,260 (only 52 

percent of them are in the very low-income category). But this is not surprising since it was 

expected that somewhat higher incomes would be required to meet the obligations of home 

ownership. The number of non-Indian occupants is negligible in Mutual Help units (2 percent) 

but higher in the rental program (16 percent, accounted for mostly in two regions where IHAs 

were created under sta;te law as public housing authorities and were required to house other very 

low-income families). 

Condition and beneficiary satisfaction. Sample surveys indicate that while physical 

problems in IHA units are far from trivial, they are much less severe than those of unassisted 

housing in Tribal Areas. Overcrowding and/or serious condition and/or facility deficiencies were 

reported for 18 percent of Rental program units and 28 percent of Mutual Help units, as against 

45 percent of unassisted units. Program beneficiaries seem reasonably well satisfied with their 

housing. Survey respondents were asked for ratings on a five point scale: only 10 percent of 

Rental program tenants said they were "most unsatisfied", compared to 20 percent for Mutual 

Help occupants, and 35 percent for the residents of unassisted housing in AlAN Areas. 

Continuing demand for IHA housing. Comparatively low vacancy rates (6 percent on 

average) and long waiting lists in most areas suggest that the demand for additionallHA housing 

remains high (our surveys indicate that the number of households on waiting lists averages about 

half of the total number of existing IHA units). 

Performance in Housing Development and Management 

HUD deregulation and management improvement initiatives. Interviews with program 

managers suggest that, through the mid-1980s, the administration of Indian housing programs 

was fraught with conflict and operating difficulties. Much of this appears due to complex rules and 

procedures, requiring detailed HUD review of all aspects of local operations. A particular problem 

was the imposition of the cumbersome regulations of the national public housing program in Tribal 

Areas without reasonable adaptation. More recently HUD has made a significant effort to cut 

regulations and oversight, and spur better local management. While it is too early to evaluate the 

results, there are a number of indications that this is helping to create an environment supportive 

of improved performance at the local level. 

The development process has been shortened--the average period from funds 

reservation to construction start dropped from 38.7 months in 1985 to 28.4 months in 1993. With 
Assessment of American Indian Housing Needs and Programs: Final Report xxi 

good management, considerable speed is possible within the current system (at least one IHA 

has recently accomplished this in less than six months). 

However, IHAs note several factors that still slow down delivery: (1) the lack of overall 

planning which frustrates project site selection and infrastructure provision (only 30 percent of 

IHAs have comprehensive housing plans--most of those are out of date and very few tribes have 

adopted clear land-use plans); (2) increasing difficulty in securing sites (reported by 40 percent-­

archeological and environmental requirements are frequently noted as barriers); (3) the wellintended requirement to give preference to Indian contractors (52 percent say this initiative is not 

meeting its objective because qualified Indian contractors are too scarce to make it workable); 

(4) interagency coordination problems--this was not considered a major obstacle, but 35 percent 

mentioned that the Bureau of Indian Affairs (BIA) was sometimes slow in providing access roads. 

Development costs. The per square foot cost of developing new IHA housing has been 

markedly reduced over the past decade--from the 1981-83 average of $96 to the 1991-93 

average of $65 (constant 1993 $). The 1991-93 average development cost per unit was $85,700, 

although there was considerable variation by region. Average per unit costs fell in the $50,000­

$60,000 range in the Eastern, Oklahoma, and Plains regions, but above $100,000 in the Alaska, 

California-Nevada and North Central regions (these differences seem to be largely explained by 

variations in input prices and tribal choices of house types). 

Although many IHAs note factors they believe still push up costs unreasonably (e.g., the 

site delay factors noted above, Davis-Bacon requirements) it is difficult to argue that these costs 

are substantially above what they should be, given the type of housing being produced in many 

of the remote regions. On most reservations, there are strong cultural preferences for low-density 

housing (which implies higher costs when full infrastructure is provided). Through the early 1980s 

HUD regulations mandated fairly high technical standards for IHA units and these too set limits 

on how much costs could be reduced. HUD-imposed standards have now been eliminated, but 

compliance with minimums in accepted national codes is still required and old traditions with 

respect to standards linger on--a natural tendency to use housing designs that have worked in 

the past rather than search for lower-cost, potentially controversial, alternatives. 

Nonetheless, this level of cost remains an issue because under the present system, while 

a significant fraction of the households in need are benefiting from substantial subsidies, even 

larger numbers in similar circumstance receive nothing. This inequity could be remedied if more 

families could be assisted for the amount of HUD funding provided with programs producing 

decent basic homes at lower cost. 

Operating costs and HUD Subsidies. In 1993, IHA costs of operating and maintaining 

completed Rental housing averaged $217 per unit-month--a measure that exhibits little variation 
Assessment of American Indian Housing Needs and Programs: Final Report xxii 

by IHA size or region. This average appears reasonable in relation to similar costs for public 

housing where 1992 allowable expenses per unit-month ranged from $140 for small housing 

authorities in the Midwest to $358 for large public housing programs in the Northeast. 

IHA operating costs in Mutual Help averaged $91 per unit-month. These outlays are only 

supposed to cover counseling, some utility allowances, and a few administrative expenses--not 

full project management, utilities, and maintenance as required of IHAs in the Rental program. 

Mutual Help costs are more variable across IHAs. For example, the average cost for smaller 

IHAs (less than 100 units in management) is $127, compared to only $62 for larger IHAs (457 

units or more). 

In 1993, the HUD operating subsidy in the Rental program averaged $180 per unit-month 

(83 percent of total operating costs). In Mutual Help, the HUD subsidy averaged $37 per unitmonth (41 percent of total operating costs). In both cases, remaining costs were covered mainly 

by payments from beneficiaries. 

Tenant Accounts Receivable (TARS). A long-standing problem in both programs has 

been substantial delinquencies by beneficiaries in meeting their payment obligations under 

program rules. On average, 36 percent of all Rental program tenants were delinquent in their rent 

payments in 1993, and cumulative Tenant Accounts Receivable (TARS) at the end of the year 

averaged $208 per unit in management. In comparison, only 12 percent of the tenants in the 

national public housing program had rent delinquencies. 

In Mutual Help, the monthly payment for purchasers is set between 15 percent and 30 

percent of income. IHA's can grant utility allowances to these households and, there is little 

evidence of IHA efforts to increase payments much beyond the minimum (Le., it is likely that 

household payments on average come much closer to the 15 percent than the 30 percent). Still, 

TARS is also a notable problem in Mutual Help: 36 percent of new Mutual Help occupants, and 

56 percent of old Mutual Help occupants are delinquent and cumulative TARS per unit in 

management is higher than in the Rental program ($294 in new Mutual Help units, and $628 in 

old Mutual Help units). 

Clearly, a part of the explanation here is that many Mutual Help households had been 

enticed into a program they simply could not afford. The 15 percent of income requirement 

sounded attractive, and many did not give enough thought to the other side of the bargain; Le., 

that they would have to pay for utilities and maintenance from their own pockets. 

The averages, however, are misleading because they mask wide differences. Some IHAs 

have an excellent record with respect to TARS while, for others, the problem is severe. For the 

ten percent of all IHAs with the best record in this regard, for example, Rental program TARS 
Assessment of American Indian Housing Needs and Programs: Final Report xxiii 

averaged only $5 per unit in management; for the ten percent with the worst record, the average 

was $1,256. On-site interviews suggest that while some tribes enforce strong eviction policies 

(and therefore avoid large TARS), others either are unwilling or unable to do so. Explanatory 

factors include the existence of weak tribal court systems and the conflict of such policies with 

tribal culture, as well as the lack of forceful management. 

Maintenance and repair activity. Maintenance and repair activity is an increasing 

challenge in the Rental program with the aging of a large share of the stock. Also, 65 percent 

of IHAs surveyed say that vandalism and tenant abuse increasingly compounding the problem. 

Nonetheless, there is wide agreement that the physical problems of Mutual Help are much more 

serious (corroborated by sample survey results noted earlier). IHAs, asked about the causes, 

most frequently cited the simple failure of residents to make needed repairs (30 percent), poor 

original construction (22 percent), and inadequate resident income to cover maintenance (20 

percent). 

The history of these programs in this regard shows how rigid program designs can distort 

incentives. In Tribal Areas, where a very high percentage of households are families, there is an 

overwhelming preference for homeownership rather than rental tenure. Also, Mutual Help 

seemed attractive because poor households only had to pay around 15 percent of their income, 

in contrast to the much higher charge in the Rental program. Accordingly, most tribes 

emphasized the development of Mutual Help units as HUD assistance began. The economics 

worked reasonably well for a time, but with the dramatic escalation of utility costs in the mid1970s, occupant incomes were much too low to cover these costs and adequate maintenance 

as well (our field surveys evidenced cases where Mutual Help residents simply did not use the 

heat and electricity provided because they could not afford to pay for them). Recognizing this, 

the 1980s saw much pressure to expand the Rental program (since its rules allowed HUD, rather 

than the occupants, to cover the costs of utilities and maintenance). Other options would have 

been possible in a more flexible program environment (see section on innovations below). 

Modernization. Recognizing the increasing physical deterioration of HUD-assisted units 

in Tribal Areas, HUD has allocated substantial additional funding for modernization in recent years 

(modemization accounted for only 6 percent of capital expenditure funds authorized over 1980-84, 

but 28 percent over 1990-93). IHAs were concerned about overly tight HUD control and allocation 

uncertainties associated with such funding under ClAP (the Comprehensive Improvement 

Assistance Program). The CGP (Comprehensive Grant Program), initiated in 1992 to rectify 

some of these problems, is a more flexible approach in which funds are allocated by a formula 

for multi-year improvement strategies. However, CGP is al~o faulted in two respects: (1) it has 

been provided only to larger IHAs (250 or more units in management)--smaller IHAs remain 

strapped for modernization funds; and (2) CGP requires the preparation of planning documents 

that are overly time-consuming. 
------------------------------------------- Assessment of American Indian Housing Needs and Programs: Final Report xxiv 

Variations in Local Institutional Performance 

IHA diversity. IHAs are diverse along many dimensions. Differences in size are 

important managerially (the top quarter ranked by size manage an average of 1,155 housing units 

whereas the bottom quarter manage on average only 59). Of the 187 total, 6 have only recently 

been founded and have not yet completed any units. Of the remainder, 24 are lumbrella-IHAs" 

that provide services to two or more Tribal Areas and 157 serve only one tribe. 

IHA performance also varies widely. In the Administrative Capability Assessment (ACA) 

system (initiated by HUD in the mid-1980s), IHAs are rated on several independent aspects of 

their performance. One of these factors is TARS which, as we have seen, varies dramatically. 

The composite scores (1990-93 averages on a 100 point scale) range from 3 to 97. The middle 

half of the IHAs fall in the range from 67 to 85. The composite ratings for 52 percent of the IHAs­

-high or low--have not changed much since the mid-1980s, but 23 percent have increased 

performance substantially, while 25 percent have experienced major declines.4 

Factors influencing performance. Statistical analysis revealed no systematic 

relationships between ACA ratings and Tribal Area characteristics examined earlier; e.g., size, 

location, comparative income. For one factor, however, the relationship was significant: IHA 

director turnover. For example, the 25 percent of all IHAs with the lowest ACA performance had 

an average of six directors over the past ten years, about twice the average for those with higher 

performance ratings. It seems likely that IHA director turnover is itself influenced by unstable or 

ineffective tribal governance. The lowest performers also had the highest turnover in board 

directors. 

Other Housing Programs and Recent Innovations 

BIA's Housing Improvement Program (HIP) provides grants for housing improvements, 

targeted to very low-income households. HIP is normally administered by the tribal governments. 

Most funds have been used for modest rehabilitation and repair of existing units rather than new 

construction, although the latter is allowable under the program. Although HIP has made valuable 

contributions, it has also had major administrative control problems, and at current funding levels 

($20 million per year) it cannot be expected to make much of a dent in the housing problems 

enumerated above. 

41HAs were divided into deciles according to their overall ACA ratings in two periods: 1986-89 and 1990-93. A major 

change was defined as occurring when an individual IHA moved up or down by two or more deciles between these 

periods. 
Assessment of American Indian Housing Needs and Programs: Final Report xxv 

Tenant-based assistance programs (Section 8 Certificates and Vouchers) help lowincome households rent housing of their choice in the private market (HUD subsidies make up 

the difference between the market rent for the unit and what the tenant can afford to pay). This 

approach will not work in remote Tribal Areas where a large private housing stock does not exist. 

However, a significant number of Tribal Areas do have such housing within their boundaries or 

nearby. Those earlier classified as "near urban" alone have around 20,000 households with 

housing affordability problems, yet HUD has so far allocated tenant-based assistance for only 

4,885 families to Tribal Areas nationwide. 

Financing initiatives. The availability of private mortgage financing that most Americans 

take for granted has been largely withheld from Tribal Areas (mostly because lenders have 

perceived additional risks due to the inability to foreclose on trust land and other legal 

complexities). The FHA Section 248 mortgage insurance program was established in 1987 in the 

hope of offsetting these risks, but the program has rarely been used. A new (Section 184) loan 

guarantee program has been established as well, but it has only recently become operational and 

it is too early to judge its effects. HUD now appears to be making a concerted effort to market 

both programs more effectively. 

Two HUD block grant programs have been used to support housing improvements in 

Federally recognized Tribal Areas: the Indian Community Development Block Grant (ICDBG) and 

the HOME Investment Partnership. Both are most often administered by tribal governments 

directly rather than their IHAs, and both permit substantially more local flexibility in spending 

decisions than occurs under categorical initiatives like the Rental and Mutual Help programs. 

ICDBG is HUD's principal vehicle for supporting community and economic development 

activities in Indian communities ($40 million budgeted in 1993). A total of over 1,300 projects in 

32 states have been funded since 1980. In 1991 and 1992, 70 percent of the resources went for 

community facilities and infrastructure, but 18 percent was allocated to housing construction and 

rehabilitation. HOME is a new block grant program, created in 1990 solely to support local 

housing initiatives ($12.8 million budgeted for Tribal Areas in 1993). It can be used to support 

a variety of locally designed activities including tenant-based assistance, down-payments for 

home buyers, and housing production and rehabilitation programs. Only a few tribes have begun 

to apply for HOME funds to date, but some creative new approaches are being devised (see 

discussion below). 

Local innovations. Using HOME and other funding vehicles, a few tribes are 

experimenting with new housing assistance approaches that, would avoid some of the problems 

of the current HUD programs discussed above. At least three principles are being applied, all in 

a manner that would increase the number of families that can be assisted for any given amount 

of Federal funding provided: 
Assessment of American Indian Housing Needs and Programs: Final Report xxvi 

1. 	 Leverage--instead of covering the full bill, the HUD subsidy can be a base with 

additional funds attracted from other sources (including private loans and loans 

from state housing finance authorities as well as tribal funding and family downpayments); 

2. 	 Using lower cost building plans and techniques (including self-help and incremental 

approaches where subsidy funds can help build a considerably more modest 

"starter-home" that families can improve and expand as their income increases); 

3. 	 Offering a variety of program formulas to more efficiently serve households with 

differing needs and incomes; for example, providing downpayment assistance only 

for those with incomes in the ranges just below the median, a continuum of 

homeownership options below that (households with incomes at the top end of this 

range would be required to pay a larger share of the costs than those at the lower 

end--shares paid by the family would change over time as their income changes), 

and more use of tenant-based assistance where a private housing stock is 

accessible. 

Even after the substantial deregulation that has occurred over the past few years, statutes 

defining HUD's Rental and Mutual Help programs still preclude using funds for creative leveraging 

schemes, help with down payments, alternative assistance formulas, and tenant-based assistance. 

Continuing to push the bulk of Federal housing assistance funds through these two limited 

program options tends to dampen local incentives to search for a more effective range of 

alternatives. 

III. DIRECTIONS FOR POLICY 

Reforming Federal Housing Assistance 

The need for continued assistance, more efficiently delivered. There is much 

evidence to suggest that American Indians and Alaskan Natives do not want lives that are 

characterized by "dependency." On the other hand, continued assistance from the Federal 

government to Tribal Areas is not only a legal obligation in most cases (under treaties between 

sovereigns), all indications are that it has widespread support, borne out the recognition that its 

withdrawal would imply a devastating blow to the cultural richness of our nation as well as a 

sense of moral obligation in response to past injustices. The enormous unmet housing needs in 

Tribal Areas documented in this report justify expanding federal housing assistance to these 

Areas, but it is reasonable for Congress to expect that such assistance be delivered in a more 
Assessment of American Indian Housing Needs and Programs: Final Report xxvii 

efficient form than it has been in the past. The challenge is to provide support in a manner that 

leverages and expands the power of these Native Americans to control and enhance their own 

destinies. 

Consolidating existing programs into a block grant framework. HUD's recent 

streamlining and deregulation of its Rental and Mutual Help programs seem to be important steps 

in the right direction, but as noted, the statutory frameworks for these programs still preclude 

sufficient flexibility. The block grant approach offered under the HOME program is already 

spurring experimentation in at least a few areas with a potentially more efficient, tribally 

determined array of program options. Although, it would seem most reasonable for HUD to 

consolidate its existing funding into a block grant framework that operates generally in the same 

way. Given the diversity of housing problems and opportunities in Tribal Areas documented 

earlier, it should be clear that different strategies will be required in different Areas--sometimes 

varying from each other in subtle ways based on tribal culture and political realities as well as 

economic and physical conditions. The strategy for any individual Area ought to be designed by 

local stakeholders who have both the knowledge of local conditions needed to select the best mix 

of activities and strong locally based incentives to implement them effectively. This approach 

would make Indian housing policy fit better with overall U.S. Indian policy in which "selfdetermination" is now the dominant theme. 

Attaching fewer Federal strings, but rigorously enforcing those that are attached. 

Recent HUD reforms have substantially reduced the regulatory burdens on these programs. In 

a new block grant, there should be yet fewer strings attached, but it is essential that some 

requirements remain to focus resources on basic national objectives that are the justification for 

Federal assistance. Probably most important in this case is requiring that the bulk of the funding 

be devoted to addreSSing the housing problems of low-income households most in need, and that 

some quantitative constraints be imposed to direct 10ca.1 decisions away from spending very large 

amounts on a small number of families while the majority of those in need remain unassisted. 

Of equal importance, program funding should be contingent on the local preparation of a Simple, 

publicly discussed, integrated housing strategy which shows how local leaders intend to allocate 

Federal and other resources. The purpose would be to make local tribal leaders more clearly 

accountable to their own members (HUD would not be expected to approve the strategy--just to 

ensure that one had been prepared). Finally, with fewer rules to monitor, HUD should be able 

to do a better job of rigorously auditing performance in relation to those requirements that remain. 

Serious penalties should be imposed for failure to comply with those requirements, and some 

form of bonuses should be considered to provide incentives for improved performance. 

I 

A phased devolution, linked to capacity building. Other researchers of Indian 

problems and institutions have recently concluded: (1) when tribal governments are given a freer 

hand in implementing their own development, they generally perform more effectively than 
Assessment of American Indian Housing Needs and Programs: Final Report xxviii 

approaches imposed from the outside; but (2) tribes vary dramatically in the effectiveness of their 

governance structures. Similarly, this study has documented substantial diversity in local 

capacity, and this may be an important constraint on policy and program devolution. Granting 

full authority and responsibility for housing development to all tribes and IHAs immediately would 

not be practical. Many are capable of handling it all now, including entrepreneurial innovations, 

but the institutional capacity of a sizeable number is not yet adequately developed. 

A phased strategy for implementing the block grant approach seems warranted, in which 

expansions of authority would go hand in hand with expansions in capacity. The initial round of 

strategic planning, as called for above, might be used to help select the most appropriate path 

for each Area. Strategies would have to include a section on proposed institutional arrangements 

for implementation, and HUD would provide resources for technical assistance to help local 

leaders understand the various programmatic options open to them and prepare their plans. 

On the basis of these submissions: (1) a large number of Tribal Areas would be given full 

authority to implement the full block grant approach immediately; (2) others would be given more 

flexibility, but be subject to closer monitoring for a fixed period as they improve their 

implementation capacity; and (3) yet others might have to wait until they had established 

adequate basic capacity to begin to perform under the new arrangements. Federal agencies 

would have to provide an adequate level of resources for technical assistance to tribes and IHAs 

in the second and third categories. 

Husbanding existing institutional capacity--ro/es for IHAs and HUD. In many Tribal 

Areas, sound working relationships have been established between tribes and their IHAs. It is 

likely that under the new approach, IHAs would naturally work with the tribes in preparing the 

strategy and the IHAs would be assigned as the lead implementing agency, taking on both more 

challenging and exciting responsibilities as they branch out from the more limited task of 

administering current HUD programs and become more entrepreneurial, for example, in seeking 

private sector financing. In some Areas, however, tribal governments might be tempted to reject 

the IHA role too easily. While this study has noted that IHA performance is uneven, the IHAs 

have generally developed a level of professional competence not easily replaced in the tribal 

structure. Ultimately, tribal governments should be able to select the institutional arrangements 

that suit them best, but constraints should be placed on their ability to eliminate existing 

performance capacity and professionalism unreasonably. 

Under the proposed approach, the Federal role changes substantially, moving away from 

direct program implementation and toward: (1) facilitating local performance capacity (through 

technical assistance, demonstrations, and information sharing functions); and (2) more careful 

monitoring and sanctioning of results. In fact, with its recent deregulation initiatives, HUD has 

moved a great distance these directions. This study has evidenced no major coordination 
Assessment of American Indian Housing Needs and Programs: Final Report xxix 

problems between Federal agencies in administering housing assistance in Indian country 

(certainly, in part, because the non-HUD programs are comparatively so small). HUD has built 

considerable capacity to understand and address AlAN housing problems and needs. We see 

no reason to shift the responsibility for administering the proposed block grant approach to any 

other Federal agency. Alternatively, we find no reason to try to consolidate aI/Indian housing 

assistance at HUD. Existing housing related functions of BIA and IHS are seen as useful 

complements to HUD's role. 

Expanding Indian access to housing assistance outside of Tribal Areas. While not 

as severe as those in Tribal Areas, the housing problems of AlAN households living in other 

areas (metropOlitan and non metropolitan) are more serious than those of the general population. 

Administrative realism, however, argues against setting up new special program initiatives to 

address their problems. Rather, emphasis should be on expanding their access to assistance 

within the framework of Federal housing programs that already exist in those areas. This implies 

the need for HUD to establish special outreach efforts for Indians in all of its programs. 

Stimulating Private Investment in Indian Housing 

As noted earlier, the number of AlAN households at moderate- and higher-income levels 

is substantial. Yet when categorized by income level and family status, AlAN homeownership 

rates are typically well below those of non-Indian households. Opportunities to increase Indian 

homeownership on market terms appear significant, and with modest subsidies, it should be 

possible to extend ownership to many more AlAN households. 

A small-scale survey of mortgage lenders conducted as a part of this study, however, 

indicated that private lending institutions near Tribal Areas in almost all parts of the country do 

now regularly originate some mortgages for Indian homebuyers, although the volumes remain 

extremely small; the reasons include lack of knowledge and initiative by tribes and their members 

as well as caution due to continued perception of high risks on the part of lenders. Major lenders 

and secondary market institutions at the national level, however, are now exhibiting considerable 

interest in finding ways to serve AlAN households in all locations more effectively. 

It is a positive sign that private intermediaries are beginning to recognize that expanded 

lending to AlAN households and communities may be a promising market opportunity. However, 

policy support is needed to translate this opportunity into reality at sufficient scale. Education and 

outreach will clearly be needed, and new institutional responses may be appropriate in a number 

of areas. 

Chapter 1 

PURPOSE AND APPROACH 

The housing problems of American Indians and Alaska Natives (AlAN) 1 have long been 

a concern of public policy in America. By the end of the 1980s, after decades of Federal Housing 

assistance, there were many indications that those problems remained serious. In 1989, 

Congress designated a National Commission on American Indian, Alaska Native and Native 

Hawaiian Housing to investigate the issue. The Commission's reports (1992, 1993) were 

provocative and contained many valuable insights. However, the Commission had not had the 

resources to undertake a thorough quantitative analysis of either the performance of the Federal 

programs that had been applied or of the problems themselves. Its 1992 report stated: 

... the lack of accurate statistics has impeded all efforts, public and private, to address 

the housing crisis in Indian Country. It is nearly impossible to set meaningful policies 

without a reliable picture of the full scope and seriousness of Native housing needs and 

how they relate to other social and economic hardships faced by America's first citizens. 

In 1993, recognizing the need for a more comprehensive and objective basis for policy 

review, the U.S. Department of Housing and Urban Development (HUD) commissioned the 

Assessment of American Indian Housing Needs and Programs, which has had three basic 

purposes: (1) evaluating the housing needs of American Indians and Alaska Natives, (2) 

assessing the effectiveness of existing federal housing programs in meeting those needs, and (3) 

comparing alternative approaches and suggesting ways in which Federal policy regarding the 

housing of these Native Americans could be improved. 

1Matthew Snipp (1989, pp. 36-40) explains why the term "American Indians and Alaskan Natives" is the preferred 

ethnic designation for the population that is the subject of this study, and we use that term most frequently. However, 

we also often use its acronym, "AlAN", and sometimes, fall back on the terms Native American and Indian to refer to 

this same population. 
Assessment of American Indian Housing Needs and Programs: Final Report 2 

Rather than simply presenting the national answers to these questions to these questions, 

however, this study has also had a special mission: characterizing diversity. Common 

observation suggests that the housing conditions of Native Americans differ substantially in 

different living environments. For example, conditions on reservations in the Northeast seem very 

different from those in the Southwest, and both may differ substantially from those in Alaskan 

villages which, in turn, appear quite unlike those for Indians living in large cities. Housing 

program performance also appears to vary in important ways in different locations. No prior 

research characterized such differences reliably, yet doing so is important because housing 

strategies that work effectively in one environment may not be appropriate in another. 

This document is the final report of the study.2 It is divided into three parts corresponding 

to the purposes noted above. By way of introduction, the remainder of this chapter: (1) reviews 

the study's overall approach and the information relied upon in the research; (2) provides a more 

detailed explanation of the structure of the report; and (3) briefly reviews the history of U.S. policy 

relating to American Indians and Alaska Natives, emphasizing the features of that history that 

establish a unique context for housing policy. 

APPROACH: THE OVERALL STUDY 

HUD selected the Urban Institute to conduct the overall study, working in collaboration with 

subcontractors Aspen Systems Corporation, and OKM Associates. The National American Indian 

Housing Council (NAIHC) also served as a subcontractor, helping primarily in making logistical 

arrangements for field surveys. HUD's design for the study recognized that information from a 

variety of sources would have to be compiled to respond to each of the project's purposes. 

The first imperative was to obtain nationwide data and perspectives on the conditions and 

issues under consideration. Doing so entailed: 

1. 	 Reviewing existing studies and reports to compile background information on the 

evolution of Indian social, economic, and housing circumstances, as well as 

relevant policies and programs. 

2Two other reports have been prepared under this study: (1) Housing Problems and Needs ofAmerican Indians and 

Alaska Natives (by G. Thomas Kingsley, Maris Mikelsons, and Carla Herbig, Washington, D.C.: The Urban Institute, 

1995) which presents more detailed analyses supporting the summary findings on this topic presented in Part I of this 

report; and (2) Housing Problems and Needs of Native Hawaiians (by Maris Mikelsons and Karl Eschbach, with Virginia 

E. Spencer and John Simonson, Washington, D.C.: The Urban Institute, 1995), containing the results of special 

analyses added to the study agenda in mid-1994, which are not reviewed in this report. 
Assessment of American Indian Housing Needs and Programs: Final Report 3 

2. 	 Consulting with experts on American Indian communities. An advisory panel, 

including scholars and Indian representatives (with substantial knowledge about 

conditions and policy issues in Indian country), provided guidance on the research 

design, provided and checked information on culture and history, and helped 

interpret findings derived from other sources. 

3. 	 Analyzing large scale data bases including the 1990 U.S. Census (focusing on 

social and economic characteristics as well as housing conditions and needs) and 

HUD management information systems (focusing on the characteristics and 

performance of HUD programs). 

4. 	 Conducting interviews with housing experts and national and regional officials 

responsible for program implementation, to gain insights on policy trends and 

options as well as program organization, interrelationships, and performance.3 

Data from these sources alone, however, could well have yielded a somewhat sterile, and 

perhaps inaccurate, portrait of actual conditions and program performance. Accordingly, the 

research design called for direct interviews and observations at the local level, first to serve as 

a "reality check" on the story obtained from national sources but, more importantly, to provide a 

much richer characterization than national sources alone could provide--one that would give us 

a clearer sense of the diversity of conditions that exist in Indian country. Four additional types 

of data collection were undertaken: 

5. 	 Conducting field interviews with Indian Housing Authority (IHA) officials and Tribal 

leaders and staff at a representative sample of 36 reservations and other Tribal 

Areas. These entailed extensive, in-person interviews on local institutional 

arrangements and procedures, housing problems, program activity, and experience 

with and attitudes about Federal programs. 

6. 	 Conducting field interviews with a sample of households at the 36 survey sites 

(and observing their housing conditions) to obtain direct information on housing 

problems; housing, tenure, and location preferences; and reactions to government 

housing programs. 

31nterviewees included representatives from HUD (central and regional offices), the Bureau of Indian Affairs (BIA), 

the Indian Health Service (IHS), the Farmer's Home Administration (FmHA), the Veteran's Administration (VA), and the 

Federal National Mortgage Association (FNMA, or Fannie Mae). 
Assessment of American Indian Housing Needs and Programs: Final Report 4 

7. 	 Conducting telephone interviews with officials of all IHAs nationally, to obtain 

comprehensive information on institutional characteristics, program activity, and 

performance. 

8. 	 Conducting interviews and preparing case studies on Indian communities in urban 

areas to identify housing conditions, needs, and prospects. Included were Public 

Housing Authorities that serve metropOlitan areas with significant enclaves of 

Native American households, and Indian Community Center staff in at least 25 

urban communities. 

The analysis of U.S. Census data contributed mainly to the first objective: the assessment 

of AlAN housing problems and needs. Information from virtually all the rest of these sources, 

however, provided inputs to all three of the primary research purposes. Figure 1.1 shows more 

specifically the major types of information from each source relied upon to help achieve each of 

these purposes. 

USE OF THE CENSUS AND HUD INFORMATION SYSTEMS 

In this section (and the one that follows it), we review in more depth the major data 

sources contributing to the study and the way they were put to use. Here the focus is on the 

approach taken to analyze data from the U.S. Census and HUD Management Information 

Systems. 

U.S. Census Data Sources and Definitions 

The decennial U.S. Census obtains a limited amount of information about each resident 

and household on a full-count basis and responses to a more elaborate set of questions on a 

sample basis. Both types of data were used in this analysis. Throughout, individuals are 

classified as American Indian or Alaska Native (AlAN) solely on the basis of whether they 

identified themselves as such in the Census question concerning "race" of the respondent. 4 An 

AlAN household is one in which either the head of the household or his/her spouse is classified 

as AlAN. 

Most important, given our purpose, we utilized numerous Census indicators on the housing 

circumstances of both AlAN and (for comparative purposes) non-AlAN households. The Census 

4Again, see Snipp (1989) for a discussion of why this approach, while it has imperfections, is superior to available 

alternatives. 
---

FIGURE 1.1 )0.

DATA COLLECTION AND ANALYSIS PLAN OVERVIEW 	 !II 

!II 

Data Sources 

1. Review published studies 

and reports 

2. Consultations with expert 

advisors 

3. Large Scale Data bases 

Analyze 

4. Interviews-National Experts 

and Officials 

5. On-site Interviews with IHA 

officials, tribal leaders 

(samples sites) 

6. Household Interviews 

(sampled sites) 

7. Telephone interviews-IHA 

officials 

8. Interviews and case studiesselected urban areas 

Housing Needs 

Appropriate measures of housing needs, special 

needs and unique circumstances, cultural 

factors, variations across communities 

Appropriate measures of housing needs, special 

needs and unique circumstances, cultural 

factors, variations across communities 

Household characteristics and incomes, housing 

conditions, housing problems, household mobility 

Household mobility, locations choice, housing 

preferences 

Assessment of local needs, special housing 

conditions and problems, cultural factors, impact 

of market conditions, mobility and location choice 

Assessment of individual housing conditions and 

problems, preferences for housing type and 

tenure, mobility and location choice 

Household mobility, location choice, housing 

preferences 

Assessment of local needs, special housing 

conditions and problems, cultural factors, impact 

of market conditions, mobility and location choice 

Federal Programs 

EXisting programs, strengths and limitations, 

implementation issues, impacts of programs 

on recipients and communities 

Existing program, strengths and limitations, 

implementation issues, impacts of programs 

on recipients and communities 

Coverage of HUD programs, types of 

households served, adequacy and affordability 

of assisted housing, allocation of subsidies 

Operation of HUD programs, planning and 

development process, project management, 

costs, modemization, unit design, outreach, 

problems and limitations, impacts on 

recipients and communities 

Local operation of HUD programs, admn 

issues, planning and development process, 

project management, costs, modemization, 

unit design, outreach, problems and 

limitations, impacts on recipients and 

community 

Knowledge of and satisfaction with HUD 

programs 

Operation of HUD programs, institutional 

arrangements and procedures, operating 

problems, program impacts 

Barriers to participation in federal housing 

programs 

- ._­

! 

Policy Assessment ~ :? 

o History of federal policy, broad policy 	 ...... 

)0. debates, program gaps and failures, 
 

altemative strategies, local demos and ~ experiments, proposed policy initiatives ::!. 
 

~ :::. 

History of ::r federal policy, broad policy 

debates, program gaps and failures 	 ~ :::. altemative strategies, local demos and 

experiments, proposed policy initiatives a: 

~ S· 

<Q 

Q) 

~ 

~ 

III Altematives for program design, 	 :::. 

Q.. funding allocation, program 

implementation l 

iiI 

~ Relationships between central, ~ regional, and local govt officials and !A!.. 

tribal leaders. Pros and cons of ;lJ 

altemative strategies ~ o 

~ 

Housing preferences and effective 

demand. Responsiveness of federal 

programs to individual needs. 

Altematives for program design, 

funding allocation, program 

implementation 

Responsiveness of federal programs to 

individual needs 

O! 
Assessment of American Indian Housing Needs and Programs: Final Report 6 

is the only comprehensive and systematically defined national source of information on key 

housing characteristics; e.g., housing tenure, age, and structure type, as well as various 

commonly recognized housing problems. With regard to the latter, the Census contains direct 

measures of the extent of overcrowding and the lack of kitchen and plumbing facilities and it 

contains income and housing cost information that enabled us to calculate the extent of 

"affordability problems" (Le., when rent or homeownership costs are excessive in relation to 

household income). The Census does not contain data on all types of housing problems, 

however. In particular, it provides no information on the structural condition of housing or on 

inadequate heating or electrical facilities (our approach to addressing this data deficiency will be 

discussed below). 

To be able to interpret information on housing conditions, we also needed to know a great 

deal about the social and economic conditions of the AlAN population. Accordingly, we also 

extracted Census data on characteristics such as age and household structure, education status, 

labor force and employment, income levels, and patterns of commuting and intercensal residential 

mobility. 

While data from a number of Census publications were used in this work, three large 

computer-based data files were relied upon primarily: 

The 1990 STF-3C File. This is one of the largest data files the Census Bureau regularly 

compiles and makes available to the public. It contains data, by race, on all of the indicators 

noted above at a detailed level geographically. It can be used to create separate tables for each 

individual state, county, metropolitan area, urban place, and (critical for our purposes) AlAN Area. 

(AlAN areas include all Indian reservations, Alaska Native Villages, and all other Census 

deSignated Tribal Areas. As used in this report, Tribal Areas include American Indian 

Reservations, Alaska Native Villages, and other special types of areas so deSignated by the U.S. 

Census--complete definitions of these area types will be provided in Chapter 2. 

A limitation of this file is that it defines AlAN households only by the race of the head of 

the household. This leaves out an important group for policy purposes--the sizeable number of 

AlAN individuals who are a part of households in which the only spouse of the household head 

(but not the head) is AlAN. 

1990 Special AlAN Tabulations. This file was created by the Census Bureau at HUD's 

request specifically for this study and it was the one we used most extensively. It does identify 

AlAN households by the race of either the household head or spouse. It also offers additional 

benefits. While it supports the same geographic breakdowns as the STF-3C file, it provides: (1) 

more detailed housing data for AlAN occupied units than are available elsewhere; and (2) cross 

tabulations of housing conditions by the income levels of occupant AlAN households, categorized 
Assessment of American Indian Housing Needs and Programs: Final Report 7 

in the same manner HUD uses in determining program priorities and eligibility (in this scheme, 

a household's income is expressed as a percentage of the median income in its local labor 

market area rather than in relation to a uniform national measure such as the poverty threshold-­

the benefits of this approach will be discussed in Chapter 2). 

1980 Census Files. It would have been desirable, of course, to examine 1980-1990 

trends in housing conditions and other social and economic characteristics of the AlAN 

population. Unfortunately, particularly with respect to housing characteristics, there were so many 

changes in the definitions used by the Census in 1980 and 1990, this type of analysis was largely 

precluded. However, we were able to relate 1980 and 1990 characteristics in a few cases and, 

most important, to analyze in some detail the patterns of growth and/or decline of total AlAN 

populations in geographic subareas throughout the country. As appropriate, we also refer to 

research by others discussing social and demographic trends for earlier periods. 

Limitations of Census Data 

In addition to the lack of information on some types of housing problems as noted earlier, 

the Census has two other limitations for the purposes of this study that should be kept in mind. 

The Increase in Self·ldentification. Particularly since 1970, the growth of the U.S. AlAN 

population as recorded by the Census has been in part explained by individuals who change their 

racial designation to AlAN; actually, by the excess of those who reported themselves as being 

of some other race in one census (or were recorded as being of some other race when born 

during the decade) and then changed to the AlAN designation in the next census, over the 

number who have done the opposite. This phenomenon was less important in the 1990 Census 

than in 1980, but even so, the group that made such a change in 1990 accounted for 9.6 percent 

of the 1990 AlAN population nationally. 

Chapter 2 discusses this issue at greater length, but we doubt that our use of Census data 

that include these individuals has any serious effect on the meaning of our findings and 

conclusions. First, the evidence suggests that this phenomenon is not sizeable in Tribal Areas, 

and that is where quantitative estimates of need are most important in relation to Indian housing 

programs. Second, even in other areas where it is more pronounced, this effect would only be 

problematic if a large share of those who changed their racial designation to AlAN did so 

untruthfully. But it is difficult to imagine any incentives that would cause many blacks, whites, and 

people of other races to falsely report their race in this way. In fact, available research suggests 

that a dominant share of those who made this change do have Indian ancestry; i.e., this 

phenomenon has been caused primarily by people recognizing a true Indian heritage after failing 

to report it in the past. 
Assessment of American Indian Housing Needs and Programs: Final Report 8 

The Undercount. A Census Bureau report on a special survey undertaken shortly after 

the 1990 enumeration, estimates that the Census' 1990 published figures understate the size of 

the AlAN population overall by 4.6 percent (not statistically different than the undercount 

estimated for either blacks or Hispanics), but more notably, they understate the numbers living 

in Tribal Areas by 12.2 percent (Bureau of the Census, 1992). The special survey employed a 

very small sample and it offers no basis for comparing the characteristics or locations of those 

who were counted and those who were missed in the original enumeration. 

The Census Bureau decided not to adjust its official totals to reflect the undercount but 

there are many who believe they should have done so. In most of this report, we review 

information based on the official figures (it seems unlikely that the undercount could have sizeable 

effects on proportional relationships, which we examine most frequently). However, this 

difference is important when we offer estimates of the absolute magnitude of AlAN housing 

needs. Accordingly in Chapters 5 and 7, where we address this topic, estimates are provided 

both on the basis of the official figures and those that would result from an upward adjustment 

to compensate for the undercount. 

Tribal Area Boundaries. In establishing Tribal Area boundaries for its enumeration, the 

Census Bureau relied on legal definitions provided by the Federal or relevant state govemment 

or, in some cases, the tribe. In the vast majority of cases the boundaries of the Area so defined 

(e.g., the reservation) incorporate all of the lands traditionally regarded as the geographical 

expanse of the "tribal community." In a few cases, however, the current legal boundary defines 

an area that is smaller than the area of the traditional community and, therefore, the Census 

numbers understate the populations of that community. This problem is most serious for 

California Rancherias (see further discussion in Chapter 2). 

HUD Management Information Systems 

HUD maintains several computer-based information systems containing data about its 

Indian Housing programs. These have been used most extensively for the program assessment 

component of the overall study and some use of them was required for the analysis of housing 

problems and needs as welt.s Most data were derived from two HUD systems: 

The Management Information Retrieval System (MIRS) which, for each Indian Housing 

Authority (IHA), contains a wealth of information about their programs' size, past growth, housing 

unit characteristics, development and operating costs, and other indicators of institutional 

performance. 

SThe main use of these data in the housing needs analysis was in measuring the extent of current assistance being 

provided in relation to overall needs; determining what portion of the total need is already being met. 
Assessment of American Indian Housing Needs and Programs: Final Report 9 

The Multifamily Tenants Characteristics System (MTCS) which contains data on the 

characteristics of the households occupying HUD units, including household size, race, and 

income characteristics.6 

Data Base Integration 

In preparation for the 1990 Census, the Bureau of the Census made an extensive effort 

to identity and map all Tribal Areas nationwide. Lists of all Federally recognized areas were 

obtained from the Bureau of Indian Affairs (BIA) and all States provided lists of other Tribal Areas 

within their boundaries.7 A total of 567 such areas were identified (some were areas controlled 

by tribes that had no resident population in 1990--the 508 which had AlAN inhabitants are the 

subject of much of the analysis of housing problems and needs in this report). 

The design for this study required that we integrate information from the Census with 

information obtained on an IHA basis from HUD Management Systems and other surveys. 

Accordingly, it was necessary for the study team to correctly link Tribal Area codes and IHA 

codes in our data files. In 1994, there were 187 recognized IHAs, 181 of which were fully 

operational at the time of our surveys. The task was not always straightforward since several 

IHAs serve more than one Tribal Area and there is also a sizeable number of Tribal Areas not 

served by any IHA. HUD Field Offices of Native American Programs (FONAPs) were contacted 

to review complex cases and double check preliminary lists to assure the correct linkages were 

made. 

As a result, we are able for the first time to accurately report Census data for IHA service 

areas. (The results of this linkage are provided in all major data files produced under this study, 

as submitted to HUD. Key data are presented in Annex A at the end of this report.) 

6HUD has built the MTCS system only recently. It now provides a full year of income certification and recertification 

data, derived from HUD form 50058, with a reporting rate of 59 percent for all residents of IHA housing. The system 

contains information on a variety of social and economic characteristics of households living in units managed by both 

Public and Indian Housing Authorities nationwide. 

7Definitions of types of Tribal Areas will be provided in Chapter 2. For further definitions and a description of the 

process used to identify these areas, see Bureau of the Census, 1993, pp. A 1-A3. 
Assessment of American Indian Housing Needs and Programs: Final Report 10 

SURVEYS AND OTHER INFORM ATlON SOURCES 

Field Surveys: Indian Housing Authority (IHA) Officials 

and Tribal Leaders and Staff 

As with data from HUD management systems, these interviews were conducted mostly 

to support the program and policy assessment components of the overall study. However, they 

also provided some information for the housing problems and needs component: primarily insights 

on housing problems and housing and locational preferences of families in AlAN Areas. 

Selecting the Sites. The key objective of the sampling plan was to select a group of sites 

that, within the confines of the project budget, would best reflect the diversity of conditions that 

exists in Indian country. This selection was a two-stage process, entailing: (1) dividing the 

country into a number of study regions which were judged to be at least relatively homogenous 

internally; and (2) randomly selecting IHAs within each region, with constraints to assure that both 

large and small areas (in terms of population) were represented. 

Regional division began with the service areas of the HUD's six FONAPs. Three of these 

areas (those headquartered in Chicago, Oklahoma City and Phoenix) were considered too 

heterogeneous for these purposes and were split to yield the· nine basic study regions used 

throughout this study as shown in Figure 1.2: (1) North Central; (2) Eastern; (3) Oklahoma; (4) 

South Central; (5) Plains; (6) Arizona-New Mexico; (7) California-Nevada; (8) Pacific Northwest; 

and (9) Alaska. Actually, for sampling and analysis of field survey data, 10 regions were used. 

The Navajo Reservation (which is by far the largest Tribal Area, alone accounting for 20 percent 

of the AlAN population in all such areas) was considered a separate region for these purposes 

(6A), split off from the rest of the Arizona-New Mexico region (68). 

A total of 36 sites were selected through this process (more were selected in some 

regions than others because those regions had a larger number of Tribal Areas). The final list 

of sites visited (identified by the name of the IHA) is provided in Figure 1.3. 

Survey Field Work. Arrangements for the field work were made in March and April 1994, 

and all 36 site visits were completed by August.s The work on-site typically entailed a two day 

visit by a two person team: an interviewer from the contractor team and a "facilitator" (consultant 

or NAIHC staff member who was known to the IHA and tribe and could help make arrangements 

81t proved difficult to work out arrangements for the surveys at two of the sites originally selected. The sample 

design had included a replacement sample, anticipating that such difficulties might occur. Two replacement sites were 

selected and surveys were scheduled there without unreasonable delays in the overall study program. 
Assessment of American Indian Housing Needs and Programs: Final Report 11 

Sellttle FONAP Danvar FONAP 

Chicago FONAP 

0IcIah0nII CIty FONAP 

FIGURE 1.2 	 Study Regions Based on HUD Field Office of Native American Programs 

(FONAP) Service Areas 

efficiently and assure effective communication). The work involved interviews with the Tribal 

Chairman (normally 35 minutes). tribal housing staff (1.5 hours--these interviews were possible 

for only 26 of the 36 tribes visited because the others did not have staff with housing program 
Assessment of American Indian Housing Needs and Programs: Final Report 12 

responsibilities), and the IHA Director and staff (4.5 hours), along with direct observation of 

housing conditions and making arrangements for the household surveys (see discussion below).9 

Survey Instruments. All questionnaires for this study were approved by the Office of 

Management and Budget (OMB). The instrument for the IHA survey, which was the most 

extensive, focused on program administration issues. The IHAs administer two HUD programs 

(Rental and Mutual Help) and although their responsibilities in the two programs differ, they are 

Figure 1.3 

FIELD SURVEY SITES 

REGION 1 - NORTH CENTRAL 

Lac Vieux Desert, MI 

Leech Lake, MN 

Red Lake, MN 

Sokaogan, WI 

Menominee, WI 

REGION 2 - EASTERN 

Mashantucket Pequot, CT 

Seminole, FL 

East. Cherokee (Qualla), NC 

Seneca Nation, NY 

REGION 3 - OKLAHOMA 

Creek Nation, OK 

Kiowa, OK 

Comanche, OK 

Delaware, OK 

REGION 4 - SOUTH CENTRAL 

Chitimacha, LA 

Alabama-Coushatta, TX 

REGION 5 - PLAINS 

Turtle Mountain, NO 

Santee Sioux, NE 

Rosebud, SO 

Cheyenne River, SO 

REGION 6A - NAVAJO 
 

Navajo, AZ. 
 

REGION 68 - REST OF ARIZ-NEW 
 

MEXICO 
 

Gila River, AZ. 
 

Yavapai-Apache, AZ. 
 

Tohono O'odham, AZ. 
 

Northern Pueblos, NM 
 

REGION 7 - CALIFORNIA-NEVADA 

Round Valley, CA 

Karuk, CA 

Pyramid Lake, NV 

Reno-Sparks, NV 

REGION 8 - PACIFIC NORTHWEST 

Fort Hall, 10 

Makah, WA 

Chehalis, WA 

Tulalip, WA 

REGION 9 - ALASKA 

AVCP,AK 

Interior Regional, AK 

Copper River Basin, AK 

Kodiak Island, AK 

9Where the sampled IHA provided housing services to more than one tribe, only one tribe was selected for the 

interviews with the Chairman and staff. 
Assessment of American Indian Housing Needs and Programs: Final Report 13 

generally concerned with two processes within each: (1) developing new housing (planning, site 

selection, construction, etc.); and (2) the operation and maintenance of existing housing 

(processing application, collecting payments from occupants, maintenance and modernization, 

etc.). The IHA instrument asked a series of questions about each of these processes and 

subprocesses generally dealing with: how the work was performed; perceived obstacles and 

barriers to its performance; the influence of HUD (regulations and staff) on outcomes; and 

suggestions for improvements. The IHA instrument, however, also covered a range of other 

topics, including: perceptions about other housing programs operating in the area; perceptions 

about housing problems and needs (in both assisted and unassisted housing); relations between 

the IHA and the tribes; broader barriers to housing improvement to the Tribal Area and how they 

might be overcome. 

The instrument for the Tribal Leader survey was comparatively brief. It included questions 

on: the nature and extent of .Iocal housing problems; desires and perceptions of tribal members 

with respect to housing and living on vs. off the reservation, IHAltribal relationships, and 

perceptions about assistance provided by Federal agencies other than HUD. 

The instrument for the Tribal Staff survey overlapped topics covered in Tribal Leader 

questions to some extent, but also examined: the operations and performance of housing 

assistance programs administered directly by the tribe; views on the operations of IHA programs; 

perceptions of local housing conditions; and tribal preferences as to housing and living 

environments. 

Field Surveys: The Household Survey 

While asking tribal and IHA officials about the housing problems and preferences of the 

people in their areas, and about housing assistance programs, was likely to be helpful, it was 

recognized that it was no substitute for asking the people themselves. Because a full-scale 

probability sample would have been too costly and time consuming, it was decided to conduct 

a smaller sample survey of 20 households at each of the 36 field-visit sites. 

Survey Design Issues. It was also recognized that any such survey could have 

difficulties. It was expected that many AlAN households would be reticent about participating (a 

large number of tribes have been "over-surveyed" in the past). This might be particularly true if 

outside non-Indian interviewers were assigned. Outside interviewers might also find it impossible 

to communicate effectively given differences in culture and, in many cases, language. If tribal 

people conducted the survey, however, the results were likely to be questioned because of 

possible biases. 
Assessment of American Indian Housing Needs and Programs: Final Report 14 

These issues were addressed as follows: First, sample selection was done directly by 

contractor staff, applying a rigorous random sampling procedure to either the tribal membership 

roster or a local list of registered voters. Second, interviews were conducted by a local tribal 

member (normally one recommended by the tribe or IHA), but three steps were taken to promote 

quality and objectivity: (1) selected interviewers were trained at some length while the contractor 

was on site (including being required to conduct one or more full rehearsal interviews with the 

contractor's site team); (2) extra care was given in the design of the survey instrument so that it 

would be simple and clear; and (3) after the surveys were completed, contractor staff conducted 

quality control checks (by phone) with a sample of the original respondents. 

Survey Results. This procedure yielded results that were generally useful, although far 

from perfect. Problems connected with the responsibility or capacity of the selected local 

interviewer, or with tribal reticence, prevented the completion of these surveys in 12 of the 36 

sites. For the two thirds that completed them, however, the information gathered appeared 

valuable for analytic purposes. The returns were well balanced across regions and the quality 

of the data submitted was high. Cross tabulations yielded reasonable distributions and 

comparatively few records had to be rejected because of obvious miscoding--a total of 414 

useable household records were produced. The quality control process indicated that the 

completed surveys were conducted much in accord with specifications. 

Nonetheless, because of the small number of respondents, all results of this survey must 

be interpreted with caution. As would be expected, confidence bands around point estimates are 

sizeable. For example, at the 95 percent confidence level, the estimated share of all of housing 

units that are overcrowded falls in the range from 6.2 percent to 14.8 percent; the estimated share 

reporting that the lack of adequate insulation against the cold is a serious problem falls in the 

range from 24.2 percent to 37.3 percent. 

IHA Telephone Surveys 

This survey was implemented successfully between mid-February and late April, 1994. 

Useful data were gathered from 177 of the 181 IHAs that were fully operational at that time, for 

a 98 percent response rate. This survey focused mostly on program assessment issues but did 

yield some data on perceptions (on locational patterns and preferences) relevant for analyses of 

housing problems and needs. Topics covered by the survey instrument were generally similar 

to those in the IHA instrument for the 36-site field survey (noted above), but due to the time 

constraints of the telephone format, this survey did not attempt to address them in the same level 

of detail. 
Assessment of American Indian Housing Needs and Programs: Final Report 15 

Interviews and Case Studies: Indians in Urban Areas 

Early in the project, it was realized that the housing needs and conditions of urban Indians 

appeared to differ significantly from those in other areas. In order to get a clearer understanding 

of these conditions, we undertook both a special analysis of census data for metropolitan areas 

with the highest concentration of Indians, and case study interviews. 

Interviews with Community Center Directors. Unlike our on-site data collection in Tribal 

Areas, where we were able to interview IHA directors, tribal housing staff, and tribal leaders 

regarding the housing condition and needs of the community, there were no comparable groups 

in urban areas. We chose instead to identify urban Indian Community Centers across the nation 

whose key staff could provide insight into the housing and socioeconomic circumstances of the 

urban Indian community they serve. We identified 28 such Community Centers whose directors 

were able to participate in a telephone interview which focused on the housing needs and 

conditions of the Indian community. These interviews, conducted in the winter of 1993, included 

both closed and open-ended questions and generally lasted about one hour. 

Interviews with Public Housing Officials. We conducted interviews with selected HUD 

headquarters and field staff whom we felt had specific knowledge regarding the provision of 

service of federal housing programs to urban Indians. A survey of local Public Housing AuthOrity 

(PHA) Directors was also contemplated. However, exploratory calls to 6 PHAs indicated that they 

had virtually no personal knowledge or readily available data concerning Indians in their projects, 

and no special programs related to them. Accordingly, the full survey was not conducted. 

Case Studies. To collect additional data on the housing situation of urban Indians, we 

undertook case study analyses in three cities: San Francisco, Oakland, and Chicago. These 

cities are by no means representative of all urban areas, but further serve to illustrate the diversity 

of housing conditions and needs of urban Indians. Case studies were prepared through in-depth 

interviews with a number of key informants at each site. Informants were selected based on 

discussions with our AdviSOry Panel members and Indian Community Center staff. Interviews 

were generally informal although an interview guide was used so that key themes were 

highlighted and remained consistent across sites. Case study interviews were conducted 

between October, 1993 and May, 1994. 

A formal sample survey of AlAN households living in urban areas would, of course, have 

been desirable. However, no complete listings of such household exist. The costs of both 

identifying the universe, selecting a sample, and then conducting interviews would have been well 

beyond the resources available for this study. 
Assessment of American Indian Housing Needs and Programs: Final Report 16 

STRUCTURE OF THE REPORT 

As noted earlier, this report is organized into three parts, reporting findings and 

conclusions related to each of the study's three main purposes. 

Part I--Housing Problems and Needs 

Part I is composed of two chapters which summarize the results of the more complete 

study report on this topic (Kingsley, Mikelsons, and Herbig, 1996). Chapter 2 looks at AlAN 

population dynamics and social and economic conditions. First, it reviews recent growth trends 

for the AlAN population in America overall. It next offers new perspectives by examining the 

spatial pattem of AlAN growth in the 1980s, considering variations in growth by region, and for 

various types of areas (Tribal Areas, surrounding counties, other metropolitan areas, other 

nonmetropolitan areas) within regions. 

The text then reviews the social and economic circumstances of AlAN population and 

households, using the same spatial framework. At the most general level, the analysis finds 

some consistent patterns in the differences between AlAN and non-Indian conditions in each type 

of area, and in the differences between the circumstances of AlAN populations in different types 

of areas. It then recognizes, however, that there is substantial diversity around area-type 

averages and characterizes that diversity. 

Chapter 3 presents the results of the assessment of housing problems and needs. It 

begins with a conceptual framework for understanding and measuring AlAN housing problems. 

The framework is then applied, using Census and household survey and data along with some 

other indicators, to estimate the nature and extent of AlAN housing problems in 1990--for the 

nation as a whole and for each of the basic area types. The analysis demonstrates that the 

housing problems of American Indians and Alaska Natives remain severe, particularly in Tribal 

Areas. This presentation is followed by a return to the topic of diversity, applying it now to 

housing problem indicators, both in Tribal Area and urban settings. The chapter closes with a 

look at likely future trends in AlAN housing problems and opportunities, and a discussion of 

implications for alternative approaches to national and local housing policy. 

Part II-Program Assessment 

To provide perspective, Chapter 4 opens with a brief historical account of the evolution 

of Indian housing policy in the United States. It then describes the array of Federal housing 

assistance programs operating in Indian country and explains their purposes, how they work, and 
Assessment of American Indian Housing Needs and Programs: Final Report 17 

their recent funding levels. Finally, it explains the approach to be taken in assessing these 

programs. 

Chapter 5 presents the assessment of the two programs that dominate housing assistance 

in Tribal Areas: HUO's rental and Mutual Help programs. It first reviews characteristics of the 

programs' housing stock and its beneficiaries. It then examines the processes of developing new 

housing and operating and maintaining existing housing under these programs and analyzes 

institutional performance (both at the national and the local levels). 

Chapter 6 begins by offering briefer assessments of other types of housing programs 

operating in Indian country: the Bureau of Indian Affairs' (BIA) HIP program, tenant basedassistance, block grant programs, and financing assistance. The chapter closes with a summary 

assessment of both the contribution and problems of Federal housing assistance programs 

operating in Tribal Areas. 

A number of changes were being made to HUO's programs while this study was 

underway. Readers should keep in mind that survey respondents were reporting on conditions 

as they saw them roughly in mid-1994. Attempts to update program descriptions were cut off as 

of the end of 1994. It is likely that other changes have been made since then that are not 

reflected herein. 

Part III-Policy Directions 

Chapter 7 opens this Part with a discussion of trends and conditions in the policy 

environment that affect possible futures for Indian housing policy. A two part approach to policy 

falls naturally from this chapter and the findings and conclusions of Parts I and II. 

First, there is a need to substantially reform the nation's current approach to providing 

housing assistance for low-income families in Indian communities--to deliver assistance more 

equitably and efficiently. How that may be addressed is the subject of Chapter 8. The chapter 

begins with a review of the context for Federal assistance policy, compares alternative 

approaches to policy change, and closes with a number of more specific recommendations. 

Second, however, the analysis makes it clear that Federal assistance in and of itself will 

never be a sufficient or appropriate way to deal with the ,full range of housing problems and 

opportunities in Indian country. The ultimate solution to the housing deprivation in Tribal Areas 

will still require Federal assistance, but it will also rest on spurring economic development (which 

will increase incomes), and reducing current barriers to market oriented mortgage lending, in 

order to lay the basis for substantially increased private investment in Indian housing. This 
Assessment of American Indian Housing Needs and Programs: Final Report 18 

potential, and policy directions, related to enhancing private mortgage lending in Indian country 

are discussed addressed in Chapter 9. 

AMERICA'S INDIAN POLICY: AN OVERVIEW 

The relationship between the federal government and American Indian and Alaska Native 

tribal governments is unique. A complex body of law governs this relationship based on a history 

of military dominance, subjugation, the ceding of Indian lands, and subsequent policies of 

assimilation versus self-determination and self-government. To understand current Federal Indian 

housing policy, one must first look at the evolution of America's overall Indian policy. 

The Sovereign-to-Sovereign Relationship and Trust Land 

Before the formation of the United States, the administrators of some British and Spanish 

colonies began negotiating treaties with native tribes. These tribes were given sovereign status 

similar to that of colonial governments. While treaties primarily dealt with the ceding of native 

land or boundary disputes, they also affirmed tribal ownership of land. By the time of the 

American Revolution, treaties were well established as a means of negotiating terms with Indian 

tribes. According to the 1781 United States Articles of Confederation, the Federal government 

had sole and exclusive authority over Indian affairs; however, states could not have their 

legislative rights infringed or violated by such authority. This left some ambiguity regarding 

federal and state power over Indian tribes. Subsequent laws, however, clarified that the Federal 

government's position would be dominant in Indian affairs. 

During the period from 1789 to 1871, the Supreme Court and Congress set the foundation 

for American Indian law and policy. The legal opinions by Chief Justice John Marshall known as 

the "Worcester Trilogy" served as the foundation for defining the Federal trust responsibility, and 

the Indian Commerce Clause of the United States Constitution gave Congress the power to 

regulate commerce with foreign nations, states and Indian tribes. The Indian Trade and 

Intercourse Act of 1790 brought nearly all interactions between Indians and non-Indians under 

federal control. 
Assessment of American Indian Housing Needs and Programs: Final Report 19 

Since then, Federally recognized tribes are seen under American law as independent 

nations, and the Federal government deals with them directly in a sovereign-to sovereign 

relationship.lO 

The most unique feature of this relationship--one that has profound implications for 

housing pOlicy--is the concept of "trust responsibility." Chief Justice Marshall stated that, "The 

Indian nations had always been considered as distinct, independent political communities, 

retaining their original natural rights, as the undisputed possessors of the soil."ll The Indian 

Trade and Intercourse Act of 1790 had specifically prohibited the sale of Indian land without 

Federal approval. 

In most reservations, through the present time, much of the land is held in trust on behalf 

of the tribe as a whole by the Federal Government; i.e., the land is not divided up among 

individual tribal members who can buy and sell parcels as they choose. Rather, the Bureau of 

Indian Affairs (BIA) of the Department of the Interior holds the title to these lands and administers 

the trust. Tribes cannot agree to any encumbrance (such as formally leasing the land to any 

party) without BIA approval, and actual sales of "tribal trust land" to non-tribal private entities 

virtually never occur. In these areas, tribes normally "assign" defined parcels to individual tribal 

members for their use, but this assignment does not actually transfer title to the land. In some 

areas, where tribes are not Federally recognized, individual States playa similar role, holding the 

tribe's land in trust. 

Removal and "Indian Territory" 

The extent and pattern of Indian landholdings today, however, is very different from what 

it was at the beginning of the 19th century. That century saw a persistent whittling away of the 

land area over which Indian's had sovereignty as the idea of "manifest destiny" emerged and 

wave after wave of white settlers moved west to gain control. 

Policy in the early 1800s favored a clear spatial separation of Indian and white 

settlements. Pressures on the land from a growing white population in the eastern states, led to 

the concept of forcefully moving Indians from their aboriginal lands east of the Mississippi to a 

new "Indian Territory" farther west (eventually narrowed in definition to what is now the State of 

Oklahoma). The policy was implemented under the Indian Removal Bill of 1830. Indians resisted 

10AIthough as Waldman (1985) suggests, "Sovereignty, as it has been applied to Indian tribes, is a relative term. 

Unilateral action on the part of the federal govemment has eroded the original concept ... The limited sovereignty of 

tribes as it exists today is comparable to that held by the states. The tribes have powers to govern themselves, but 

only under Federally imposed regulations." 

11Cited by the National Commission on American Indian, Alaska Native and Native Hawaiian Housing (1992), p. 7. 
Assessment of American Indian Housing Needs and Programs: Final Report 20 

the removallaw--in battles and in the courts--but a decade later most eastern Indians had been 

relocated. In some cases, several tribes were moved into one of the new Tribal Areas created, 

and the government proceeded to deal with them as one tribe rather than recognizing them as 

various and distinct tribes. 

The rest of the century witnessed continued delineation, and curtailment, of Indian land 

areas farther west as white settlement proceeded. It was during this period that many of today's 

reservations were defined through treaties--often small pieces cut out of sizeable land areas 

which tribes had considered their own. 

Allotment and Assimilation 

Congress' passage of the General Allotment Act (or the Dawes Severalty Act) in 1887 

signaled an important shift in Federal policy in one sense--the guiding concept had changed 180 

degrees, from separateness to assimilation--but in another sense it remained the same: the 

outcome was a continued dwindling of Indian land resources. Under this Act, large tracts of 

Indian land were ceded for homesteading in many parts of the country.12 In the ceded areas, 

the land was divided with 160 acre parcels allotted to each Indian family who, having attained 

individual rights, would presumably be motivated to farm it more effectively. Allotted Indians were 

to be subject to local and State, rather than tribal, jurisdiction. Remaining lands in the ceded 

areas not allotted to Indians were made available for homesteading by non-Indians, again with 

the rationale of improving the utilization of tillable lands. 

It was expected that the allotment approach in itself would promote assimilation, but that 

objective was reinforced in other ways. For example, the BIA established boarding schools for 

Indian youngsters who were required to abandon their native languages, dress, religion and other 

traditional customs. In 1924, as a move to provide equity and further promote assimilation, for 

the first time, Indians were made United States citizens. 

The land allotments to Indians under the Dawes Act first created the concept of "individual 

trust land": where the BIA holds parcels of land in trust for the benefit of individual Indians (and 

their heirs) rather than the tribe as a whole. Again, the individuals cannot sell these allotments, 

and cannot not encumber them, without BIA approval.13 Unlike the case of tribal trust land, 

sales of individual trust lands can and do occur--the process is just more cumbersome than is 

typical in normal private land markets because of BIA involvement. Further complicating such 

12The proportion of the total area ceded for homesteading (vs. being left as tribal trust land within the reservation) 

varied from tribe to tribe. 

130riginally, the allotments were to remain in trust for 25 years, but the Dawes Act was subsequently amended to 

extend indefinitely the time allotments remained in trust. 
Assessment of American Indian Housing Needs and Programs: Final Report 21 

transactions today is the fact that these allotments are now typically held by a number of heirs 

of the original allottee. Decisions conceming the use of the land, and any possible sale or other 

encumbrance, must be made by them jOintly. 

There is little disagreement that many abuses occurred during the period when allotment 

and assimilation were the main policy themes. Because of high taxation, corruption of officials, 

and other unscrupulous practices of land speculators, many Indian allottees lost their land. 

Federal policy toward Indians was to change again in the 1930s, but this period had seen a 

dramatic reduction in the extent of Indian lands nationally. By 1934 the total was only a little over 

one third of what it had been in 1887 (a decline from 138 million acres to 48 million acres). 

Today the residual effects of allotment remain most relevant to Indian policy in the State 

of Oklahoma. Large areas of that state are under tribal jurisdiction (delineated as Tribal 

Jurisdiction Statistical Areas by the Census--see Chapter 2). These areas include a mix of land 

types: some tribal trust land, some individual trust land, and some private land (owned by Indians 

and non-Indians). In the rest of the country, most of the areas that remain under tribal jurisdiction 

are the reservations as defined earlier (what is left of them), whose areas are predominantly held 

as tribal trust land. 

The Indian "New Deal" 

In the 1920s, allotment/assimilation policies came under fire and there was increasing 

concern for the welfare of American Indians. In 1921, the Snyder Act authorized BIA to provide 

a broad range of social, economic and educational assistance programs to recognized tribes. 

In 1929, a study of Indian affairs, made at the request of the Secretary of Interior, was 

prepared by the Brookings Institution. Saunders (1966) notes that it described wretched 

conditions under which Indians lived and recommended an increase in educational programs, 

emphasized health services, economic development and better living conditions, and an end to 

the allotment policy. 

This report accelerated pressure for reform in Indian affairs and ultimately led to 

substantial policy change through passage of the Indian Reorganization Act (IRA) of 1934. In full 

contrast to past pOlicies, this act promoted tribal self-government by encouraging tribes to adopt 

constitutions thus forming a more solid basis for tribal political authority. It returned unsold 

allotted lands to tribes and provided for their purchase of Inew land. It also emphasized "onreservation day schools instead of off-reservation boarding schools; advocated the hiring of 

Indians by the BIA and Indian involvement in policy making at the national and tribal levels; 

extended Indian trust status; and granted Indians religious freedom" (Waldman, 1985, p.194). 

Furthering these themes, in 1946 Congress created the Indian Claims Commission as an 
Assessment of American Indian Housing Needs and Programs: Final Report 22 

independent agency to expedite Indian claims processing and provide financial compensation for 

treaty violations. 

Termination and Relocation 

Opponents of the New Deal policies toward Indians had been there all along and in the 

1950s they gained the upper hand. Assimilation once again became the watchword. This was 

implemented in .three ways: 

The first was the "termination", brought about by the passage of House Concurrent 

Resolution 1 08 of 1953. Termination was an experiment imposed on many California Rancherias 

and some other tribes, ending the special trust relationship between them and the Federal 

government. Between 1954 and 1962, Congress passed specific laws authorizing the termination 

of 61 Indian tribes, bands, and communities. One hundred thirty-three separate bills were 

introduced to permit transfer of trust land from Indians to non-Indians (Comell and Kalt, 1992, 

p.12-13). 

Second, many tribes not terminated were subjected to a series of laws transferring 

responsibility from the BIA to other agencies and, in some cases, to the states. Public Law 280, 

for example, gave selected states civil and criminal jurisdiction over reservations without tribal 

consent. 

Third was a policy of relocation, implemented through the BIA's Direct Employment 

(Relocation) Program. This program was explicitly aimed at moving Indians from the reservations 

to a selected group of urban areas with the goal of furthering their employment and assimilation. 

There were eleven relocation centers, half of which were on the West Coast. 

Self-Determination 

In the late 1960s and early 1970s, the pendulum swung back again (and has remained 

generally in the same position since then). The key theme of this era has been "selfdetermination". A series of studies and commission reports in the 1960s criticized termination, 

proposed that this new theme be emphasized, and called for more effective Federal assistance 

to address the plight of American Indians in all parts of the country. Congress responded in a 

number of legislative enactments. 

These included the Indian Civil Rights Act of 1968, which provided rights to tribal members 

in dealing with tribal govemments, and allowed states to transfer jurisdiction back to the tribes and 

Federal govemment, and the Indian Self-Determination and Education Assistance Act of 1975 

(PubliC Law 93-638), which encouraged tribes to assume administrative responsibility for 
Assessment of American Indian Housing Needs and Programs: Final Report 23 

programs administered by the SIA and the Indian Health Service. 14 They have also included 

other steps to restore a number of tribes that had been terminated, and actions focused on 

supporting Indian cultural renewal and economic development. 

Different administrations have given more emphasis to some issues than others, but the 

basic theme has been endorsed throughout. In 1983, President Reagan restated the unique 

"government to government" relationship between the United States and Indian tribes. In 1994, 

President Clinton reaffirmed a commitment to self-determination for tribal governments, and 

stressed the need for a federal-tribal partnership (SIA, 1994). 

Special Circumstances of Alaska Natives 

Alaska Natives had little contact with Americans even after the United States bought the 

territory of Alaska from Russia in 1867. No treaties were negotiated with them and their land 

claims were not fully defined until the passage of the Alaska Native Claims Act of 1972 (ANSCA). 

The Act established, under State law, village and regional corporations in which enrolled natives 

received corporate stock. Those corporations, now own the land and protect against alienation 

through corporate bylaws. In October of 1993 the Department of Interior recognized Alaska Native 

groups as acknowledged tribes with the same status as tribes in the contiguous 48 states. 15 

Conclusions 

Indian tribes have proven resilient. In the last two centuries and more, they have faced 

phenomenal economic, political and cultural changes. From military violence and subjugation, 

horrific epidemics of disease, land seizures, and economic deprivation, tribes have somehow 

managed to survive, and in some cases are making significant progress in independence and 

economic viability. Distinct tribal nations are built upon dozens of cultural lineages that have 

persevered, bound together by ties of family, language, history and cultural heritage. 

Cornell and Kalt (1992) state that the lesson from Indian Country is a lesson of strength: 

"As long as American Indians and Alaska Natives retain power, land and resources, there will be 

struggles over control and management of those lands and resources. Americans must learn the 

history of the federal-tribal relationships, the unique legal status of Indians, and understand the 

heritage and cultures of Indians to begin to comprehend the issues involving American Indians 

today." 

14For a more complete list, see Waldman, 1985, p. 195. 

15Federal Register, Vol. 58, No. 202, October 21, 1993, pp. 54364 - 54369. 
Assessment of American Indian Housing Needs and Programs: Final Report 24 

REFERENCES 

Bureau of the Census. 1993. 1990 Census of Housing: Detailed Housing Characteristics, 

American Indian and Alaska Native Areas. 1990 CH-2-1A. Washington, D.C.: U.S. 

Department of Commerce. 

______. 1992. "The Coverage of American Indians in the 1990 Decennial Census". 

Presentation to the American Indian and Alaska Native Census Advisory Committee. 

Washington, D.C.: U.S. Department of Commerce. 

Bureau of Indian Affairs. 1994. Indian News. Vol. 18, May 13. 

Cornell, Stephen, and Joseph P. Kalt, Eds. 1992. What Can Tribes Do?: Strategies and 

Institutions in American Indian Economic Development. American Indian Handbook and 

Manual Series No.4. Los Angeles: American Indian Studies Center, University of 

California at Los Angeles. 

Kingsley, G. Thomas, Maris Mikelsons, and Carla Herbig. 1996. Housing Problems and Needs 

of American Indians and Alaska Natives. Washington, D.C.: U.S. Department of Housing 

and Urban Development. 

National Commission on American Indian, Alaska Native and Native Hawaiian Housing. 1992. 

Building the Future: A Blueprint for Change. Washington, D.C.: National Commission on 

American Indian, Alaska Native and Native Hawaiian Housing. June. 

______. 1993. Supplemental Report and Native American Housing Improvements 

Legislative Initiative. Washington, D.C.: National Commission on American Indian, Alaska 

Native and Native Hawaiian Housing. January. 

Saunders, Charles. 1966. The Brookings Institution: A Fifty-Year History. Washington, D. C.: 

The Brookings Institution 

Snipp, 	 C. Matthew. 1989. American Indians: The First of This Land. New York: Russel Sage 

Foundation. 

Waldman, Carl. 1985. Atlas of the North American Indian. New York: Facts on File, Inc. 
PART I 
 

HOUSING PROBLEMS 

AND NEEDS 

Chapter 2 

POPULATION GROWTH, SOCIAL AND 

ECONOMIC CONDITIONS, AND 

SPATIAL PATTERNS 

Research to support housing policy always begins with demographics. The most basic 

questions are, "how much, and where?"--how large is the population to be housed and how it is 

distributed geographically. Beyond understanding the current pattern, it is also essential to 

develop some sense of how that pattern is likely to change in the future--appropriate policies for 

two areas with similar conditions now will obviously differ markedly if one is losing population 

rapidly while the other faces burgeoning growth. How fast is the population growing, are the 

trends altering its spatial pattern, what are the factors influencing the trends, and how might they 

change in the future? 

Housing analysis must also be based on understanding of the social and economic 

conditions of the population to be served. Their age structure and household composition are key 

determinants of the types of housing they require; their success in the labor market, largely 

determines their income, which in turn, is the primary determinant of what housing they can 

afford. These are the issues addressed in this chapter. 

POPULATION TRENDS: DECLINE AND RESURGENCE 

There is considerable uncertainty about the size of the AlAN population in North America 

in pre-Columbian times. The most widely accepted estimates range from 2 million to 5 million. 

There is general agreement, however, that the arrival of European settlers led to a tragic loss of 

population, more due to diseases like smallpox and cholera than military confrontations. 16 

16See a full discussion of this history in Snipp, 1989. 
Assessment of American Indian Housing Needs and Programs: Final Report 26 

As European settlers moved west, they found the territory sparsely settled by nomadic 

people of what appeared to be a primitive culture. This left a lasting impression, that only now 

is beginning to break down. More recent evidence suggests that what they found was probably 

the reaction to the debilitating effects of the diseases that had advanced ahead of them years 

before--the remnants of formerly stronger cultures, by then well along in the process of 

decimation. The more familiar history of the period from then through the end of the 19th 

century--tribes ravaged by wars and forced relocations along with the unabated effects of 

disease--simply perpetuated a long-standing demographic trend. 

Figure 2.1 shows how the AlAN population total has changed since its low point in 1900, 

as measured by the U.S. Census. As noted, these are the totals of individuals who identify their 

race as American Indian, Aleut, or Eskimo in the Census Bureau's decennial surveys.17 

Changes through the mid-point of this century were not dramatic. After 1950, however, 

the AlAN population has exhibited a remarkable resurgence, growing from 357,000 to about 2 

million in 1990, almost a sixfold increase in just 40 years. While the AlAN population remains 

small in comparison to the major ethnic groups in America (0.08 percent of the total U.S. 

population in 1990), it is one of the fastest growing. Its total 1980-90 percentage increase (32 

percent) by far exceeded that for non-Hispanic whites (4 percent), and African-Americans (13 

percent) although it did remain below that for Hispanics (53 percent) and Asians (108 percent)-­

(Frey, 1993). 

The phenomenal increase in the AlAN population since 1950 has occurred mostly for the 

same reasons many disadvantaged populations throughout the world accelerated over the same 

period: the development and dissemination of medical innovations that substantially reduced 

fatalities in all age groups (infant mortality in particular), coupled with important environmental 

improvements (better housing, water supply, and sanitation). However, as pointed out in Chapter 

1, there is another cause: the increase in self-identification. 

Passel has analyzed this phenomenon for every Census since 1960 (Passel, 1976 and 

1992, and Passel and Berman, 1986). In each case, he found the total reported end-of-decade 

AlAN populations to be significantly larger than the sum of the comparable populations at the 

beginning of the decade and the growth that occurred during the decade due to natural population 

increase (the excess of births over deaths). For example, the 1980 population (1,420,000) plus 

the 1980s natural increase (350,000) yields a total of 1,770,000; 189,000 short of the reported 

1990 total. Such differences can hardly be caused by immigration of American Indians and 

Alaska Natives from outside of the U.S.--the change in self-identification is the only reasonable 

explanation for most of them. Passel states that similar "errors of closure" have accounted for 

17See discussion of the implications of this measure in Chapter 1. 
Assessment of American Indian Housing Needs and Programs: Final Report 27 

AlAN Population (In thousands) 

2,500 

1,959 2,000 

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _1 L4?O_ _ 1,500 

............................................................ '827 ....
 1,000 

500 - - - - - - - - - - - - - - - - - - -332" - - -3~ -343 -­

248 237 257 244 

o 

1890 1900 1910 1920 1930 1940 1950 1960 1970 1980 1990 

Census 

FIGURE 2.1 American Indian and Alaska Native Populatlon,-1890-1990 

32 percent of the 1,407,000 net growth in the AlAN population that has occurred since 1960. 

Passel's analysis of natural increase and reported totals at this level leads him to conclude 

that this phenomenon has been more important in some parts of the country than others. 

Generally, it does not appear to have much effect in states that have traditionally had the largest 

concentration of Indians in Tribal Areas--it has occurred more frequently in the more urbanized 

states (including California and those below the Great Lakes, and most along the East Coast). 

Again as noted in Chapter 1, the authors do not believe that this phenomenon has great 

significance for the purposes of this study. In and around Tribal Areas, it appears to have a small 

impact, and even where it is more pronounced, it should not have much policy significance. It 

is difficult to imagine any incentives that would cause many blacks, whites, and people of other 

races to falsely report their race in this way. In fact, Passels and Berman (1986) suggest that a 

dominant share of those who made this change do have Indian ancestry; i.e., this phenomenon 

has been caused primarily by people recognizing a true Indian heritage after failing to report it 

in the past. 
Assessment of American Indian Housing Needs and Programs: Final Report 28 

THE GEOGRAPHY OF INDIAN COUNTRY 

Introduction 

Beyond giving a reliable characterization of AlAN housing problems and needs nationally, 

a strong part of the motivation for this study was to learn how such conditions vary in different 

types of locations. This section defines the structure that has been used to differentiate U.S. 

geography for this analysis. Divisions were based on factors that earlier literature, and expert 

advice, indicated were likely to be associated with important differences in the social and 

economic well-being of AlAN populations as well as their housing conditions and other 

circumstances of their living environments. 

Region 

Regional differences were the first considered. There is a sizeable literature showing how 

the characteristics of different regions (flora, fauna, climate, land forms and general location in 

relation to the unfolding pattern non-Indian settlement) historically influenced the evolution of 

different tribal cultures throughout America. Contrasts appear in lifestyles, approaches to 

economic activity, and modes of governance, as well as in types of housing (see, for example, 

Driver and Massey, 1937). It was judged that the nine regional divisions defined in Chapter 1 

would capture the most important of these variations (Figure 1.2). 

Area Types 

Within regions, probably the most important differentiation for Indians is whether they live 

within or outside of Tribal Areas. As noted, Tribal Area is the generic term used in this report for 

American Indian Reservations, Alaska Native Villages, and other special types of areas that 

represent ongoing centers of tribal culture (to be defined in more detail below). 

Outside of Tribal Areas, the most obviously contrasting types of living environments are 

metropolitan and nonmetropolitan. Although comparatively little research has been conducted 

on the topic to date, there has been substantial interest in how well AlAN households adapt to 

life in America's high-density cities and their surrounding metropolitan suburbs. Are they, in fact, 

easily "assimilating" or do urban environments perpetually clash with their cultural heritage to the 

extent that their personal goals for advancement remain frustrated? And how do their 

circumstances differ from AlAN households that live in rural environments, but also outside of 

Tribal Areas? 
Assessment of American Indian Housing Needs and Programs: Final Report 29 

This study's Advisory Panel, however, suggested that another division might be equally 

important: that between those living outside, but close to, Tribal Areas and those living in areas 

(rural or urban) farther removed. Their argument was that a large number of American Indians 

are forced to live outside of their reservations because of the lack of employment and housing 

opportunities, but retain strong ties to the tribal culture and remain near enough to return on a 

routine basis. This is a group, they argued, that has never before been counted, let alone 

analyzed, and its members are likely to have dHferent problems and needs than those living much 

farther away. 

Defining this group in a uniform manner proved a difficult assignment. The question of 

what is "near enough to retain close ties" may have a different answer in Arizona (where, for 

example, Navajos are used to driving hundreds of miles in a day to conduct their affairs) than it 

might be in Connecticut or Maine. The best compromise that could be implemented with the 

resources available for this study, was to use county boundaries; i.e., to identity all counties in 

which Tribal Areas were located and, within those counties, to assemble data separately for those 

that lived inside the Tribal Areas and those that lived outside. 

Accordingly, our spatial analysis examines conditions and trends in four distinct types of 

areas: 

• Counties containing Tribal Areas, subdivided into 

1. Tribal Areas, and 

2. SUffoundingCounffes, and 

• The rest of the United States, subdivided into 

3. Metropolitan Areas, and 

4. Nonmetropolitan Areas 

Types of Tribal Areas 

Chapter 1 explained that the 1990 Census provides data on a total of 508 inhabited Tribal 

Areas in the United States. Their locations, within our study regions, are mapped in Figure 2.2. 

They are listed individually, by region, in Annex A at the end of this report. All have much in 

common as the cultural homelands for their peoples, but there are important differences between 

six basic types as noted below (for more complete definitions, see Bureau of the Census, 1993). 

Many of the differences relate to the manner in which land is held in Tribal Areas as explained 

at the end of Chapter 1 . 
30 

. ... 

. >-­ • 

, ~\•• I

-

Assessment of American Indian Housing Needs and Programs: Final Report 

;::. ...... .:. 

• • • • • • •• • • 

• 

.... • •

• ......... 
 ~ ...... • i"~:J ...."" 

.-.~ ­ -....J U!~.!

.. .J.~ f} 

.~"IJ .~~~ 

j

. .. .. . ....... . '.. ....... . ., . : 

c..

. ; . . 

• • 

• • 

• • • • • • 

.............. •• ; 

• 

..............•....

· ;,....--r-, .: • 

·:1..,

· . .-: • · 

FIGURE 2.2 Locations of American Indian and Alaska Native Tribal A....s 
Assessment of American Indian Housing Needs and Programs: Final Report 31 

Federally Recognized American Indian Reservations. These, the most well known type 

of Tribal Areas, have boundaries established by Federal treaty, statute, and/or executive order 

and are recognized by the Federal government as territory over which an American Indian tribe 

has jurisdiction. Tribes so recognized deal with the Federal government in a sovereign-tosovereign relationship and their reservations are generally not under the jurisdiction of the States 

in which they are located, nor of any local government. Normally, a large share of the land in 

these reservations is held in trust by the BIA and some of them have identified trust lands outside 

of the reservation boundaries (data for AlAN populations on any such lands are included with 

those of their associated reservation in our statistics). One group of areas in this category is an 

exception in this regard: The New Mexico Pueblos. All Pueblo land is owned by the tribal 

government. Areas composed of reservation lands administered jointly and lor claimed by two 

reservations are called "joint areas" by the Census and are identified as separate Tribal Areas 

in our data. 

State Recognized American Indian Reservations. These are reservations established 

under the laws of an individual State and, in many cases, the State (not the Federal government) 

holds the land in trust for the use and benefit of the tribe. 

California Rancherias. These are really a type of Federal reservation, but they deserve 

special mention because of a unique history. Originally, the Rancherias were tracts of land 

acquired by the Federal government in the early 1900s for California Indians, many of whom were 

homeless or in extreme poverty. Most lands were put in trust for a particular band in a specific 

area. As mentioned in Chapter 1, the Rancherias were most affected by the termination policies 

of the 1950s. The Federal government terminated the Rancherias and distributed the land to 

individual Indians who were residing there at the time, or to "associations" that held community 

land as shareholders. In 1969, California Indian Legal Services started suing the government to 

restore the tribes. Out of 41 terminations, 29 have been reversed. The intent was restore the 

Rancherias, but much of their original land bases no longer existed in Indian ownership. 

Rancherias as now defined for Census purposes, are lands that were held by individual Indians, 

associations, or others who have put their land back in trust. Important for our purposes is that 

the traditional tribal areas are typically larger than areas now held in trust, but only the latter are 

recognized in Census data. 

Alaska Native Villages. Again as explained in Chapter 1, Alaska Natives (Indians, 

Eskimos and Aleuts) hold their land under the unique system imposed by the Alaska Native 

Claims Settlement Act of 1972 (ANSCA) and its technical amendments. Village and regional 

corporations (in which enrolled natives own corporate stock) own the land and protect against 

alienation through corporate bylaws. The Bureau of the Census worked with each such 

corporation to define "statistical areas" for its 1990 enumeration that approximated the "settled 

area" of each village. 
Assessment of American Indian Housing Needs and Programs: Final Report 32 

Tribal Jurisdictional Statistical Areas (TJSA). These areas exist only in the State of 

Oklahoma. They are recognized geographic areas over which Federally recognized tribes have 

jurisdiction but in which most the land is not held in trust for the benefit of the tribe as a whole. 

The land within their boundaries includes substantial amounts of privately land (owned by nonIndians and Indians) along with allotments of individual trust land to Indians as defined in Chapter 

1. 

Tribal Designated Statistical Areas (TDSA). These, located outside of Oklahoma, are 

generally similar to the T JSAs: they are areas containing an American Indian population over 

which Federally-recognized tribes have some jurisdiction, or where State tribes provide benefits 

and services to their members. But, unlike reservations: (1) many different people and 

corporations (including many non-Indians) own land within them; and (2) they fall under the 

jurisdiction of the normal system of State and local government. For Census purposes, TDSAs 

are normally delineated by the tribes themselves. 

Numbers of Areas and Populations. Table 2.1 shows the number of Tribal Areas, and 

population totals, for each type within each study region. Almost half (236 or 46 percent) are 

reservations. They had an average population of 1,838 in 1990, but if the Navajo reservation 

(population of 143,700) is excluded, the population of the remaining 235 averaged 1,234. The 

second largest group in number are the Alaska Native Villages (198) whose average population 

is small (239). The California Rancherias (40 in total) have an even smaller average population 

(102). There are many fewer T JSAs and TDSAs (17 each) but their average populations are by 

far the largest among these types: 11,782 and 3,202 respectively. 

Regionally, Alaska has the largest number of Areas (199), followed by California-Nevada 

(98), although in both, Area populations are typically quite small. The largest populations are 

found in Arizona-New Mexico and Oklahoma (235,500 and 206,400 respectively--together 

accounting for 60 percent of the 739,800 total AlAN population residing in Tribal Areas. 

THE SPA TIAL PA TTERN OF THE AlAN POPULA TlON 
 

AND ITS RECENT GROWTH 
 

The Current Pattern 

As discussed in Chapter 1, the story of American Indians from colonial times through the 

19th century is largely one of being pressured ever westward as Europeans settled the coast and 

began to move farther and farther inland. A devastating event in this sequence was the 1930 

Indian Removal Act, and subsequent government actions reinforced this trend. Westward 
Assessment of American Indian Housing Needs and Programs: Final Report 33 

Tabla 2.1 

AlAN TRIBAL AREAS AND POPULATION, 1990 

Reg. 1 Reg. 2 Reg. 3 Reg. 4 Reg. 5 Reg. 6 Reg. 7 Reg. 8 Reg. 9 

Total North South- Ariz.­ Calif.- Pacif. 

U.S. Central Eastern Ok/a. Central Plains N.Mex. Nev. No.West Alaska 

NO. OF AREAS 

Reservation 236 33 28 1 8 28 44 58 35 1 

Rancheria 40 0 0 0 0 0 0 40 0 0 

TJSA 17 0 0 17 0 0 0 0 0 0 

TOSA 17 0 10 0 5 0 0 0 2 0 

Alaska Nat.Vil. 198 0 0 0 0 0 0 0 0 198 

Total 508 33 38 18 13 28 44 98 37 199 

1990 POPULAnON (000) 

Reservation 433.7 27.7 19.7 6.1 1.8 93.9 235.5 16.0 31.8 1.2 

Rancheria 4.1 0.0 0.0 0.0 0.0 0.0 0.0 4.1 0.0 0.0 

TJSA 200.3 0.0 0.0 200.3 0.0 0.0 0.0 0.0 0.0 0.0 

TOSA 54.4 0.0 35.1 0.0 11.2 0.0 0.0 0.0 8.1 0.0 

Alaska Nat.Vil. 47.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 47.3 

Total 739.8 27.7 54.8 206.4 13.1 93.9 235.5 20.1 39.9 48.5 

POPULATION PER AREA 

Reservation 1,838 840 703 6,100 230 3,355 5,351 275 908 1,206 

Rancheria 102 0 0 0 0 0 0 102 0 0 

TJSA 11,782 0 0 11,782 0 0 0 0 0 0 

TOSA 3,202 0 3,509 0 2,248 0 0 0 4,047 0 

Alaska Nat.Vil. 239 0 0 0 0 0 0 0 0 239 

Total 1,456 840 1,442 11,466 1,006 3,355 5,351 205 1,077 244 

movement continued, albeit more gradually, over the next 100 years, but picked up after that as 

Indians joined non·lndians in migrations to California. Also as noted in Chapter 1, migration was 

expanded in the 1950s and 1960s by the Bureau of Indian Affairs (BIA) Direct Employment 

(Relocation) Program which moved thousands of Indians from the reservations to urban areas 

The results of this heritage are evident in the regional distribution of the AlAN population 

in 1990 as shown in Table 2.2.18 The Eastern region as we have defined it is quite large and 

it still accounts for the largest share, 21 percent of the total. The next largest concentrations are 

in Arizona·New Mexico (17 percent), and California·Nevada and Oklahoma (13 percent each). 

1srhe data base for this table (and most of the remaining analysis in this report) differs from the population total 

shown in Figure 2.1 in that it relies on Census sample estimates rather than full-count data (this makes only a modest 

difference: the sample has the national AlAN population at 2.01 million compared to the full count total of 1.96 million). 
Assessment of American 34 Indian Housing Needs and Programs: Final Report 

Table 2.2 

AlAN POPULATION, 1990, BY PLACE OF RESIDENCE 

Reg. 1 Reg. 2 Reg. 3 Reg. 4 Reg. 5 Reg. 6 Reg. 7 Reg. 8 Reg. 9 

Total North- South- Ariz.­ Calif.- Pacif. 

U.S. Central Eastern Okla. Central Plains N.Mex. Nev. NoWest Alaska 

POPULATION, 1990 (000) 

Tribal Areas 

Metro. Counties 137.0 3.3 4.6 73.4 9.5 0.1 22.0 7.4 16.6 0.0 

Non-metro.Counties 602.8 24.4 50.1 132.9 3.9 95.3 211.7 12.6 23.3 48.5 

Subtotal 739.8 27.7 54.8 206.4 13.4 95.4 233.8 20.0 39.9 48.5 

Surrounding Counties 

Metro. Counties 277.1 9.2 28.0 33.1 2.6 5.0 55.0 82.7 46.8 14.9 

Non-metro.Counties 184.5 20.8 26.2 10.4 1.8 23.5 48.6 23.9 17.2 12.2 

Subtotal 461.5 30.0 54.2 43.5 4.4 28.5 103.5 106.6 63.9 27.0 

Total AlAN Counties 1,201.3 57.7 109.0 249.9 17.8 123.8 337.3 126.5 103.8 75.5 

Rest of Region 

Metro. Counties 

Central Cities 286.5 36.3 104.5 1.0 47.6 30.0 0.5 55.0 11.7 0.0 

Suburbs 331.1 34.8 138.3 0.2 46.6 19.2 0.6 82.7 8.7 0.0 

Subtotal 617.6 71.1 242.8 1.2 94.2 49.1 1.1 137.7 20.4 0.0 

Non-metro.Counties 190.6 18.8 73.6 1.4 39.3 22.5 3.7 5.6 15.2 10.6 

Subtotal 808.2 89.9 316.3 2.6 133.5 71.6 4.9 143.3 35.5 10.6 

Total 2,009.5 147.6 425.3 252.5 151.3 195.5 342.1 269.8 139.3 86.1 

PERCENT OF POPULATION, 1990 

Tribal Areas 

Metro. Counties 6.8 2.2 1.1 29.1 6.3 0.1 6.4 2.7 11.9 0.0 

Non-metro.Counties 30.0 16.6 11.8 52.7 2.6 48.7 61.9 4.7 16.7 56.3 

Subtotal 36.8 18.8 12.9 81.7 8.9 48.8 68.3 7.4 28.6 56.3 

Surrounding Counties 

Metro. Counties 13.8 6.2 6.6 13.1 1.7 2.5 16.1 30.6 33.6 17.3 

Non-metro.Counties 9.2 14.1 6.2 4.1 1.2 12.0 14.2 8.9 12.3 14.1 

Subtotal 23.0 20.3 12.7 17.2 2.9 14.6 30.3 39.5 45.9 31.4 

Total AlAN Counties 59.8 39.1 25.6 99.0 11.8 63.3 98.6 46.9 74.5 87.7 

Rest of Region 

Metro. Counties 

Central Cities 14.3 24.6 24.6 0.4 31.4 15.3 0.1 20.4 8.4 0.0 

Suburbs 16.5 23.6 32.5 0.1 30.8 9.8 0.2 30.7 6.2 0.0 

Subtotal 30.7 48.2 57.1 0.5 62.2 25.1 0.3 51.0 14.6 0.0 

Non-metro.Counties 9.5 12.7 17.3 0.5 26.0 11.5 1.1 2.1 10.9 12.3 

Subtotal 40.2 60.9 74.4 1.0 88.2 36.7 1.4 53.1 25.5 12.3 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 
Assessment of American Indian Housing Needs and Programs: Final Report 35 

It is important to note how the regional data on this table have been constructed. State 

boundaries actually cut across Tribal Area boundaries in a number of cases. The most striking 

example is the extensive Navajo reservation (14.8 million acres, about three times the size of 

New Jersey) which is centered in Arizona, but extends into New Mexico, Utah, and Colorado as 

well. 19 In Table 2.2 (and all others presenting regional data in this report), we have kept Tribal 

Areas in tact and, where they cross state lines, assigned them as a whole to the region in which 

the largest share of their population resides. 

Probably the most important new finding of the area-type analysis is the importance of the 

Surrounding Counties in AlAN demographics. Nationally, a total of 453 counties incorporate all 

or parts of Census designated Tribal Areas--14 percent of the 3,131 counties that exist in the 

United States. Their locations are shown in Figure 2.3. Their land areas cover virtually all of the 

states of Oklahoma, Alaska, and Arizona. Geographically, these counties also dominate 

California, Nevada, Washington, and Oregon, and make up extensive portions of all states along 

the Canadian border west of the Great Lakes. 

Narratives concerning Indian issues often seem to assume that American Indians either 

still live on the reservations or they have migrated to the cities. The data on Table 2.2 show that 

this is a quite inaccurate view. In 1990, 37 percent of the AlAN population nationally (739,800) 

lived in Tribal Areas but another 23 percent (461,500) lived in the Surrounding Counties. And, 

while these counties do contain some cities of note, they are not predominantly urban (counties 

among them that are classified as parts of Metropolitan Statistical Areas account for just one third 

of their total population). These AlAN Counties then (Tribal Areas plus the Surrounding Counties 

as we have defined them) account for 60 percent of the national AlAN population, compared to 

just 31 percent for metropolitan areas elsewhere and only 10 percent in the multitude of other 

non metropolitan counties around the United States. 

These shares do differ in important ways in different regions. The AlAN counties account 

for almost all of the AlAN populations in the Oklahoma, Arizona-New Mexico, and Alaska regions, 

but they account for only 12 percent in the South Central region, and 25 percent in the Eastern 

region. 

Figure 2.4 highlights the regional contrast that exists between the spatial distribution of 

American Indians and Alaska Natives that live in AlAN counties and those living in metropolitan 

and nonmetropolitan areas elsewhere. Those outside of AlAN counties are predominantly 

19Navajo is by far the largest reservation. The next seven ranked by size are: Tohono O'Odham, AZ (2.8 million 

acres). Wind River. WY (1.9 million). San Carlos. AZ (1.8 million). Pine Ridge. SO (1.8 million). Fort Apache. AZ (1.7 

million). Hopi. AZ (1.6 million). and Crow. MT (1.5 million). All of these are larger than the state of Delaware (1.3 

million). 
Assessment of American Indian Housing Needs and. Programs: Final Report 36 

';;. 

.co _fJp­ _..r~.: .. .-..' 

.: :::~ .....J~@~L ..·.;.·.:.'4::...:~....... :1 •••:•.' ••• _; ...;_~:'::;.;.:':':":;':"_::::~_':~.:.~ ..:'::....... :.:.: '~.••:.:•.': :::.·.:·:i:.·.;..:l.::.:.·.:~.'.::.:!: :;.:F.:·.:.·.: .. ..:::':':: :.:::: .. ..: .:::::H:.; r-----;" ":i~iim; ~~--~--~~~ ;111W= :.::-::•... __ ...•...•• 

~-l;:"'--' 

FIGURE 2.3 U.S. Counties with Tribal Areas Inside Their Boundaries 
Assessment of American Indian Housing Needs and Programs: Final Report 37 

40 

30 28 

10 

o 

1 No 2 East 30kla 4So 5 6 Ariz 7 Cal­ 8 Pac 9 

Cent Cent Plains N.M. Nev No Alaska 

Population Living In AlAN Counties 

39 

40 

30 

-

c • 18 20 17

Q. 

~ 

10 

0.3 


0 


1 No 2 East 30kla 4So 5 6 Ariz 7 Cal- 8 Pac 9 

Cent Cent Plains N.M. Nev No Alaska 

Population Living Outside of AlAN Counties 

FIGURE 2.4 Regional Distribution of AlAN Populations Living Inside and Out of AlAN 

Counties, 1990 
Assessment of American Indian Housing Needs and Programs: Final Report 38 

IIcoastalll ; three quarters of them live in just three regions (the East, California-Nevada, and South 

Central). Only 22 percent of the those in AlAN counties, however, live in those regions. Indian 

populations in AlAN counties reside predominantly in the nation's mid-section. 

Patterns of Growth and Decline, 1980-1990 

Rates of population change during the 1980s are shown in Table 2.3. Among area types, 

the highest annual AlAN growth rates were experienced by AlAN Counties (3.8 percent) and 

metropolitan central cities outside of those counties (3.6 percent). AlAN populations in the 

suburbs of those metropolitan areas grew much more slowly (1.0 percent) and those in other 

non metropolitan areas actually declined (-0.6 percent per year).20 The average AlAN growth 

rate nationally was 2.8 percent. Overall comparative changes by region show the fastest growth 

in the Eastern, Oklahoma, and South Central regions, the slowest in the Plains and CaliforniaNevada. 

It is true that a number of the AlAN Counties in 1990 were within metropolitan areas, but 

their populations were dominantly nonmetropolitan (66 percent), and their 1980-90 growth was 

also dominantly nonmetropolitan to about the same extent (63 percent). 

The largest contributions to AlAN County growth were made by the Oklahoma (80,700), 

Arizona-New Mexico (79,600), and Eastern (69,900) regions. Among areas outside of those 

counties, the metropolitan areas of the Eastern region made by far the largest contribution 

(together increasing by 75,700), the next closest being the 19,000 addition in South Central 

metropOlises. In two regions (California-Nevada and the Pacific Northwest) AlAN populations 

outside of the AlAN counties actually declined (together experiencing a net loss of 13,200, 

92 percent of which came from suburban areas in the California-Nevada region). 

Table 2.3 does not show changes in raw counts for Tribal Areas and Surrounding Counties 

within the AlAN County totals because, in relation to future expectations, doing so would have 

indicated misleadingly large rates of increase in the Tribal Area components for some regions. 

This is because of changes in classification between the 1980 and 1990 Censuses. As noted 

earlier, the Census Bureau made a special effort to more comprehensively identify Tribal areas 

for the 1990 survey. Some 1990 Tribal Areas that also existed in 1980 were not then recognized 

as such, being simply counted in with the Surrounding County totals at that time. In some regions 

this has no effect (no change between 1980 and 1990 classifications), but for a few it has a 

sizeable impact. 

2°ln the data base for this study, Metropolitan Area definitions applicable at the time of the 1990 Census were 

applied to both 1980 and 1990 data. In other words, the changes shown are those for a constantly defined set of areas 

and are not influenced by any changes in classification. 
Assessment of American Indian Housing Needs and Programs: Final Report 39 

Table 2.3 
 

AlAN POPULATION CHANGE 1980-90, BY PLACE OF RESIDENCE 
 

Type of Area Reg. 1 Reg. 2 Reg. 3 Reg. 4 Reg. 5 Reg. 6 Reg. 7 Reg. 8 Reg. 9 

Total North- South- Ariz.- Calif.- Pacif. 

U.S. Central Eastern Okla. Central Plains N.Mex. Nev. No.West Alaska 

ANNUAL PERCENT CHANGE, 1980-90 

AlAN Counties 

Metro. Counties 4.2 4.7 4.2 4.3 20.9 1.5 4.0 2.9 4.3 5.2 

Non-metro.Counties 3.6 3.9 16.0 3.7 8.2 2.4 2.4 2.2 4.8 2.7 

Total 3.8 4.0 10.8 4.0 14.9 2.4 2.7 2.7 4.5 3.2 

Rest of Region 

Metro. Counties 

Central Cities 3.6 2.4 5.0 5.5 3.9 6.0 3.6 1.0 3.4 NA 

Suburbs 1.0 2.2 3.0 1.2 0.9 0.4 4.0 -1.4 -3.2 NA 

Subtotal 2.1 2.3 3.8 4.6 2.3 3.4 3.8 -0.5 0.0 NA 

Non-metro.Counties -0.6 2.0 -2.3 1.1 2.4 0.3 1.1 -5.5 -1.3 1.6 

Subtotal 1.4 2.3 2.0 2.6 2.3 2.3 1.6 -0.7 -0.6 1.6 

Total 2.8 2.9 3.6 4.0 3.2 2.3 2.7 0.7 2.9 3.0 

ABSOLUTE CHANGE, 1980-90 (000) 

AlAN Counties 

Metro. Counties 138.5 4.6 10.9 36.8 10.3 0.7 24.8 22.5 22.0 5.9 

Non-metro.Counties 236.5 14.3 59.0 43.8 3.1 25.0 54.7 7.1 15.1 14.3 

Total 375.0 18.9 69.9 80.7 13.4 25.7 79.6 29.6 37.1 20.2 

Rest of Region 

Metro. Counties 

Central Cities 85.6 7.7 40.6 0.4 15.0 13.2 0.2 5.2 3.4 0.0 

Suburbs 31.4 6.9 35.0 0.0 4.0 0.7 0.2 (12.1) (3:4) 0.0 

Subtotal 117.1 14.7 75.7 0.4 19.0 13.9 0.3 (7.0) 0.0 0.0 

Non-metro.Counties (11.0) 3.4 (18.8) 0.1 8.2 0.6 0.4 (4.2) (2.1) 1.6 

Subtotal 106.1 18.0 56.9 0.6 27.2 14.4 0.7 (11.1) (2.1) 1.6 

Total 481.1 36.9 126.8 81.2 40.6 40.2 80.3 18.5 34.9 21.8 

We have made adjustments to offer rough estimates of the population change for Tribal 

Areas assuming consistent 1990 definitions, as shown in Table 2.4 (the method for doing this is 

defined in Kingsley, Mikelsons, and Herbig, 1995). Nationally, the results indicate a higher annual 

AlAN growth rate for the Surrounding Counties (4.6 percent) than the Tribal Areas (3.4 percent); 

this same relationship (faster growth in the Surrounding Counties than in Tribal Areas) also 

occurred in most regions. 
Assessment of American Indian Housing Needs and Programs: Final Report 40 

Table 2.4 

AlAN POPULATION GROWTH, 1980-90, BY PLACE OF RESIDENCE - ADJUSTED 

Reg. 1 Reg. 2 Reg. 3 Reg. 4 Reg. 5 Reg. 6 Reg. 7 Reg. 8 Reg. 9 

Total North- South- Ariz.­ Calif.- Pacif. 

U.S. Central Eastern Okla. Central Plains N.Mex. Nev. No.West Alaska 

ADJUSTMENTS FOR CLASSIFICATION OF NEW TRIBAL AREAS 

Tribal Area 1980 AlAN Population (000) 

Tribal Areas-1980 def. 519.6 21.4 18.7 121.1 2.0 81.5 195.7 15.6 24.4 39.3 

Tribal Area 1990 AlAN Population (000) 

Tribal Areas-1980 def. 681.4 27.3 19.6 206.4 2.0 95.4 233.8 18.6 31.6 46.7 

New areas 58.4 0.4 35.1 0.0 11.4 0.0 0.0 1.4 8.2 1.8 

Total-1990 def. 739.8 27.7 54.8 206.4 13.4 95.4 233.8 20.0 39.9 48.5 

Tribal Areas AlAN Population Growth Rate ('%JYR.) 

Tribal Areas-1980 def. 2.7 2.5 0.5 5.5 0.1 1.6 1.8 1.8 2.6 1.8 

Total 3.6 2.6 11.4 5.5 21.1 1.6 1.8 2.5 5.0 2.1 

ADJUSTED POPULATION ESTIMATES, 1980-1990 

1980 Population 

Tribal Areas-1990 def. 531.2 21.6 19.6 121.1 3.3 81.5 195.7 16.7 30.8 40.8 

Surrounding Counties 295.0 17.2 19.4 48.1 1.1 16.6 62.0 80.2 35.9 14.6 

Subtotal 826.3 38.8 39.1 169.2 4.4 98.1 257.7 96.9 66.7 55.3 

Other Metropolnan 500.5 56.4 167.1 0.8 75.2 35.3 0.8 144.6 20.4 0.0 

Other Nonrnetro. 201.6 15.4 92.4 1.2 31.2 21.9 3.4 9.8 17.3 9.0 

Total 1,528.4 110.7 298.5 171.2 110.8 155.3 261.8 251.3 104.4 64.4 

1990 Population 

Tribal Areas-1990 def. 739.8 27.7 54.8 206.4 13.4 95.4 233.8 20.0 39.9 48.5 

Surrounding Counties 461.5 30.0 54.2 43.5 4.4 28.5 103.5 106.6 63.9 27.0 

Subtotal 1,201.3 57.7 109.0 249.9 17.8 123.8 337.3 126.5 103.8 75.5 

Other Metropolnan 617.6 71.1 242.8 1.2 94.2 49.1 1.1 137.7 20.4 0.0 

Other Nonrnetro. 190.6 18.8 73.6 1.4 39.3 22.5 3.7 5.6 15.2 10.6 

Total 2,009.5 147.6 425.3 252.5 151.3 195.5 342.1 269.8 139.3 86.1 

1980-90 Growth Rate (%/yr.) 

Tribal Areas-1990 def. 3.4 2.5 10.8 5.5 14.9 1.6 1.8 1.8 2.6 1.8 

Surrounding Counties 4.6 5.7 10.8 -1.0 14.9 5.5 5.3 2.9 5.9 6.4 

Subtotal 3.8 4.0 10.8 4.0 14.9 2.4 2.7 2.7 4.5 3.2 

Other Metropolnan 2.1 2.3 3.8 4.6 2.3 3.4 3.8 -0.5 0.0 NA 

Other Nonmetro. -0.6 2.0 -2.3 1.1 2.4 0.3 1.1 -5.5 -1.3 1.6 

Total 2.8 2.9 3.6 4.0 3.2 2.3 2.7 0.7 2.9 3.0 

Share (%) of National Net Increas. 

Tribal Areas-1990 def. 43.3 1.3 7.3 17.7 2.1 2.9 7.9 0.7 1.9 1.6 

Surrounding Counties 

Subtotal 

34.6 

n.9 

2.7 

3.9 

7.2 

14.5 

-1.0 

16.8 

0.7 

2.8 

2.5 

5.3 

8.6 

16.5 

5.5 

6.2 

5.8 

7.7 

2.6 

4.2 

Other Metropolnan 24.3 3.0 15.7 0.1 4.0 2.9 0.1 -1.4 0.0 0.0 

Other Nonrnetro. -2.3 0.7 -3.9 0.0 1.7 0.1 0.1 -0.9 -0.4 0.3 

Total 100.0 7.7 26.3 16.9 8.4 8.3 16.7 3.8 7.3 4.5 
Assessment of American Indian Housing Needs and Programs: Final Report 41 

In summary, our most important finding is that, in contrast to much of the conventional 

wisdom of the past, the AlAN population is heavily concentrated in and around Tribal Areas and 

that the extent of that concentration is increasing: Tribal Areas and their Surrounding Counties 

contained only 16 percent of the total U.S. population in 1990, but they accounted for 60 percent 

of the national AlAN population and they had captured 78 percent of the growth in that population 

since 1980. 

Figure 2.5 shows the trends in more detail: Tribal Areas accounted for 37 percent of the 

1990 AlAN population and 43 percent of its 1980-90 growth; the Surrounding Counties accounted 

for only 23 percent of the 1990 total, but for 35 percent of its growth. The share of the AlAN 

population in the rest of the United States was declining: metropolitan areas elsewhere accounted 

for 31 percent of the population but only 24 percent of the growth; other nonmetropolitan areas 

accounted for only 10 percent of the total and had suffered absolute AlAN population losses equal 

to 2 percent of the national net increase. 

Migration and Implications for the Future 

An important question for housing policy is whether these geographical trends are likely 

to continue. Further analysis to begin to answer this question might look the at trends in the 

components of population change in each of these types of areas (how much of the change was 

caused by natural increase and how much by migration?) and then consider how the factors 

influencing each of the components are likely to be altered. Unfortunately, full data on in- and 

out-migration for small areas (e.g., Tribal Areas and their surrounding counties) are not available, 

but cruder indicators can be examined as the basis for at least somewhat more informed 

speculation. 

Using 1980 Census data, Snipp (1989) showed that the AlAN population is more mobile 

than average. In 1980, the share of all households that had moved from a different house over 

the preceding five years was 46 percent for whites and 43 percent for blacks, but 53 percent for 

Indians. Table 2.5 shows that the comparable share for the AlAN population in 1990 was just 

slightly lower (51 percent), but they still remained more mobile than non-Indians on average (46 

percent). Of the AlAN population, 30 percent had moved from a different house in the same 

county, and the remaining 21 percent had moved from another county (both shares were higher 

than the comparable ones for non-Indians). 

The Table also shows, however, that there were notable differences in these rates among 

AlAN households, depending on where they were located in 1990. Most pronounced is that the 

share of all Tribal Area residents who had moved into their 1990 house over the past five years 

(37) was much lower than for AlAN populations living in other parts of the country: for example, 

59 percent in other metropolitan areas. 
Assessment of American Indian Housing Needs and Programs: Final Report 42 

-2 

Tribal Areas Surrounding 

Counties 

50 II % of 1990 Population 43 • % of 1980-90 Growth 

40 

30 

i 

~ 20 

D. 

10 

0 

-10 

Other Metro Other NonMetro 

FIGURE 2.5 	 Area Type Shares of U.S. AlAN Population, 1990 and Net Population Increase, 

1980-1990 

Tribal Areas also stand out in that a considerably smaller share had moved into them from 

another county: 12 percent, compared to shares in the 26-27 percent range in other areas. Their 

share of all households having moved in from a different house in the same county (25 percent) 

was fairly close to the national average (26 percent) for non-Indians. 

One relevant implication is that the large population growth that occurred in Tribal Areas 

during the 1980s was no doubt predominantly due to natural increase rather than migration; in 

fact, many of the Tribal Areas probably experienced net out-migration over that decade. This is 

suggested by the low shares of households moving in since 1985, coupled with high birth rates 

(see Passel, 1992). 

However, we do not see these figures suggesting enormous flows of migration out of the 

Tribal Areas to distant urban centers or that migration is all a one-way-street. The fact that 12 

percent of all AlAN households living in Tribal Areas in 1990 had moved there from another 

county since 1985 is far from trivial. While we cannot say that cultural ties are strong enough to 

overcome other forces in keeping current residents on the reservations and drawing many others 

back, we cannot say that such ties are without influence. 
Assessment of American Indian Housing Needs and Programs: Final Report 43 

Tlble2.5 

MOBILITY STATUS, 1990 

AlAN POPULATION NON·AIAN POPULATION 

Trbal Surr. Other Other Trbal Surr. Other Other 

Total Areas Co. Metro. Nonmet. Total Areas Co. Metro. Nonmet. 

Pet. by 1990 locltlon compared to 1985 

Same house as 1985 49.1 63.3 39.9 41.5 41.8 54.5 55.4 50.1 54.2 58.8 

DIfferent house 

Same county 29.6 24.8 34.0 33.0 31.4 26.0 25.0 28.1 26.7 22.3 

Different co. 21.3 11.9 26.0 25.5 26.7 19.5 19.6 21.8 19.1 18.9 

Subtotal 50.9 36.7 60.0 58.5 58.2 45.5 44.6 49.9 45.8 41.2 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Intercounty moves as 

pet. In dlff. house 41.8 32.4 43.4 43.6 46.0 42.8 43.9 43.8 41.7 45.9 

The existence of such ties is corroborated by the sample survey of households in our field 

survey sites. Respondents who lived in the Tribal Area were asked to rank various reasons for 

remaining there as to their importance on a scale from 1 to 5: 65 percent gave a "most important" 

rating to "family and friends are all here", but the next highest shares in this category (55 percent) 

were earned by "being an active member of the tribe", "preserving the traditional way of life", and 

"access to health care".21 

When the same respondents were asked to rate reasons for living off the reservation 45 

percent gave a "most important" rating to "better jobs and business opportunities"--only 23 percent 

said "more interesting way of life", and only 22 percent said "more houses or apartments". Of 

those who lived in the same county but outside the reservation, 71 percent said they would 

"prefer to live on the reservation".22 Interviews with Indian community center directors in urban 

21A considerably smaller 37 percent rated access to HUD or BIA housing assistance as a "most important" reason 

for remaining in their Tribal Area. 

22A11 households surveyed responded to these questions. For all percentage estimates given in these paragraphs 

(except the last) 95 percent confidence intervals ranged from 6 to 8 points above and below the reported figures. The 

confidence interval is broader for the last figure (percent of those living off the reservation who would prefer to live on 

the reservation) because out of the 414 total respondents only 118 live off the reservation. The 95 percent interval in 

this case ranges 18 points above and below the reported value. Still, this finding is significant. The range implies that 

at the very least the majority of those living outside would prefer to live in the reservation environment, and the figure 

could be as high as 89 percent. 
Assessment of American Indian Housing Needs and Programs: Final Report 44 

areas suggested that large numbers of urban Indians retain close ties to their tribes, and many 

hope to return to their original Tribal Areas when they retire. 

There are pulls in a number of directions, but in summary, we see no basis for assuming 

that migration flows are likely to substantially alter the spatial trends exhibited in the 1980s one 

way or another. We judge that the safest assumption for housing policy is that the spatial 

patterns of AlAN growth and decline over the coming decade are likely to be similar to those 

evidenced in the 1980s. 

SOCIAL AND ECONOMIC CONDITIONS 

Age Structure and Household Composition 

American Indians and Alaska Natives are considerably younger, on average, than the 

general population. Nationally, 34 percent of the AlAN population are children and teenagers 

(under 18 years) in contrast to only 25 percent for non-Indians (Table 2.6). At the other end of 

the distribution, the contrast is also strong, but runs in the other direction: 15 percent of all nonIndians are elderly (62 years or more) compared to only 8 percent of the AlAN population. 

Differences by area types in this regard, however, are pronounced. With 41 percent under 

18, the AlAN populations in Tribal Areas are considerably more youthful than Indians elsewhere. 

At the other extreme, only 27 percent in metropolitan areas are below 18 years of age: the 

comparable shares for the Surrounding Counties and other Nonmetropolitan areas are not much 

higher than that (31-32 percent). Still, in all types of areas the AlAN under-18 share is higher 

than that for their non-Indian counterparts--the differences just are not as great as for Tribal 

Areas. 

One of the most frequently discussed social concerns in America today is the decline of 

the traditional family. Progressively, over the past several decades, families--all groups of related 

individuals living together, but households headed by married couples in particular--have been 

shrinking as a share of all households in all parts of the country. Perhaps the most important 

conclusion to be derived from the household composition data in Table 2.6 is that this tendency 

has not been as strong among American Indians and Alaska Natives. 

Just over 80 percent of the 812,000 AlAN households nationally are families (compared 

with 72 percent for non-Indians), 61 percent are headed by married couples (vs. 58 percent for 

non-Indians), and households with children make up 52 percent of the total (vs. 36 percent for 

non-Indians). 
Assessment of American Indian Housing Needs and Programs: Final Report 45 

Table 2.6 

AGE AND HOUSEHOLD COMPOSITION, 1990 

AlAN POPULATION NON·AIAN POPULATION 

Tribal Surr. Other Other Tribal Surr. Other Other 

Total Areas Co. Metro. Nonmet. Total Areas Co. Metro. Nonmet. 

Pel of population by age 

Under 18 years 34.2 40.9 31.5 27.0 30.7 25.1 26.5 25.8 24.6 26.0 

18-44 years 44.2 38.7 46.7 50.1 45.8 43.2 40.4 43.0 44.3 39.9 

45-61 years 14.0 12.3 14.6 15.6 15.6 16.3 16.9 15.9 16.3 16.7 

62 years or more 7.6 8.1 7.2 7.3 7.9 15.4 16.3 15.3 14.8 17.5 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Number of households (000) by type 

Elderly 55 19 12 17 7 11,023 194 1,661 6,622 2,546 

Small family 436 114 102 167 53 43,148 690 6,084 28,240 8,133 

Large family 161 63 35 48 15 9,889 141 1,503 6,499 1,746 

Other, Nonfam. 161 39 38 66 17 26,693 402 3,855 17,952 4,484 

Total 812 234 188 298 92 90,754 1,428 13,103 59,313 16,910 

Pel of households by type 

Elderly 6.7 7.9 6.5 5.7 7.7 12.2 13.6 12.7 11.2 15.1 

Small family 53.7 48.5 54.2 56.2 57.5 47.5 48.3 46.4 47.6 48.1 

Large family 19.8 26.7 18.9 16.1 16.2 10.9 9.9 11.5 11.0 10.3 

Other, Nonfam. 19.8 16.8 20.4 22.1 18.7 29.4 28.2 29.4 30.3 26.5 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Pel of households by family relationship 

Family households 

Married w/child. 37.3 38.2 37.2 35.5 41.0 27.8 26.4 26.5 25.6 28.0 

Married no child. 23.4 18.9 23.2 25.8 27.4 29.9 31.9 30.5 28.9 33.0 

Subtotal 60.7 57.1 60.4 61.4 68.4 57.8 58.3 57.1 54.5 61.0 

Female head w/ch. 11.7 15.6 11.7 9.9 8.0 6.3 5.8 5.9 6.7 5.6 

Male head w/ch. 3.2 4.8 3.1 2.2 2.0 1.4 1.3 1.6 1.3 1.3 

Subtotal 14.9 20.3 14.8 12.2 10.0 7.7 7.2 7.5 8.0 6.9 

Other 4.6 5.8 4.4 4.4 3.0 6.7 6.3 6.0 7.2 5.6 

Total 80.2 83.2 79.6 77.9 81.4 72.2 71.8 70.6 69.8 73.5 

Nonfamily households 19.8 16.8 20.4 22.1 18.7 29.4 28.2 29.4 30.2 26.5 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

One sign of distress, however, does stand out for AlAN households: the share made up 

by female headed households with children (12 percent) is double the non-Indian average. This 

AlAN share was lower than the average for blacks in 1990 (21 percent) but substantially above 

the averages for most other racial groups (e.g., 5 percent for whites--U.S. Department of 

Commerce, 1994, Table 49). 
Assessment of American Indian Housing Needs and Programs: Final Report 46 

Another striking characteristic of AlAN household composition stards out from the 

alternative typology shown in Table 2.6--the sizeable number of large families. 23 This typology 

groups households into one of four categories: Elderly (one or two member families with a 

household head and/or spouse 62 years of age or over); Small families (other family households 

with two to four members); Large families (family households with five or more members; and 

Other households (non-family households of all types). 

Twenty percent of all AlAN households nationally are large families, almost twice the 11 

percent large families make up of non-Indian households. The AlAN large family share is highest 

in Tribal Areas (27 percent), second highest in the Surrounding counties (18 percent), and 

averages a uniform 16 percent in other parts of the country. And in each type of area, AlAN 

households by far outpace non-Indians by this measure. 

Contrasts between area types at the national level with regard to household composition 

also generally characterize differences within individual regions. Oklahoma stands out for having 

in most categories (particularly within its Tribal Areas) comparatively low shares of female headed 

households and large families and higher shares of elderly households. This pattern also 

characterizes the Eastern, South-Central, and California-Nevada regions to some extent. The 

opposite--higher than average shares of female headed households and large families and fewer 

elderly--is found in the regions where urban influences are less pronounced: the Plains, and 

Arizona-New Mexico. 

Comparisons with 1980 data show that the ratio of total population to households did 

decline in all categories over the 1980s; by a substantial 8.9 percent (from 4.13 to 3.66) in Tribal 

Areas, but only to a very small extent (from 3.15 to 3.13, or less than one percent) in the rest of 

the country. In other words, while AlAN households are typically larger than non-Indian 

households, they are gradually getting smaller. AlAN households in Tribal Areas are larger on 

average than those living elsewhere, but their size is declining more rapidly. 

Education Status, Labor Force, and Employment 

Education is increasingly recognized as the key to economic advancement in America, and 

on this score the AlAN population lags considerably behind: 34 percent of those over 25 years 

of age never graduated from high school, compared to a non-Indian rate of 25 percent (Table 

2.7). The AlAN share that has graduated from college is less than half that for non-Indians (9 

percent vs. 20 percent). 

23Th is typology has been developed because of it simplicity and its usefulness for housing needs analysis--see 

Bogdon, et ai, 1993. 
Assessment of American Indian Housing Needs and Programs: Final Report 47 

Table 2.7 

EDUCATION AND LABOR FORCE STATUS, 1990 

AlAN POPULATION NON-AlAN POPULATION 

Tribal Surr. Other Other Tribal Surr. Other Other 

Total Areas Co. Metro. Nonmet. Total Areas Co. Metro. Nonmet. 

Pel population over 25 by educational status 

Not H.S. graduate 34.4 42.7 30.0 28.6 35.7 24.7 27.2 22.2 23.3 31.6 

H.S. graduate 56.3 51.4 60.5 58.4 56.2 54.9 56.7 57.3 54.1 55.8 

Bach. degree & above 9.3 5.9 9.5 13.0 8.1 20.4 16.1 20.5 22.7 12.7 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Labor force status 

Total population 

In labor force 63.4 54.9 66.2 70.0 64.5 65.3 61.2 65.2 66.7 60.4 

Not in lab. force 36.6 45.1 33.8 30.0 35.6 34.7 38.8 34.8 33.3 39.6 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Labor force 

Armed forces 1.0 0.3 1.0 1.4 1.2 1.3 1.6 2.0 1.3 1.0 

Employed civilian 84.8 79.7 85.6 88.2 85.8 92.5 91.5 91.8 92.7 92.3 

Unemployed 14.2 20.1 13.4 10.4 13.1 6.2 7.0 6.2 6.1 6.6 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Pet. of employed by occupation 

Profess.lManagerial 18.5 17.4 17.9 20.3 15.7 26.4 23.5 26.5 28.3 19.5 

T ech.lsales/admin. 26.6 24.4 27.3 29.3 21.3 31.7 30.4 31.9 33.3 25.8 

Other 54.9 58.3 54.8 50.4 63.0 42.0 46.1 41.6 38.5 54.8 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Pet. of employed by type of worker 

Private for-prol~ 64.3 52.1 66.0 71.1 68.0 70.8 68.1 69.9 71.7 67.9 

Private non-proln 5.9 6.4 5.8 5.8 5.7 6.7 5.8 6.0 7.1 5.7 

Government workers 23.5 35.3 22.4 17.2 18.3 15.1 16.5 16.0 14.7 15.8 

SeH-employed 5.7 5.8 5.4 5.5 7.4 7.0 8.9 7.7 6.1 9.8 

Unpaid family workers 0.5 0.4 0.5 0.4 0.7 0.4 0.7 0.4 0.4 0.8 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Pet. of employed by industry 

Agric.lFor./Mining 4.7 6.9 4.6 2.4 7.4 3.1 6.5 3.6 1.8 7.2 

Construction 8.4 8.8 7.9 8.3 8.5 5.7 5.5 6.3 5.5 6.2 

Manufacturing 16.0 14.5 14.8 16.8 19.9 16.4 13.7 13.9 16.0 20.2 

Transportation 6.9 5.9 6.8 7.9 6.6 6.5 7.0 6.4 6.8 5.7 

Trade 19.3 15.1 20.7 21.2 19.9 19.6 20.0 20.2 19.8 18.4 

Services 44.8 48.8 45.1 43.4 37.8 48.7 47.3 49.6 50.2 42.3 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Again, this problem is most pronounced in Tribal Areas where a full 43 percent are without 

a high school' diploma. It is least serious in Metropolitan Areas where the comparable figure is 
Assessment of American Indian Housing Needs and Programs: Final Report 48 

29 percent. Shares in the Surrounding Counties and other Nonmetropolitan Areas again fall inbetween (30 percent and 36 percent respectively). 

The average AlAN labor force participation rate (63 percent) is just slightly below that for 

non-Indians (65 percent). Labor force participation is lowest in Tribal Areas (55 percent) and 

highest in Metropolitan Areas (70 percent). AlAN labor force participation rates are actually 

somewhat higher than those for non-Indians in all area types except Tribal Areas. 

Unemployment, however, is a particularly severe problems for Indians everywhere. The 

national AlAN unemployment rate is 14 percent, more than twice the 6 percent rate for other 

Americans. AlAN unemployment is also most serious in Tribal Areas (20 percent) and least 

serious in Metropolitan Areas (10 percent) but even in the latter, the AlAN rate substantially 

exceeds the 6 percent rate for non-Indians. 

This same pattern (higher unemployment in Tribal Areas than more urban locations) holds 

in all regions. However, there are some important regional differences between Tribal Areas in 

this regard. Their unemployment rates are lowest (close to the metropolitan average) in the 

Oklahoma and Eastern regions (both at 12 percent) and highest in the Plains (29 percent), 

Arizona-New Mexico (26 percent), and Alaska (24 percent). 

Among those who do have jobs, the composition of employment by type of worker for 

Indians differs importantly from that of the general population. A much higher percent of AlAN 

employment is provided by jobs in government or nonprofit institutions (29 percent) than is true 

for non-Indians (22 percent). This also stands out most strongly in Tribal Areas where 42 percent 

of AlAN workers are in the public and nonprofit sectors (close to twice the 23 percent for Indians 

in Metropolitan Areas). 

AlAN workers are less likely to be self-employed than non-Indians (5.7 percent vs. 7.0 

percent) and have lower shares working for private for-profit firms (64 percent vs. 71 percent). 

The self-employment rate for Indians does not vary much by area type, but there are important 

variations in private for-profit employment. The AlAN share of total employment in such jobs 

varies from a high of 71 percent in Metropolitan Areas, down through the 66-68 percent range for 

Surrounding Counties and other Nonmetropolitan Areas, reaching an average far below that level 

for Tribal Areas (52 percent). 

An area's level of employment in private for-profit firms and self-employed (PPSE 

employment) is an indicator of the economic strength of a local economy, independent of 

government support. Calculating PPSE employment per 1,000 population, AlAN populations lag 

far behind with a national average of 255, 30 percent below the 362 average for non-Indians. Per 

capita, Tribal Areas have larger dependent populations (more children), lower labor force 
Assessment of American Indian Housing Needs and Programs: Final Report 49 

participation rates, more unemployment, and more dependence on government jobs. It is 

certainly not surprising then that the PPSE rate for Tribal Areas (158) is far below Gust about half) 

the average for Indians living elsewhere (311). The latter figure is still below the average for nonIndians, but it is at least within striking distance. The AlAN average in Tribal Areas is not, 

signifying incredible economic distress. 

The industrial structure of the United States has changed dramatically during this century, 

first with enormous increases in agricultural productivity (our national agricultural output remains 

high but the percentage of our workers required to produce it is now just a tiny fraction of what 

it once was) and then the same sort of thing happening in manufacturing (although not to the 

same extent as yet). 

The first change was particularly important for Indians. Even knowing the history, 

however, the numbers come as something of a shock. Only 6.9 percent of all AlAN workers in 

Tribal Areas (4.6 percent in the Surrounding Counties and 7.4 percent in other Nonmetropolitan 

Areas) are now employed in agriculture, forestry, fisheries or mining. The comparable average 

for non-Indians nationally is just 3.1 percent. There are simply very few formal jobs left available 

in these sectors anymore anywhere. This does not imply that indians have lost their ties to the 

land, however. Subsistence hunting, farming, and gathering are still important in many areas. 

The AlAN population traditionally did not have a high share of its workforce in 

manufacturing (given that sector's concentration in and around large urban areas) but interestingly 

enough, with recent declines in manufacturing employment affecting all races, the AlAN share (16 

percent) is now on a par with that for non-Indians. With 64 percent of the total, however, trade 

and services now dominate the AlAN workforce, and they do so to a roughly similar extent in all 

area types. 

Poverty and Income 

Given their employment problems enumerated above, it is not surprising that American 

Indians and Alaska Natives are Significantly more likely to be impoverished than non-Indians in 

all parts of America--see Table 2.8. In 1989, 34 percent of all AlAN households (compared with 

24 percent of non-Indian households) had annual incomes of less than $15,000. The AlAN 

poverty rate was 24 percent, almost twice that for non-Indians. As would be expected considering 

their typically weak economic base, AlAN poverty rates were highest in Tribal Areas (36 percent) 

and considerably lower in Metropolitan Areas (17 percent), other Nonmetropolitan Areas (21 

percent) and Surrounding Counties (23 percent). 

Poverty rates also varied importantly by household type, the rates being much higher for 

large family and nonfamily households (33 percent and 34 percent respectively) than for elderly 
Assessment of American Indian Housing Needs and Programs: Final Report 50 

Table 2.8 
 

INCOME AND POVERTY, 1990 
 

AlAN POPULATION NON-AlAN POPULATION 

Tribal Surr. Other Other Tribal Surr. Other Other 

Total Areas Co. Metro. Nonmet. Total Areas Co. Metro. Nonmet. 

Pet. of households by Income ($OO(IIyr) 

Less than $15 33.S 46.9 30.4 25.3 34.7 24.2 31.9 22.9 21.9 32.S 

$15-$29 27.9 2S.0 2S.S 26.3 31.5 25.6 2S.8 25.8 24.3 29.8 

$30-99 36.5 24.3 39.0 45.6 32.9 45.S 37.0 46.7 4S.6 35.8 

$100 or more 1.8 0.8 1.8 2.S 1.0 4.4 2.3 4.6 5.2 1.7 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Pet. of households In poverty 

Elderly 16.2 24.S 10.7 10.5 15.4 6.4 9.2 5.2 5.3 9.6 

Small family 19.1 29.3 17.9 12.9 17.9 9.2 12.4 8.4 8.4 12.0 

Large family 32.5 44.9 26.9 20.4 28.9 17.0 21.S 15.7 15.S 22.1 

Other-nonfamily 33.5 47.2 30.6 25.3 37.3 19.3 26.4 17.6 17.1 28.7 

All households 24.4 36.2 21.7 16.7 23.1 12.7 16.9 11.5 11.5 17.1 

Pet. of households by Income category 

0-30 pet. of median 19.1 25.S 16.S 15.7 16.4 12.6 12.7 11.5 12.7 12.8 

31-50 pet. of median 14.2 16.9 13.6 12.4 13.9 11.2 12.1 11.5 10.7 12.5 

51-SO pet. of median 1S.7 19.1 19.2 18.0 19.6 16.5 16.7 16.8 16.1 17.9 

81-95 pet. of median 8.4 7.5 8.7 9.0 8.6 8.5 7.9 8.7 8.5 8.4 

95+ pet. of median 39.6 3O.S 41.S 45.0 41.4 51.3 50.6 51.5 52.1 48.4 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Ratio AlAN to Non-AlAN 

Pet. in poverty 1.93 2.15 1.S8 1.45 1.35 
 

Pet. 0-50 pet. med. 1.40 1.72 1.32 1.20 1.20 
 

households and small families (16 percent and 19 percent respectively). This same pattem 

appeared in all area types with, of course, higher rates for all groups in Tribal Areas than in other 

metropolitan and non metropolitan environments. This pattern was also typical for non-Indians. 

Indeed, one of the reasons that the overall AlAN poverty rate is so high is that large families 

make up comparatively such a large share of all AlAN households. 

Poverty rates, however, can be misleading indicators, distorting true comparisons of wellbeing between different social groups and locations. The reason is that the poverty threshold 

($12,674 in 1989 for a family of four) is defined as the same in all parts of the country. Yet living 
Assessment of American Indian Housing Needs and Programs: Final Report 51 

costs are very different in different locations.24 And this is a particular problem in analyzing the 

comparative living standards of American Indians and Alaska Natives--they have very low 

incomes by national standards, but a much larger share of them live in low-cost locations. 

HUD uses an alternative approach for comparing household incomes that takes variations 

in living costs into account and largely avoids this problem. In this system, a household's income 

is related to the median income in its own local labor market area, and median incomes serve 

as a reasonable proxy for differences in living costs between those areas. Households are 

generally eligible for HUD programs if they are Low-Income (LI--incomes below 80 percent of the 

local median) and are often given priority for housing assistance if they are Very Low-Income 

(VLI--incomes below 50 percent of the median). 

Table 2.8 also shows variations in AlAN income levels, compared to those of non-Indians, 

using this approach. The data tell the same basic story. Nationally, one third of all AlAN 

households are Very Low-Income (compared to 24 percent for non-Indians) and 52 percent of 

AlAN households are Low-Income (compared to 40 percent for non-Indians). AlAN households 

have significantly larger shares in these lower-income groups than non-Indians in all types of 

areas, and among AlAN households, lower income shares are highest by far in Tribal Areas and 

less sizeable elsewhere. 

Regional variations in VLI rates are substantial. They are lowest in the Oklahoma (30 

percent) and Eastern (36 percent) regions. They are significantly higher in the Arizona-New 

Mexico, North-Central, and Plains regions (all above 50 percent--see Kingsley, Mikelsons, and 

Herbig, 1995). 

Gaming in Tribal Areas 

There have been many media accounts of late about substantial income earned by Indian 

tribes from gaming establishments. This trend, however, has had very little effect on the wealth 

of Indian communities overall. So far, gaming has proven successful in only a few of the Tribal 

Areas where it has been tried and it has not yet been tried in most of them. Many of the others 

are much too remote from urban centers for profitable gaming ever to be feasible. 

One study (Robinson, 1993) indicates that there were only 81 active Indian gaming 

operations in the United States in 1992. Yet there were a total of 508 Tribal Areas (309, if Alaska 

is excluded). Of the total net income derived from these oj!)erations, over 30 percent went to a 

single Connecticut tribe; nearly half went to only two states (Connecticut and California). It was 

24Gabriel, et ai, (1993) have shown that, in particular, the disparities in housing prices between U.S. metropolitan 

areas grew significantly over the 1980s. 
Assessment of American Indian Housing Needs and Programs: Final Report 52 

also estimated that 15,900 persons were employed by these operations (and a non-trivial portion 

of those were non-Indians). Yet 15,900 represents only 8 percent of total AlAN civilian 

employment in Tribal Areas in 1990. Gaming has substantially enhanced the economic well-being 

of several of these areas, but it has left most of them untouched. In general, reservations and 

other Tribal Areas are still characterized by deep and persistent poverty. 

DIVERSITY ACROSS TRIBAL AREAS 

Summary of Findings So Far 

Reviewing the indicators presented in this chapter to this point, several reasonably 

consistent findings emerge that can be summarized as follows: 

1. 	 Compared to non-Indians, the AlAN population nationally is more family oriented, 

but along several dimensions, more prone to economic distress. 

2. 	 These characteristics (stronger family orientation, weaker economic conditions) 

distinguish the AlAN population from the general population in all area types and 

regions. 

3. 	 ConSistently, these differences are most pronounced in reservations and other 

Tribal Areas. AlAN characteristics more closely resemble those of the general 

population in metropolitan areas, but differences are still noteworthy, even there. 

4. 	 In contrast, key social and economic indicators for the non-Indian population do 

not exhibit as much variation geographically. 

5. 	 But for the AlAN population, there are also evidences of notable diversity even 

among Tribal Areas. 

This latter point comes out in examining regional differences across area types, and there 

also appeared to be some consistency in these patterns. For example, with respect to some of 

the characteristics by which Tribal Areas on average most differ from the general population, 

scores for the Tribal Areas of some regions (in particular, the Plains, Arizona-New Mexico, and 

Alaska) are even more extreme: e.g., larger shares of their households are large families, female 

headed, and Very Low Income, and yet larger shares of their labor force are unemployed or 

holding government jobs. In contrast, the Tribal Areas of the Oklahoma and Eastern regions are 
Assessment of American Indian Housing Needs and Programs: Final Report 53 

in the opposite position along each of these dimensions: i.e., more like AlAN populations in 

Metropolitan Areas and the non-Indian population in general. 

Still, this examination is not enough to show that it is the regional environment itself, rather 

than some other set of factors, that causes such variations. And it begs the question, to what 

extent do Tribal Areas exhibit diversity along these lines within regions? 

The Extent of Diversity 

Several approaches were taken to assess the extent and nature of diversity among Tribal 

Areas. The first and simplest was to tabulate the number of Tribal Areas and their populations 

in a number of ranges for several variables. Two examples are shown in Figure 2.6. Both show 

considerable diversity. The pie charts at the top show that one quarter of all Tribal Areas are 

extremely poor (86 percent or more of all households are low-income: i.e., with incomes less 

than 80 percent of the local median), but these Areas are typically small and account for only 4 

percent of the national AlAN population living in Tribal Areas. At the other extreme, in 19 percent 

of the Tribal Areas, less than half of households are low-income and these are much larger, 

together accounting for 24 percent of the total population. 

The charts at the bottom of Figure 2.6 show the variation in the PPSE variable discussed 

earlier. Again, there are a substantial number of Tribal Areas in dire circumstances according to 

this measure: 24 percent of all Areas with less than 50 private for-profit or self-employed workers 

per thousand population. But these are also small on average, accounting for only 6 percent of 

the population. At the other end of the scale, one quarter of the Areas have at least a 

comparatively strong private employment base with a PPSE ratio of 176 or more. And these are 

also much larger, accounting for 41 percent of the total Tribal Area AlAN population. 

A second approach was to plot the locations of the Tribal Areas scoring highest and 

lowest on a number of measures. These exhibited no consistent regional patterns. A third was 

to examine these distributions statistically. To do this we computed coefficients of variation for 

Tribal Area distributions for several variables. These also showed considerable diversity 

(Kingsley, Mikelsons, and Herbig, 1995, pps. 76-77). 

Factors Influencing Diversity: Hypotheses 

Factors that affect the economic well-being of tribal areas have been examined in depth 

by Cornell and Kalt (1989, 1991, 1992). In discussing these factors we rely primarily on their 

themes, offering only a few variations. Learning better methods of developing Tribal Area 

economies, of course, is not a part of the mission of this study, but learning more about how and 

why economic conditions vary is important to the purposes of this report. The nature of a Tribal 
Assessment of American Indian Housing Needs and Programs: Final Report 54 

Percent of Households Low Income 

86%+ 

4% 

Percent of Areas 

Private For-Profit Employment 

Per 1,000 Population 

66-85% 

46% 

Percent of Population 

0-50 

6% 

176+ 

41% 

51-100 

38% 

101-175 

15% 

Percent of Areas 	 Percent of Population 

FIGURE 2.6 	 Variations Among Tribal Areas: Percent Households Low Income and Percent 

Private For-Profit Employees Per 1,000 Population 
Assessment of American Indian Housing Needs and Programs: Final Report 55 

Area's economy is likely to explain much about current housing conditions and offer clues as to 

the potentials for different housing strategies in the future. 

It is helpful to group the forces driving the diversity we have identified in three categories: 

(1) internal resources; (2) integration with the broader economy; and (3) institutional-cultural 

factors. 

Internal. Resources. In assessing the strength of local economies, much of economic 

theory stresses internal resources. Basically, these are either human resources (the skills of the 

labor force) or natural resources (soil quality, timber, and mineral resources, but also scenic 

beauty as an attraction for tourism). Tribal Areas certainly vary across these dimensions. As to 

human resources, we noted that there is substantial diversity with respect to educations levels; 

quite sizeable coefficients of variation, for example, with respect to the share of all adults that had 

not graduated from high school. As to natural resources there are also vast differences between 

Tribal Areas. Most reservations have negligible mineral wealth while others are replete with oil 

wells. Cornell and Kalt note that the Crow Tribe of Montana owns one of the largest reserves of 

strippable coal in the world (in 1988, the tribe's assets were valued at about $27 million, over $3 

million per person). 

Integration with the Broader Economy. This is a theme that emerged strongly in 

assessing the field survey results of this study. Some reservations were poor, remote, and 

isolated, while others, generally closer to urban settlements, had large numbers of non-Indians 

living within their borders, and much less poverty). 

Two variables were derived from our data base to quantify the extent of diversity along 

these lines. We calculated the distance between each Tribal Area and the nearest urban area 

with a population of 50,000 or more (hereafter referred to as large urban area). The pie charts 

at the top of Figure 2.7 show the variation. Contrary to the popular image of the remoteness of 

most reservations, we found that one third of all Tribal Areas are within 50 miles (a reasonable 

commuting distance) of a city at least that size. And these were larger than the average, 

accounting for 39 percent of the total Tribal Area AlAN population nationally. At the other 

extreme, 29 percent of the Areas are more than 300 miles from a large urban area (many of 

these are Alaska Villages). They are much smaller on average, accounting for only 5 percent of 

the population. 

The lower panel on Figure 2.7 shows that a significant number of Tribal Areas are "open" 

in the sense that they have large non-Indian populations residing within their boundaries. For just 

over one quarter of all Tribal Areas, the ratio of total population to AlAN population is at least 2.0 

(i.e., there are at least as many non-Indians as Indians living within them) and as we noted in the 

examples above, for a number of them the ratios are much higher than that. And these too are 
Assessment of American Indian Housing Needs and Programs: Final Report 56 

Miles From Nearest Urban Center 50,000 

Population Or More 

301+ 

5% 

0-50 

39% 101-300 

33% 

51 00 

23% 

Percent of Areas Percent of Population 

Ratio Total Population to AlAN Population 

11% 1.00-1.20 

50% 

2.01-4.00 

Percent of Areas 

1.21-2.00 

15% 

Percent of Population 

FIGURE 2.7 Variations Among Tribal Areas: Distanc:e From Large Urban Centers and Ratio 

of Total Population to AlAN Population 
Assessment of American Indian Housing Needs and Programs: Final Report 57 

larger than average, accounting for about 40 percent of the total Tribal Area AlAN population. 

It would be expected that another factor of relevance here would be the strength of the 

economy of the surrounding region. Our sample observations suggest that a Tribal Area is likely 

to be better off in terms of income if it is close to, and well integrated with, the economy of its 

region, but we would expect that whether the region itself is booming or in decline would also 

make a difference. 

InstitutionallCultural Factors. In this area, in particular, Comell and Kalt have made 

important contributions to understanding. They note that while the Crow reservation sits on an 

extremely valuable resource base, it has not translated those resources into substantially 

increased incomes for its tribal members: "three quarters of its workforce is unemployed and half 

the population receives some form of public assistance". Three quarters of those who do work 

have government jobs. In contrast, other tribes have been quite entrepreneurial in developing 

their economic potentials and generating employment. White Mountain Apache is a notable 

example. The tribe operates nine tribally-owned enterprises and "has had repeated success in 

raising (extemal) capital and attracting employers" ... Approximately half the employment on the 

reservation is in enterprises as opposed to govemment services" (Cornell and Kalt, 1989). 

What accounts for such differences? Their analyses show that both cultural factors and 

forms of government play important roles. Crow has been unwilling to develop its mineral 

resources largely because doing so (strip mining) would devastate the natural landscape and 

habitat--a clear violation of its tribal culture. But its form of govemment may also inhibit other 

approaches to development. White Mountain Apache has a strong chief executive government 

and is characterized by strong tribal control over day-to-day decision making. Crow, in contrast, 

has a constitutionally-based general council form of government in which all voting-age tribal 

members sit on the council (no separation of powers and no checks and balances), and its 

constitution provides the Secretary of the Interior with the right of disapproval over council actions. 

In considering a broader variety of tribes, Cornell and Kalt also note differences in the 

capacities of tribal bureaucracies, differences in traditional structural relationships (in some cases, 

tribal members identify much more strongly with clans within the recognized tribe rather than the 

tribe itself), and other cultural-misfits (in some cases, the Federal government has imposed forms 

of tribal governance that are inconsistent with the tribal culture). Their statistical analysis for 

selected tribes shows that these factors do have an important influence on incomes and economic 

development. 
Assessment of American Indian Housing Needs and Programs: Final Report 58 

Analysis 

Clearly, the determination of the economic well-being among Tribal Areas is complex. 

There is tremendous diversity in outcomes, and a long list of factors that appears to have some 

influence in determining them. The Census data files used in this study have reasonable 

measures for a number of them, although several that appear to be important are missing: e.g., 

the value of natural resources on the reservation and the nature of tribal governance and its mesh 

with tribal culture. 

Nonetheless, since these data files cover all areas, it should be useful to test the relative 

importance of those factors for which data are available--without expecting to explain a high 

proportion of the diversity that has been identified. Regression analysis, however, yielded 

reasonably strong findings. 

We chose PPSE employment per 1,000 population as the dependent variable (it can be 

seen as a rough measure of the natural strength of the local economy--a direct measure of 

income was not chosen because all such measures available are distorted to some extent in that 

they mix transfer payments with earned income). The independent variables were: (1) the ratio 

of total population to AlAN population; (2) the log of the distance between the Area and the 

nearest large urban center; (3) the percentage of adults that had not graduated from high school; 

(4) the 1980-90 population growth rate; and (5) a dummy variable indicating whether the Tribal 

Areas were in a "coastal" region (Eastern, California-Nevada, or Pacific Northwest) or not. 

This regression explained 29 percent of the variation in the PPSE ratio--reasonably strong 

for cross-sectional analysis. And all of the variables were statistically significant at the 99 percent 

level (except for the population growth rate--significance level of .666). (See Annex 2A at the end 

of this Chapter). 

Interpretation and Typology 

These analyses confirm the view that AlAN Tribal Areas in the United States cannot easily 

be stereotyped. They vary from each other to a significant extent along many dimensions. And 

while they clearly do not account for all relevant forces, variables that measure the extent of a 

Tribal Area's integration with the broader economy do seem to be important. They are not final 

determinants: i.e., it seems likely that with the right leadership and institutional structure, a remote 

tnbe could succeed economically, and it is quite possible for an open reservation within the 

bounds of a thriving metropOlitan area to be quite poor. 
Assessment of American Indian Housing Needs and Programs: Final Report 59 

Nonetheless, other things being equal, Tribal Areas that are close to urban centers, 

comparatively open, with a large share of adults that have graduated from high school, and 

located in coastal regions, are likely to be performing better economically. 

What is important from a policy standpoint is that those areas have different needs, and 

different strategic opportunities than Areas that are more remote and isolated. There is no one 

correct economic development strategy (nor we suspect, one correct housing assistance strategy) 

that will fit all Areas. 

To illustrate the effect and magnitude of these differences, a rough typology has been 

constructed (Table 2.9). All of the 508 inhabitated Tribal Areas are first divided into three groups: 

"Near Urban" (within 50 miles of a large urban area); "Remote" (farther away than that), and 

"Alaska" (all of the Alaska Villages were kept separate in this typology because they are more 

similar to each other and their location offers a different set of policy options and constraints). 

The variations in characteristics are marked. 

Near Urban. This category includes 159 Tribal Areas (31 percent of the total), but has 

an AlAN population of 284,400 (38 percent of the total). It has, on average, a high level of PPSE 

employment (227 per 1,000 population) and a comparatively small share of its households are 

VLI (very low-income--34 percent). 

Remote. This category includes 148 Areas (29 percent) with a much larger population 

of 406,500 (55 percent). Its average PPSE employment ratio is not much more than half that of 

the Near Urban group (119) and a much higher share of its households are VLI (49 percent). 

Areas within it have many fewer non-Indians within their boundaries (total population to AlAN 

population averages 1.6) than those in the Near Urban group (average ratio of 9.9). They also 

have a larger average household size (3.4 persons) than those that are Near Urban (2.8 

persons). 

Alaska, as noted earlier, has a large number of Tribal Areas (199 or 39 percent), but a 

small total AlAN population (48,500 or 7 percent). It has the lowest PPSE employment ratio of 

these groups (79) and the same of households in the VLI category as the Remote group. 

Some groups have been further subdivided as to whether they are "Large and Open" 

(population of 400 or more and total to AlAN population ratio of 2.0 or more) and whether they 

have a "Strong Private Employment Base" (200 PSE employees or more per 1,000 population) 

or not. Here, a number of the variations are also of interest, but they are not as important as the 

basic differences between the Near Urban and Remote categories. 
Assessment of American Indian Housing Needs and Programs: Final Report 60 

Other and more detailed typologies could be constructed with differing boundary conditions 

that would be equally valid. As noted, however, the purpose here was only to illustrate that 

important differences exist and that large shares of the Tribal Area AlAN population nationally live 

in areas where private market forces seem to be operating. The meaning of these differences 

for housing strategies will be explored in Chapter 3 

Table 2.8 

MARKET TYPOLOGY OF TRIBAL AREAS, SOCIAL AND ECONOMIC CHARACTERISTICS 

AlAN (000) Pet. Hsehlds. 

Total Priv. Miles: 

No. of Pop.! Emp.! Nearest 

Tribal Popu- House- Pop.! AlAN 1,000 Urban LowAreas lation holds Hseld Pop. Pop. Center Income VLI 

NEAR URBAN AREAS 

Large-Open 

Strong Priv.Empl. 

Oklahoma 7 130.6 56.0 2.3 9.5 268 34 49 29 

Other 10 18.9 6.7 2.8 53.8 247 21 58 39 

Subtotal 17 149.5 62.7 2.4 15.1 266 27 50 30 

lower Priv.Empl. 29 36.6 11.7 3.1 11.0 146 26 57 38 

Total 46 186.1 74.4 2.5 14.2 242 27 51 31 

Other 

Strong Priv.Empl. 44 36.3 11.6 3.1 2.7 312 27 53 33 

lower Priv.Empl. 69 62.0 16.5 3.8 1.2 131 27 70 48 

Total 113 98.3 28.1 3.5 1.7 198 27 63 43 

Total 159 284.4 102.5 2.8 9.9 227 27 54 34 

REMOTE 

Large-Open 

Strong Priv.Empl. 6 67.7 28.8 2.4 16.2 230 74 51 31 

lower Priv.Empl. 18 36.3 11.7 3.1 4.5 108 98 68 48 

Total 24 104.0 40.5 2.6 12.1 188 85 56 36 

Navajo 4 146.0 35.9 4.1 1.0 97 99 77 59 

Other 

Strong Priv.Empl. 16 10.5 2.7 3.9 6.8 234 103 64 40 

lower Priv.Empl. 104 146.0 39.2 3.7 1.2 84 104 71 52 

Total 120 156.5 41.9 3.7 1.6 94 104 71 51 

Total 148 406.5 118.3 3.4 4.1 119 96 67 49 

ALASKA 188 48.5 13.2 3.7 1.6 78 418 68 49 

TOTAL 508 738.7 234.0 3.16 6.2 158 83 62 43 
Assessment of American Indian Housing Needs and Programs: Final Report 61 

DIVERSITY OF CONDITIONS IN URBAN AREAS 

Where Do Urban Indians Live? 

Table 2.2 showed that a total of 754,600 American Indians and Alaska Natives lived in 

Metropolitan Statistical Areas (MSAs) in 1990--38 percent of the total AlAN population nationally. 

This population, however, is not spread evenly across the nation's MSAs. To the contrary, while 

some Indians live in almost all of them, they have tended to concentrate in a comparatively small 

number. Rather than present data on conditions in all, this section focuses on 15 MSAs in which 

Indians are most concentrated, that together account for 61 percent of the AlAN metropolitan 

total. 

To the extent that scholars and the media have focused on urban Indians to date, most 

have dealt with their lives in the inner cities. It is of particular interest in this light to find that so 

many of them live in the suburbs: 331,100 (54 percent of all those in metropolitan areas outside 

of the Surrounding Counties) are suburban dwellers. For the 15 selected MSAs, 59 percent of 

the AlAN population lives in the suburbs, a higher rate than for non-Indians on average (54 

percent). It must be remembered, of course, that there is great divergence within the non-Indian 

population in this regard: AlAN households are much more likely to live in the suburbs than blacks 

or Hispanics, but less so than whites. Index measures show substantially less residential 

segregation for American Indians than for blacks and Hispanics: dissimilarity indices (where 1.0 

implies complete segregation and 0.0 implies no segregation) for the AlAN population in the 15 

MSAs ranged from 0.23 to 0.52. 

Of the urban Indian community center directors, interviewed as a part of this study, 57 

percent said that Indians in their central cities tended to congregate in identifiable neighborhoods, 

but little is known about their spatial patterns in the suburbs. Community center directors also 

stated that urban Indians generally maintain close ties with their tribes: 88 percent said that 

Indians in their communities returned to their Tribal Areas at least occasionally, and 42 percent 

they returned at least on a weekly basis. 

Contrasting Characteristics 

As noted earlier, Indians living in metropolitan areas generally fare better on many social 

and economic indicators than Indians who live in Tribal Areas and Surrounding Counties. Central 

city Indians, however, do not to fare as well as their suburban counterparts. For example, in the 

15 MSAs, they are more likely to lack a high school diploma (30 percent vs. 27 percent), be 

unemployed (11 percent vs. 8 percent), and live in households headed by single women (20 

percent vs. 12 percent) and with Very Low-Incomes (40 percent vs. 29 percent). However, in 
Assessment of American Indian Housing Needs and Programs: Final Report 62 

several of these MSAs, the socioeconomic gap between suburban Indian and non-Indian 

households is larger than that between Indians and non-Indians living in central cities. For 

example, the AlAN unemployment rate in the central cities is 1.2 times that for non-Indians, 

whereas the comparable suburban AlAN rate is 1.7 times the suburban non-Indian average. 

Contrasts in Different Types of Metropolitan Areas 

The comparative economic position of metropolitan Indians, however, appears to differ in 

different types of MSAs. AlAN households appear best off economically in two contrasting 

environments: (1) very large metropolitan areas, typically far distant from AlAN Areas; and (2) 

small metropolitan areas that are close to AlAN areas. 

The first group includes Chicago, Dallas, Detroit, Los Angeles, New York and Oakland; 

the second, Albuquerque, Oklahoma City and Tulsa. For example, the share of AlAN households 

with Very Low Incomes exceeds the comparable share for non-Indians by only 11 percent on 

average in the first group, and by 25 percent in the second. In two of these areas (Los Angeles 

and Oakland) the AlAN Very Low Income share is actually below that for non-Indians. 

In other metropolitan areas with large concentrations of AlAN population, disparities are 

much more severe. For example, for Minneapolis, Phoenix, Seattle and Tucson, the AlAN Very 

Low Income share exceeds that for non-Indians, on average, by 90 percent. In these areas, on 

average, twice as many AlAN adults do not have a high school diploma as non-Indians, whereas 

AlAN rates exceed non-Indian rates by this measure by only 18 percent in the first group and 23 

percent in the second group. 

Comparing Indians with other races using these indicators, we find that, in general, Indians 

fare better economically than blacks, but worse than Hispanics. In the latter group of MSAs noted 

above, however, Indians are in a worse position than all other groups. (See further discussion 

in Kingsley, Mikelsons, and Herbig, 1995, Chapter 4). 

REFERENCES 

Bogdon, Amy, Joshua Silver, and Margery Turner, with Martha Kuhlman and Lisa Cintron. 1993. 

. 	 National Analysis of Housing Availability, Affordability, and Adequacy: A Framework for 

Local Housing Strategies. Project Report 6290/1. Washington, D.C.: The Urban Institute. 

March. 
Assessment of American Indian Housing Needs and Programs: Final Report 63 

Bureau of the Census. 1993a. 1990 Census of Housing: Detailed Housing Characteristics, 

American Indian and Alaska Native Areas. 1990 CH-2-1A. Washington, D.C.: U.S. 

Department of Commerce. 

Bureau of the Census. 1993b. We the First Americans. Washington, D.C.: U.S. Department of 

Commerce. September. 

Cornell, Stephen, and Joseph P. Kalt. 1989. Pathways from Poverty: Development and 

Institution Building on American Indian Reservations. Harvard Project on American Indian 

Economic Development. Cambridge, MA: Harvard University. May. 

_______. 1991. Where's the Glue?: Institutional Bases ofAmerican Indian Economic 

Development. Harvard Project on American Indian Economic Development. Cambridge, 

MA: Harvard University. February. 

Cornell, Stephen, and Joseph P. Kalt, Eds. 1992. What Can Tribes Do?: Strategies and 

Institutions in American Indian Economic Development. American Indian Handbook and 

Manual Series No.4. Los Angeles: American Indian Studies Center, University of 

California at Los Angeles. 

Driver, Harold E., and William C. Massey. 1957. "Comparative Studies of North American 

Indians." Transactions of the American Philosophical Society. Vol. 47, Part 2. July. 

Frey, William H. 1993. "The New Urban Revival in the United States." Urban Studies. Vol. 30, 

Nos. 4/5, pp.741-774.h 

Gabriel, Stuart, Janice Schack-Martinez, and William L. Wascher. 1993. "The Effects of 

Regional House Price and Labor Market Variability on Interregional Migration: Evidence 

from the 1980s", in G. Thomas Kingsley and Margery Turner, eds., Housing Markets and 

Residential Mobility. Washington, D.C.: The Urban Institute Press. 

Johnson, Dirk. 1994. "Economies Come to Life on Indian Reservations." The New York Times. 

July 3. 

Kingsley, G. Thomas, Maris Mikelsons, and Carla Herbig. 1996. Housing Problems and Needs 

ofAmerican Indians and Alaska Natives. Washington, D.C.: U.S. Department of Housing 

and Urban Development. 

Passel, Jeffrey S. 1976. "Provisional Evaluation of the 1970 Census Count of American 

Indians." Demography. 13(3): pp. 397-409. 
Assessment of American Indian Housing Needs and Programs: Final Report 64 

_______. 1992. "The Growing American Indian Population, 1960-1990: Beyond 

Demography." Paper presented at the Annual Meeting of the American Statistical 

Association. August. 

Passel, Jeffrey S., and Patricia A. Berman. 1986. "Quality of 1980 Census Data for American 

Indians." Social Biology. 33(1986): pp. 163-182. 

Robinson, Robert. 1993. The Economic Impact of Indian Reservation-Based Gaming Activities. 

Washington, D.C.: National Indian Policy Center. 

Snipp, 	 C. Matthew. 1989. American Indians: The First of This Land. New York: Russel Sage 

Foundation. 

_____. 1992. "Sociological Perspectives on American Indians." American Review of 

Sociology. 18: pp. 351-371. 

u.S. 	 Department of Commerce. 1994. Statistical Abstract of the United States, 1994. 

Washington, D.C.: U.S. Department of Commerce. 
Assessment of American Indian Housing Needs and Programs: Final Report 65 

Annex 2A 
 

Multiple Regression Analysis 
 

Dependent Variables: 

Independent Variables: 

Variation 

R-Square: 

Standard Error: 

Analysis of Variance 

Degrees of Freedom: 

Mean Dep. Variable: 

F Value: 

Probability> F: 

PPSE 

SHARE 

HIGH 

POP89 

LNDIS50 

BICOAST 

29.12 

81.27 

5 

114 

35 

.0001 

Variable: Parameter Est.: 

INTERCEPT 206.42 

SHARE 2.67 

HIGH -1.51 

POP89 0.009 

LNDIS50 -22.46 

BICOAST 49.44 

Private For-Profit And Self-Employed 
 

Persons Per 1,000 Persons, AlAN Area 
 

Ratio Of Total Tribal Area Population To AlAN 

Population 

Percentage of Adults That Had Not Graduated From 

High School 

Percentage Change Of AlAN Population From 1980 

to 1990 

Natural Log Of Distance From AlAN Area To Nearest 

Urban Place Of 50,000 Or More Persons 

If AlAN Area Is Located In State Bordering East or 

West Coast, BICOAST =1, 0 Otherwise 

Std. Error: T for HO: Prob.> ITI: 

17.69 11.67 .0001 

0.49 5.36 .0001 

0.35 -4.22 .0001 

0.02 0.43 .6661 

3.36 -6.74 .0001 

10.22 4.84 .0001 
Chapter 3 

HOUSING PROBLEMS AND NEEDS OF 

AMERICAN INDIANS AND ALASKA 

NATIVES 

With a better understanding of the varying social and economic contexts in which 

American Indians and Alaska Natives lead their lives, we now turn to the central purpose of this 

assessment: the analysis of housing problems and needs. 

This chapter begins with a review of several basic characteristics of AlAN housing. It then 

describes and discusses the standards by which housing problems will be assessed and shows, 

by way of background, how America's housing problems overall have changed since 1980, using 

the same framework. The central part of the chapter then presents our analysis of AlAN housing 

problems and needs in 1990 at the national level by area-type, and reviews the extent of diversity 

that exists in these measures. At the end of the chapter, we briefly consider future prospects if 

current trends continue and, implications for national housing policy. 

BASIC CHARACTERISTICS OF AlAN HOUSING 

One of the most basic distinctions affecting housing is that between homeownership and 

rental tenure. Homeownership is a powerful value in America, and one that is strongly promoted 

by public policy. High levels of ownership have always been associated with higher levels of 

stability and maintenance in neighborhoods, and home equity represents the largest component 

of wealth for the majority of U.S. families. 

Table 3.1 shows that 57 percent of all American Indian and Alaska Native households own 

their own homes, well below the 65 percent homeownership rate for non-Indians. Interestingly 
Assessment of American Indian Housing Needs and Programs: Final Report 67 

Table 3.1 

BASIC CHARACTERISTICS, OCCUPIED HOUSING, 1990 

AlAN POPULATION NON·AIAN POPULATION 

Tribal Surr. Other Other Tribal Surr. Other Other 

Total Areas Co. Metro. Nonme!. Total Areas Co. Metro. Nonme!. 

Number of Occupied Housing Units (000) 

Renter occupied 351 74 92 148 38 31,405 437 4,514 21,983 4,471 

Owner occupied 461 161 96 150 54 59,349 991 8,589 37,330 12,439 

Total 812 234 188 298 92 90,754 1,428 13,103 59,313 16,910 

Pct. of Units 

Renter occupied 43.2 31.4 48.8 49.7 41.1 34.6 30.6 34.5 37.1 26.4 

Owner occupied 56.8 68.6 51.2 50.3 58.9 65.4 69.4 65.6 62.9 73.6 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Pet. by number of bedrooma 

None or 1 B. R. 17.6 18.2 18.8 18.1 11.9 15.1 11.4 16.4 16.8 8.4 

2 B.R. 31.4 28.4 33.4 31.5 35.0 29.6 30.9 30.1 29.0 31.3 

3 or more B.A. 51.0 53.5 47.9 50.4 53.1 55.3 57.7 53.5 54.2 60.3 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Pct. by year strueture buin 

1949 or earlier 34.7 27.0 33.2 34.5 37.1 21.9 13.4 16.5 23.7 19.8 

1950 to 1959 9.4 9.6 8.0 9.9 8.9 9.2 7.9 10.1 9.5 6.7 

1960 to 1979 20.0 23.0 19.0 19.8 21.1 29.2 38.2 32.6 28.8 25.1 

1980 to 1990 35.9 40.5 39.9 35.8 32.9 39.8 40.5 40.9 38.0 48.5 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

Pet. by type of a_age disposal 

Public sewer 81.3 63.2 90.9 80.3 75.5 90.8 68.2 87.9 94.6 74.6 

Septic tank 16.1 31.8 6.9 17.7 17.6 7.7 27.0 10.8 4.5 20.1 

Other 2.6 5.0 2.2 2.0 6.8 1.5 4.8 1.3 0.9 5.4 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

enough (given their generally weaker economic positions), it is in the Tribal Areas that the AlAN 

ownership rates are highest (68 percent). This is no doubt due to HUD's Mutual Help program. 

Even though most do not yet have title to their homes it is probable that most Mutual Help 

occupants classified themselves as owners in the Census. If Mutual Help units are excluded, the 

AlAN homeownership rate in Tribal Areas would be only 51 percent. In all other area-types, AlAN 

ownership rates are much lower (50-51 percent in the Surrounding Counties and other 

Metropolitan Areas, 59 percent in other Nonmetropolitan Areas). 

Considering their generally larger family sizes, one would have hoped that AlAN 

households occupied generally larger housing units (houses and apartments) than non-Indians, 

but Table 3.1 shows this is typically not the case. Only 51 percent of AlAN households, 

compared with 55 percent of non-Indians, live in units with three or more bedrooms. 

Correspondingly, a larger fraction of the Indians live in units with only one or no bedroom (18 
Assessment of American Indian Housing Needs and Programs: Final Report 68 

percent vs. 15 percent). There is not much variation in these relationships by area-type 

nationally. 

An even larger difference appears with respect to the age of the housing in which the 

AlAN population resides: 35 percent of all AlAN households (compared to just 22 percent of nonIndians) live in structures built 40 years ago or more (in 1949 or earlier). The share in such 

housing is higher in Metropolitan and Nonmetropolitan Areas outside of the AlAN counties (35 

and 37 percent respectively) than it is in Tribal Areas (27 percent). 

Another sign of problems is the last indicator on Table 3.1 : type of sewage disposal. The 

number of U.S. housing units not connected to either a public sewer system or a septic tank is 

negligible. For units occupied by non-Indians, only 1.5 are in that category on average. For AlAN 

occupied housing, shares connected to adequate means of sewage disposal are fairly similar to 

those of non-Indians in Surrounding Counties and other Metropolitan Areas, but much higher 

elsewhere: 5 percent in Tribal Areas, and 7 percent in other Nonmetropolitan Areas. 

DEFINING HOUSING PROBLEMS AND NEEDS: A FRAMEWORK 

The information reviewed above is indicative of problems in AlAN occupied housing, but 

it does not measure them directly. This section reviews the attributes of housing that identify 

these problems and, thereby, define needs. 

Characteristics Defining Housing Problems and Needs 

As a concern of public policy, housing inadequacy is defined by several differing problem 

attributes. Appropriate remedial actions for individual housing units can vary dramatically 

depending on the specific mix of problems that affect each unit. 

While the literature on the definition of housing problems (see, for example, Baer, 1976, 

Kristof, 1968, U.S. Bureau of the Census, 1967, United Nations, 1967, and HUD, 1994) varies 

in many respects, almost all of it has recognized three attributes of housing as the basic in 

defining housing problems and needs: price, quantity, and quality. 

Price. Here, a problem exists when a family is forced to payout in housing expense more 

than it can reasonably afford; in other words, when it has to spend so much for housing that it 

does not have enough money left over for adequate food, clothing, and other necessities of life. 
Assessment of American Indian Housing Needs and Programs: Final Report 69 

Quantity. Here, at a market-wide level, the question is whether there are enough housing 

units to accommodate the number of households in the area (this always means enough for the 

number of households plus a sufficient number of vacant units to permit a reasonable rate of 

exchange and mobility). The second aspect of quantity is at the individual family level; i.e., the 

extent of overcrowding (whether there is enough floor space in the unit to reasonably 

accommodate the activities of the number of people who have to live in it). Theoretically, at least, 

this level of housing quantity problem could occur because the housing units in the stock were 

on average too small for the typical household or, because of market-level supply constraints, 

some units have to accommodate more than one household. 

Quality. This is the most complex of the three because it has at least three aspects, two 

of which are extremely difficult to define and measure reliably. 

• 	 Facilities problems. This is the easiest to monitor. Such problems occur when a 

unit either lacks adequate plumbing, kitchen, electrical, and/or heating facilities, or 

such facilities function improperly or constitute a safety hazard. 

• 	 Condition problems. These occur when the unit was built inadequately (or has 

since deteriorated) such that it is structurally unsafe or offers inadequate protection 

from the elements. They have always proved harder to rate in an objective 

manner. 

• 	 Design problems. These relate to the physical arrangement and characteristics 

of external features and internal spaces--whether or not the inhabitants find them 

attractive and functionally convenient. Since tastes are inherent in assessing this 

attribute, and tastes vary importantly between groups and individuals, no objective 

scheme for rating such design problems has ever been devised. However, this 

does not mean that such problems are not important to the residents. 

Some housing built on reservations over the last few decades (certainly including some 

assisted housing built by IHAs) has been criticized because of this last aspect: design problems. 

The criticism has focused on designs considered insensitive to Indian culture (see, for example, 

National Commission on American Indian, Alaska Native and Native Hawaiian Housing, 1992). 

While it is not possible to measure the extent of such problems scientifically, this study has 

attempted to relate to them through more general questions about attitudes (see Kingsley, 

Mikelsons, and Herbig, 1995, Chapter 5). Even to do that, however, it was necessary to identify 

characteristics of housing that are of particular importance in Indian culture. 
Assessment of American Indian Housing Needs and Programs: Final Report 70 

The types of housing historically developed by indigenous cultures are in most cases no 

longer directly relevant, but they may offer some clues. A number of such types are illustrated 

in Figure 3.1. Clearly, they differ from each other in important ways, having evolved out of the 

interaction of physical environments, life-styles and cultures that differ between tribes. The tipi 

of the plains, for example, was effective shelter for tribes that were nomadic (moving from place 

to place in response to the movements of game herds and changing seasonal conditions). 

Alternatively, the Iroquois long house offered shelter from the elements but presented an interior 

space that better suited a more communal culture. The larger pueblos of the Southwest (evolving 

from the great settlements of the Anasazi) were solider structures that provided better protection 

from attack as well as supporting a quite "urban-like" community environment.25 

HUD has taken a number of steps to encourage IHA sensitivity to cultural design issues, 

including initiating and sponsoring a study of Indian housing design by the American Indian 

Council of Architects and Engineers: Our Home: Giving Form to Traditional Values (AICAE, et 

aI., 1992). One theme emphasized, in this report is speCial sensitivity to local landforms and 

physical conditions--the use of forms, colors, and textures in harmony with the land--achieved in 

part through the use of indigenous materials. This study also notes other features that are 

commonly considered ideals in Indian homes, for example: orienting the main entrance to the 

East (so the family can "greet the first light of day"); more open interior planning (the use of 

something approximating a "great room" for family activity, and smaller bedrooms than are typical 

in non-Indian housing); kitchen areas that blend into dining areas and are big enough to allow 

several people to work comfortably; the provision of ample storage space; the open display of 

colors and symbols that have cultural and religious significance. 

Standards and Approach 

In assessing the seriousness of housing problems, public policy in the United States has 

always focused on a set of minimum standards related to the measurable attributes of price, 

quantity, and quality. The question is: What share of all households fall below the minimum 

standard with respect to each attribute? 

Most analysts recognize that there is no absolute set of minimum housing standards that 

hold for all times and cultures. Science has found few specific cut-offs with respect to physical 

conditions, for example, where it can be said that housing below that standard is absolutely 

dangerous or unhealthy. Standards are therefore based on cultural norms as well as scientific 

knowledge of causes and effects. As their material wealth expands, societies have, in fact, 

sometimes made their standards more stringent (see discussion in Baer, 1976). 

25For more complete discussion of the evolution of different Indian housing types, see Driver and Massey, 1957, 

and for one specific case--the Navajo--see Jett and Spencer, 1981. 
Assessment of American Indian Housing Needs and Programs: Final Report 71 

Pueblo House Longhouse (Iroquois) 

Hogan Tipi 

Th.lChed HOUle 

FIGURE 3.1 Traditional Housing Types, American Indians 
Assessment of American Indian Housing Needs and Programs: Final Report 72 

In this study, we have relied on the standards that are most commonly accepted by 

housing analysts today, as reflected in the surveys by the Bureau of the Census (its American 

Housing Survey--AHS--as well as its decennial Census).26 These standards are defined in 

Figure 3.2. As per the discussion in Chapter 1, the Census is the most reliable source of 

information on many of these measures. It gives us a basis for assessing all of them except: (1) 

heating and electrical facilities; and (2) structural condition. In this assessment, we will first 

review all measures of housing problems available from the Census and then, at least for Tribal 

Areas, rely on our sample household survey to estimate the extent of problems in these latter two 

categories. 

The following paragraphs offer explanation and comments on the standards defined in 

Figure 3.2. 

Price (Affordability). Up until the early 1980s, the traditional Federal standard was that 

no family should have to payout more than 25 percent of its income for housing expenses. 

Congress then changed the standard to 30 percent for calculating subsidy entitlements and we 

use that level in this analysis--data are derived from special 1990 Census files prepared for this 

study (see discussion in Chapter 1). 

This is a reasonable comparative indicator, but that does not mean it is the best standard 

in our judgement. Actually, any standard expressed as a fixed percent of income is almost sure 

to be inequitable. At higher income levels, households can quite easily pay more than 30 percent 

for housing and have more than enough left over to cover the costs of other necessities. At very 

low-incomes, however, 30 percent is likely to reflect true hardship; i.e., the absolute amount left 

over after paying for housing is clear1y insufficient pay for subsistence levels of food, clothing, and 

other needs. Stone (1993) has designed a sliding scale for this purpose which would be more 

equitable and, by his estimates, not unreasonably expand subsidy obligations. 

2s,-he AHS is a nationwide sample survey of household and housing characteristics which conforms to Census 

definition for most of its measures, but it also covers a number of topics in more depth. It does contain data, for 

example, on the full range of types of housing problems identified here and we will use it to characterize the extent of 

national problems for each. The AHS survey process supports nationwide estimates of changes in housing 

characteristics and conditions every two years. As such it is an extremely valuable information source. Unfortunately, 

the national sample (about 60,000 units) is too small for use as a reliable basis for separately estimating conditions for 

American Indians and Alaska Natives. (See further description of the AHS and its uses in measuring housing problems 

in Bogdon, Silver, and Turner, 1993). 
Assessment of American Indian Housing Needs and Programs: Final Report 73 

Figure 3.2 

HOUSING STANDARDS DERIVED FROM CENSUS AND 

AMERICAN HOUSING SURVEY MEASURES 

PHYSICAL PROBLEMS 

A unit is defined to have a severe physical problem if it has any of the following five problems: 

1. Condition-Severe: (a) having any five of the following six maintenance problems: 

(1) leaks from outdoors; (2) leaks from inside the structure such as pipes or plumbing fixtures; 

(3) holes in the floor; (4) holes or open cracks in the walls or ceilings; (5) more than one square 

foot of peeling paint; and (6) signs of rats or mice in the last 90 days; or (b) having all of the 

following four problems in public areas: (1) no working light fixtures; (2) loose or missing steps; 

(3) loose or missing railings; or (4) no elevator. 

2. Facilities-Plumbing-Severe: Lacking hot piped water or a flush toilet, or lacking both 

bathtub and shower, all inside the structure for the exclusive use of the unit. 

3. Facllltles-Kltchen-Severe: Lacking a sink, refrigerator, or burners, all for the exclusive 

use of the unit. 

4. Facilities-Heating-Severe: Having been uncomfortably cold last winter, for 24 hours or 

more, because the heating system broke down, and it broke down at least three times last winter, 

for at least six hours each time. 

5. Facilities-Electrical-Severe: Having no electricity, or all of the following three electric 

problems: (a) exposed wiring; (b) a room with no working wall outlet; and (c) three blown fuses or 

tripped circuit breakers in the last 90 days. 

OVERCROWDING PROBLEM 

A unit is defined to be overcrowded if it has 1.01 or more persons per room. 

AFFORDABILITY PROBLEM 

A household is defined to have an affordability problem if it pays gross rent exceeding 30 percent 

of its income (for renter households) or total expenses of home ownership exceeding 30 percent 

of its income (for home owner households). 
Assessment of American Indian Housing Needs and Programs: Final Report 74 

Quantity (Overcrowding). As noted, we accepted as the cut-off the standard now 

accepted in the Census. Namely, a housing unit is defined to be overcrowded if it has 1.01 or 

more inhabitants per room. Here, too, data pertaining to this indicator are available in the 1990 

Census. 

Quality (Facilities). The measures of affordability and overcrowding noted above offer 

a clear distinction as to whether, for a specific household, the standard is or is not met. This is 

also true for the existence of facilities: i.e., a housing unit either does or does not have hot piped 

water and a toilet. Decisions could get muddy with respect to whether the specified facilities are 

working properly, since this could be a matter of judgement. However, the standards in these 

cases (Figure 3.1) are also stated in a manner that eliminates ambiguity so that clear 

determinations can be made. As noted above, the Census provides data on deficiencies with 

respect to two of these types of basic facilities (plumbing and kitchen facilities) but not the 

remaining two (heating and electrical facilities).27 

Quality (Condition). Among all measures of housing problems, the physical condition 

of the structure has been the most difficult to assess reliably. The Census attempted ratings with 

judgmental categories (like "needing major repairs" or "dilapidated") from 1940 through 1960, but 

gave up any such measures after analysis showed they were unreliable (see Bureau of the 

Census, 1967). Another approach has been developed which does produce more consistent 

ratings, and it is now being used in the AHS. It is evident from the way the condition standards 

are stated (Figure 3.2). The overall condition rating is built up from a series of ratings of 

individual condition elements and each of these is defined in a way that requires only 

straightforward yes-or-no answers, and the right answer is easily recognizable without special 

training. 

271t should be noted that while definitions for individual facility and condition problems used here conform to those 

used in the AHS, the approach in Figure 3.2 puts them together in a somewhat different way than the summary 

measures published by the AHS itself. First, the AHS has "moderate" and "severe" ratings for each item; the scheme 

in Figure 3.2 omits the moderate ratings because, in our judgement, those identify problems that can be remedied in 

most cases by fairly low-cost repairs. Second, we classify the lack of kitchen facilities as a severe problem, while the 

AHS does not. Third, we use definitions for "lacking plumbing and kitchen facilities" that conform to the Census, and 

are somewhat different from those used in the AHS summary tabulations of housing problems. 
Assessment of American Indian Housing Needs and Programs: Final Report 75 

THE HOUSING PROBLEMS OF AMERICAN INDIANS 
 

AND ALASKA NATIVES: NATIONAL SUMMARY 
 

The National Context 

To understand the policy implications of the housing problems of American Indians and 

Alaska Natives,.it is necessary to see them in the context of the changing nature of the housing 

problems of the United States in general. And, over the past few decades, the composition of 

U.S. housing problems has changed dramatically. In brief, affordability problems have grown to 

become the nation's primary housing issue while the incidence of the other (phYSical) problems 

has plummeted. We describe the national housing picture using data from the 1989 AHS (rather 

than the Census) because it has data on the full range of problems classified above (Table 3.2). 

Overcrowding and Physical Problems. From 1950 to 1983, the share of all American 

households that were overcrowded (standard of over 1.5 persons per room) went down from 9.0 

percent to 0.8 percent (the 1989 level was 2.7 percent but at a standard of 1.01 persons or more 

per room). From 1950 to 1989, the share lacking plumbing facilities decreased even more 

dramatically: from 55.4 percent to 2.7 percent. Clearly, these are impressive changes over a 40 

year period.28 And among facility deficiencies, the lack of plumbing facilities was the most 

prevalent in 1989. Perhaps the most remarkable change was that, by 1989, the share of all 

occupied units with severe condition problems (those that could only be alleviated by major 

rehabilitation) had become negligible: 0.25 percent. There was some overlap between these 

problems: i.e., some units had two or more of them. Altogether, 4.5 percent of all occupied units 

had one or more serious facility/condition problems in 1989; 5.9 percent were in this category, 

and/or overcrowded. 

Affordability Problems. In contrast, the share with affordability problems in 1989 

(housing expenses equal to more than 30 percent of household income) was much higher: 23 

percent. And for almost all of these (20 percent) affordability was their only housing problem (no 

overcrowding or physical deficiencies). 

Comparison with Census Indicators. The AHS data show that the incidence of 

problems not measured by the Census (problems with heating facilities, electrical facilities, and 

structural condition) is quite small nationally. The total for these categories is the equivalent of 

0.76 percent of all occupied units. However, many of these problems occur in units that also 

have problems measured by the Census. Subtracting them brings down the total overcrowded 

28Base numbers for these calculations and further discussion of them can be found in Struyk, Turner, and Ueno 

(1988), and Kingsley (1991). 
Assessment of American Indian Housing Needs and Programs: Final Report 76 

Table 3.2 

U.S. HOUSING PROBLEMS, 1989 AMERICAN HOUSING SURVEY 

National AHS, 1989 Survey 

U.S. Cent. Outside 

Total City Suburb Metro. 

TOTAL HOUSEHOLDS (000) 93,684 30,294 43,095 20,295 

PERCENT WITH HOUSING PROBLEMS 

Physical Problems 

Plumb.lKitch.Facii. 3.8 4.4 3.1 4.2 

Other Severe 0.7 1.1 0.5 0.7 

Total 4.5 5.6 3.6 4.9 

OVercrowding 

Units wI Phys.Prob. 1.4 2.3 1.0 0.9 

Other Units 1.4 1.8 1.2 1.0 

Total OVercrowded 2.7 4.1 2.2 1.9 

Total, Phys.+ O.C. 	 5.9 7.4 4.8 5.9 

Affordability Problem 

Units wI Phys.&lor O.C. 2.2 3.5 1.6 1.7 

Other Units 20.8 25.7 19.5 16.3 

Total 23.0 29.2 21.1 18.0 

Total with Housing Prob. 26.7 33.0 24.3 222 

SOURCE: American Housing Survey, 1989, and special flies complied for Bogdon, Sliver, and Turner, 1993 

and/or with other physical problems down from 5.9 percent to only 5.4 percent. 

AlAN Housing Problems Nationally-Census Indicators 

The Census data on Table 3.3 show that the housing problems of American Indians and 

Alaska Natives are much more severe than the national averages. 

National Overview. 

• 	 The AlAN share of occupied units lacking plumbing and or kitchen facilities is 5.5 

percent, well above the 3.8 percent national average. 
Assessment of American Indian Housing Needs and Programs: Final Report 77 

Table 3.3 

U.S. AlAN HOUSEHOLDS AND HOUSING PROBLEMS 

AlAN COUNTIES REST OF U.S. 

Total Tribal Surr. NonU.S. Total Areas Co. Total Metro. Metro. 

TOTAL HOUSEHOLDS (000) 

No housing problem 487.7 242.3 130.6 111.7 245.4 185.3 60.1 

One or more problems 

Facilities 44.3 37.5 32.8 4.6 6.8 4.0 2.8 

Other Overcrowded + mix 80.4 52.6 31.8 20.8 27.8 22.2 5.6 

Afford. only 200.1 89.9 39.2 50.8 110.2 86.2 23.9 

Subtotal 324.7 180.0 103.8 76.1 144.8 112.4 32.3 

Total 812.4 422.2 234.4 187.9 390.2 297.7 92.5 

PERCENT OF TOTAL 

No housing problem 60.0 57.4 55.7 59.5 62.9 62.2 65.0 

One or more problems 

Facilities 5.5 8.9 14.0 2.5 1.8 1.4 3.0 

Other Overcrowded + mix 9.9 12.5 13.6 11.1 7.1 7.4 6.1 

Afford. only 24.6 21.3 16.7 27.0 28.2 29.0 25.9 

Subtotal 40.0 42.6 44.3 40.5 37.1 37.8 35.0 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

NO. OF LOW INCOME HOUSEHOLDS (000) 

No housing problem 160.7 92.2 59.8 32.4 68.5 49.4 19.0 

One or more problems 

Facilities 35.9 30.6 27.0 3.6 5.3 3.1 2.2 

Other Overcrowded + mix 54.8 36.4 22.1 14.3 18.4 14.6 3.8 

Afford. only 169.9 78.6 36.0 42.7 91.3 70.2 21.1 

Subtotal 260.6 145.6 85.1 60.5 115.0 87.8 27.2 

Total 421.3 237.8 144.9 92.9 183.4 137.2 46.2 

PERCENT OF LOW INCOME 

No housing problem 38.1 38.8 41.3 34.8 37.3 36.0 41.2 

One or more problems 

Facilities 8.5 12.9 18.6 3.9 2.9 2.2 4.7 

Other Overcrowded + mix 13.0 15.3 15.3 15.3 10.0 10.6 8.3 

Afford. only 40.3 33.1 24.8 45.9 49.8 51.1 45.7 

Subtotal 61.9 61.2 58.7 65.2 62.7 64.0 58.8 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 

• Overcrowding is much more prevalent among Indians--12 percent of all 

households are overcrowded, more than 4 times the 2.7 percent national average. 
Assessment of American Indian Housing Needs and Programs: Final Report 	 78 

• 	 Accounting for the over1ap (which is substantial), a total of 15 percent of all AlAN 

households are either overcrowded or have facility deficiencies (compared with the 

5.4 percent for the nation as a whole). 

• 	 The difference is not as substantial with respect to affordability; 29 percent of AlAN 

households had an affordability problem compared with the 23 percent national 

average. For 25 percent of the AlAN households, affordability was the only 

housing problem (the comparable national average was 20 percent). 

• 	 Altogether, 40 percent of AlAN households had one or more housing problems 

(compared to the national figure of 27 percent). 

Variations by Area Type, however, are extremely important in interpreting the housing 

problems of American Indians and Alaska Natives (see Figure 3.3 as well as Table 3.3). 

• 	 The overcrowding rate for AlAN households is higher than the 2.7 percent national 

average everywhere, but highest by far in the Tribal Areas: 21 percent, compared 

to 12 percent in the Surrounding Counties, 8 percent in Metropolitan Areas and 7 

percent in other Nonmetropolitan Areas. 

• 	 The share of AlAN households lacking plumbing or kitchen facilities is substantially 

above the 3.8 percent national average in Tribal Areas (14 percent), but below that 

average in the Surrounding Counties (2.5 percent), Metropolitan Areas (1.4 

percent), and other Nonmetropolitan Areas (3.0 percent). Facility deficiency rates 

are extraordinarily high in the Tribal Areas of two regions--ArizonalNew Mexico (37 

percent), and Alaska (51 percent)--and these (particularly the former because of 

its large population size) have a strong influence on the average for AlAN Areas. 

• 	 Putting these last two measures together (and again accounting for the fact that 

some units had both types of problems), a total of 28 percent of all AlAN 

households in Tribal Areas had overcrowding and/or plumbing/kitchen facilities 

deficiencies. The comparable shares were 13 percent in Surrounding Counties, 

8 percent in Metropolitan Areas elsewhere, and 8 percent in other Nonmetropolitan 

Areas. 

• 	 In most of the country, the share of all AlAN households whose only housing 

problem is affordability is notably above the 20 percent national average: 27 

percent in the counties surrounding AlAN areas, 29 percent in Metropolitan Areas 

elsewhere, and 26 percent in other nonmetropolitan areas. In the Tribal Areas 

themselves, however, the share with an affordability problem is lower: 17 percent. 
Assessment of American Indian Housing Needs and Programs: Final Report 79 

50 .Plumbing/KHch. Facil. 

IIIIOvarcrowding only 

CAffordability only 

40 

(II 

-0 

15 

.<::

., 30 (II 

:> 

0 

J: 

0 

E 

~ 20 ., 

Q. 

10 

o Tribal Anoas Surrounding Counties Other Metro Other Non-Metro ALL U.S. HOUSEHOLDS 

AlAN HOUSEHOLDS 

FIGURE 3.3 Housing Problems by Area Type Based on Census Measures 

This is probably explained, at least in part, by the substantial amount of HUD 

housing provided in those areas (to be examined in Chapter 5). 

• 	 The AlAN total share with one or more housing problems is 44 percent in Tribal 

Areas, 41 percent in the Surrounding Counties, 38 percent in other Metropolitan 

Areas, and 35 percent in other Nonmetropolitan Areas. 

Table 3.3 also pOints out that AlAN housing problems are highly concentrated among lowincome households (those with incomes below 80 percent of the local median). Out of the total 

of 812,400 AlAN households, 421,300 (52 percent) are low-income. Among all who have one or 

more housing problems, however, the low-income households account for 80 percent (260,600 

out of 324,700)--this share is about the same in all area-types. 

Estimates of Total Housing Problems in Tribal Areas 

Earlier in this chapter, it was noted that the Census data presented above account for only 

a part of the nation's housing problem, because they do not measure the extent of heating 
Assessment of American Indian Housing Needs and Programs: Final Report 80 

system, electrical system, and structural condition deficiencies. How important are these 

problems in comparison to the Census measures reviewed to this point? 

Data from the American Housing Survey (AHS) indicate that these "missing problems" 

affect only a small fraction of all households nationally. Table 3.2 showed that only 4.5 percent 

of all occupied housing units had facility or condition deficiencies of any kind. And only a small 

part of this group was accounted for by deficiencies not also recorded in the Census. Together, 

they raised the total with phYSical deficiencies only by 0.7 percent. Still we do not know if this 

is an accurate portrayal of their importance in AlAN occupied housing. 

The only data that can provide additional clarity on this issue are from the small scale 

household survey conducted in a sample of Tribal Areas as a part of this study (see discussion 

in Chapter 1). In this survey, interviewers (usually local tribal members) interviewed the sampled 

households, but also recorded physical characteristics of their housing units, following questions 

similar to those used in the AHS (and conforming to the standards stated in Figure 3.2). 

Because the sample was so small nationally (414 complete responses), no attempt was 

made to analyze these deficiencies item by item but the data were tabulated in a manner that 

would support an estimate of the total effect of the types of deficiencies not covered by the 

Census. This entailed: (1) grouping the data by region; (2) identifying the number of sampled 

units in each group that did not have Census problems but did have heating, electrical and/or 

condition deficiencies and calculating their share of all units in each regional grouping; and (3) 

creating a national estimate, adjusting the raw scores by applying appropriate AlAN Tribal Area 

household count weights for each region. 

The resulting estimates indicated that, for AlAN households in Tribal Areas, deficiencies 

in these categories are much more important than they are at the national level. Compared to 

the 0.7 percent national average, about 17 percent of the weighted Tribal Area sample had 

heating, electrical, or condition deficiencies (exclusive of Census plumbing and kitchen 

deficiencies). Adding this to the 14 percent with plumbing and kitchen deficiencies brings the total 

with all such problems to 31 percent. After making minor adjustments to the overlap with 

overcrowding, the total percent of occupied units overcrowded and/or with any physical 

deficiencies jumps from the 28 percent identified by Census measures alone, to 40 percent.29 

2DAt the 95 percent confidence level, the estimate of the share of all units with severe condition and/or 

heating/electrical falls in the range from 11.7 percent to 22.3 percent; the estimate of the portion of that group that is 

not also overcrowded falls in the range from 7.4 percent to 16.6 percent. The Census estimates are also based on a 

sample, but a much more substantial one--the 95 percent confidence interval around the point estimates given above 

are well below one percent. Adding the Census estimates to those derived from the household sample produces the 

following results: the point estimate for the total units with any severe condition or facility problem was 31 percent (95 

percent confidence interval, 26 percent to 36 percent); the estimate for the total units overcrowded and/or with any 

severe condition or facility problem was 40 percent (95 percent confidence interval, 35 percent to 44 percent). 
Assessment of American Indian Housing Needs and Programs: Final Report 81 

Adding those with affordability problems only, the share with any housing problems increases 

from 44 percent to 54 percent (see Figure 3.4). 

Official census figures show a total of 234,400 occupied housing units in Tribal Areas 

nationally in 1990. The 40 percent average implies that 93,800 of these units were overcrowded 

and/or had serious physical deficiencies. That number, however, is not adjusted to compensate 

for the major census undercount in Tribal Areas that occurred in 1990. If that adjustment is 

made, the total overcrowded and/or with serious physical deficiencies would be 105,200 units 

(81,600 of which had physical deficiencies). 

Because these estimates were based on such a small sample, they should be used with 

caution. They do seem to indicate at the very least, however, that deficiencies of AlAN Tribal 

Area housing with regard to condition and heating and electrical systems are indeed serious. 

Added to the more reliably documented Census measures of problems with plumbing and kitchen 

facilities (much more frequent than for Indians or non-Indians in other areas), it does appear that 

American Indian and Alaska Native Tribal Areas contain among the most serious concentrations 

of inadequate occupied housing that still exist in America. 

No data is available to support reliable estimates of condition and heating/electrical 

facilities problems of AlAN housing in other areas. Because AlAN households tend to occupy 

older units on average, it is likely that their deficiencies in this regard are more serious than those 

of non-Indians in those locations. Yet such problems are probably much less widespread than 

those in Tribal Areas. 

TRIBAL AREA HOUSING PROBLEMS: REGIONAL VARIATIONS 

Table 3.4 shows the percentage of AlAN Tribal Area households in each housing problem 

category, by tenure group, by region. This table reports only on housing problems evidenced in 

Census files. Because of the small sample size, household survey data on other problems were 

not tabulated at the regional level. 

All Households with Problems 

1 . 

In absolute terms, the largest concentration of housing problems occurs in the ArizonaNew Mexico region (39,300 households with one or more problems, 31,200 of which are owners). 

The second largest is in Oklahoma (25,200 households with problems, 13,700 of which are 

owners) and the third is in the Plains region (11,900 households, 4,900 of which are owners). 
Assessment of American Indian Housing Needs and Programs: Final Report 82 

60 II Affordability only 54 

.Overcrowding & 

50 physical deficiencies 

I 40 

I 

:I 

0

::c 30 

'& 

i 20 ; 

Go 

10 

0 

Tribal Areas U.S. Average Tribal Areas U.S. Average 

Physical Problems: Physical Problems: Add 

Plumbing/Kitchen Only Condition and Heat/Electrical 

FIGURE 3.4 Housing Problems - Comparison of Census and Household Survey Measures 

In percentage terms, a somewhat different picture of priorities is apparent. Two regions 

stand out as having, by far, the largest shares of all Tribal Area households with housing 

problems: Alaska, with a notable 71 percent, and Arizona-New Mexico, with 68 percent. The next 

highest regions were the Plains (47 percent) and the South Central (42 percent). Overall shares 

with problems,were in the 30-40 percent range for all other regions except for Oklahoma, which 

was lowest at 29 percent. 

Affordability Problems in Tribal Areas 

As pOinted out earlier in this chapter, affordability problems are not as frequent in Tribal 

Areas as they are for AlAN households elsewhere, but they are quite high in some cases.30 The 

share of all Tribal Area households whose only problem is affordability is considerably higher for 

renters (24 percent) than owners (13 percent) and this distorts the comparison of the overall 

3O'fhe breakdowns on these tables are calculated so that subcategories add to totals, thus they do not exhibit all 

of the overlaps that occur. The first category--Affordability only--is just that. The second--Overcrowding and mixed-­

includes all of the overcrowded households, but some of these also have affordability and facility problems. The third-­

Facility and other--includes households in units lacking plumbing and/or kitchen facilities, but some of these may also 

have affordability problems. 
Assessment of American Indian Housing Needs and Programs: Final Report 83 

Table 3.4 
 

TRIBAL AREA HOUSING PROBLEMS BY REGION-peT. OF HOUSEHOLDS 
 

Reg. 1 Reg. 2 Reg. 3 Reg. 4 Reg. 5 Reg. 6 Reg. 7 Reg. 8 Reg. 9 

Total North- South- Ariz.- Calif.- Pacif. 

U.S. Central Eastern Okla. Central Plains N.Mex. Nev. No.West Alaska 

Renter 

No housing problem 50.1 55.1 53.9 56.0 47.1 46.4 42.2 63.1 55.3 27.4 

One or more problems 

Afford. only 24.2 28.6 29.6 31.8 32.4 24.3 9.3 18.3 27.5 11.1 
 

Overcrowded + mix 21.5 13.9 10.0 10.0 19.2 26.8 42.3 16.4 16.0 39.0 
 

Facil. and other 4.2 2.4 6.6 2.2 1.3 2.6 6.3 2.2 1.2 22.5 
 

Subtotal 49.9 44.9 46.1 44.0 52.9 53.6 57.9 36.9 44.7 72.6 
 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 
 

Owner 

No housing problem 58.3 68.8 71.6 77.4 62.0 60.2 29.1 68.2 68.8 29.9 

One or more problems 

Afford. only 13.3 17.6 16.9 17.0 20.8 15.5 6.2 15.2 16.2 6.2 
 

Overcrowded + mix 20.4 10.7 9.2 4.7 15.8 19.5 45.5 12.9 13.2 37.9 
 

Facil. and other 8.0 3.0 2.3 0.9 1.4 4.7 19.1 3.7 1.8 26.0 
 

Subtotal 41.7 31.2 28.4 22.6 38.0 39.8 70.9 31.8 31.2 70.1 
 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 
 

Total by Region 

No housing problem 55.7 62.7 67.4 70.9 57.7 53.2 32.2 66.5 63.4 29.2 

One or more problems 

Afford. only 16.7 22.5 19.9 21.4 24.1 20.0 7.0 16.2 20.7 7.6 
 

Overcrowded + mix 20.8 12.1 9.4 6.3 16.8 23.2 44.8 14.1 14.3 38.2 
 

Facil. and other 6.8 2.8 3.4 1.3 1.4 3.6 16.0 3.2 1.5 25.0 
 

Subtotal 44.3 37.3 32.6 29.1 42.3 46.8 67.8 33.5 36.6 70.8 
 

Total 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 100.0 
 

Total Across Regions 

No housing problem 100.0 4.1 9.1 47.1 2.1 10.3 14.3 3.6 6.4 2.9 

One or more problems 

Afford. only 100.0 4.9 8.9 47.4 3.0 13.0 10.3 2.9 7.0 2.6 
 

Overcrowded + mix 100.0 2.1 3.4 11.2 1.7 12.1 53.3 2.0 3.9 10.3 
 

Facil. and other 100.0 1.5 3.7 7.1 0.4 5.7 58.2 1.4 1.3 20.6 
 

Subtotal 100.0 3.1 5.5 24.2 2.0 11.4 37.8 2.3 4.6 9.0 
 

Total 100.0 3.7 7.5 37.0 2.1 10.8 24.7 3.0 5.6 5.6 
 

average with Indians living in other metropolitan and non metropolitan environments since Tribal 

Areas have higher ownership rates than found in other areas. 

Among renters, the highest shares with an affordability-only problem are found in the 

Oklahoma and South Central regions (both at 32 percent). The lowest are much below those 

levels: 9 percent in Arizona-New Mexico and 11 percent in Alaska. For owners, there is not quite 

as much variation. The highest is again the South Central (21 percent) followed by the North 

Central, Oklahoma, Eastern, and Pacific Northwest (all in the 16-18 percent range. The lowest 
Assessment of American Indian Housing Needs and Programs: Final Report 84 

affordability problem shares for owners, however, are found in the same regions as for renters: 

Arizona-New Mexico and Alaska (both at 6 percent). 

Overcrowding and Facility Problems 

Taking both these categories together, incidence rates do not vary dramatically between 

renters (26 percent) and owners (28 percent) for all Tribal Areas nationally. But there are major 

regional variations. Two regions dominate in this regard: Alaska (with 63 percent of all 

households having these problems) and Arizona-New Mexico (61 percent). The next highest 

(South Central) is far below those levels at 27 percent. All the rest are in the 13-18 percent range 

except Oklahoma, which is again low at 8 percent. 

There are compositional differences between the regions with the most serious problems 

in this regard. In Arizona-New Mexico, by far the most frequent problem (affecting 45 percent of 

all households) is overcrowding. In Alaska, 38 percent are overcrowded--the problems there are 

explained more by a lack of basis facilities. The next highest in terms of overcrowding is the 

South Central region (23 percent). Rates of overcrowding are comparatively quite low elsewhere 

(all in the 9-17 percent range, again except for Oklahoma which is lowest at 6 percent). 

Looking solely at the residual category (units that are not overcrowded but have facility 

deficiencies), problem levels are noteworthy only in Alaska (25 percent) and Arizona-New Mexico 

(16 percent). They are quite low in the Tribal Areas of all other regions. 

Summary 

To be sure, there are important regional differences in the incidence of housing problems 

in Tribal Areas. Probably most important is that physical problems (overcrowding and facility 

deficiencies) are considerably higher in two regions (Alaska and Arizona-New Mexico) than they 

are elsewhere. Though lower than in these two, overcrowding rates in the Tribal Areas of all 

other regions are still serious (much above the national averages for non-Indians) but the 

incidence of facility deficiencies is quite low in most other regions. 

The pattern with respect to affordability problems, however, appears to be almost the 

reverse of that for physical problems. Oklahoma, for example, which has by far the lowest share 

of its units overcrowded or with facility defiCiencies, has one of the highest shares with 

affordability problems. And the regions that have by far the lowest share of renters with 

affordability problems are Alaska and Arizona-New Mexico. 
Assessment of American Indian Housing Needs and Programs: Final Report 85 

THE IMPACT OF HUD HOUSING ASSISTANCE 

HUO's Housing Production Programs 

The Federal government began to provide substantial amounts of new housing 

construction in Tribal Areas in the mid-1960s. It has relied primarily on two programs: the Rental 

Program (essentially the national Public Housing program, implemented in Indian country with 

very little adaptation), and the Mutual Help Program (one of a very few Federal programs that 

have offered home-ownership to low-income families). (See complete descriptions in Chapter 4 

and 5). 

Table 3.5 shows the calculation of the number of AlAN occupied units provided by the 

Indian Housing Authorities (IHAs) under these programs in Tribal Areas in 1990 (at the time of 

the Census). Not all of the units in management in these programs are not occupied (Le., some 

are vacant) and some that are occupied are occupied by non-Indians. The calculations, in effect, 

subtract vacant and non-Indian occupied units from the totals (data from HUD's MTCS and MIRS 

systems--see Chapter 1). 

This contribution is indeed impressive. There were a total of 60,700 AlAN occupied IHA 

units in Tribal Areas in 1990. This means that these programs were serving 26 percent of all 

Tribal Area AlAN households and 42 percent of all Low Income AlAN households in Tribal Areas. 

These figures assume official Census totals. If adjustments are made to respond to the 

undercount discussed in Chapter 1, HUD programs were serving roughly 23 percent of all Tribal 

Area AlAN households and 37 percent of all Low Income AlAN households in Tribal Areas. 

Whichever calculation is used, this is a substantially higher rate of housing assistance than 

HUD typically has been able to provide to needy groups. In 1989, HUD provided assistance to 

about 4.1 million renter households nationally (1.4 million in public housing projects, 1.7 million 

in other assisted projects, and 1.0 million through Section 8 tenant-based assistance--Casey, 

1992)--only 22 percent of the total 18.9 million Low Income renters in the country at that time. 

Table 3.5 also shows that there is considerable variation in the distribution of this housing 

by region. HUD's contribution has been by far the highest in Tribal Areas of the Plains, 

California-Nevada, and North Central regions where 78 percent, 73 percent, and 64 percent of 

all Low Income AlAN households are served, respectively. At the other extreme, HUD units serve 

only 14 percent of all Low Income AlAN households in the. Tribal Areas of the South Central 

region, 27 percent in the Eastern Region, 32 percent in Oklahoma, and 33 percent in the ArizonaNew Mexico region. 
Assessment of American Indian Housing Needs and Programs: Final Report 86 

Table 3.5 

ESTIMATE OF AlAN OCCUPIED IHA HOUSING, 11190 AND 1994 

Reg. 1 Reg. 2 Reg. 3 Reg. 4 Reg. 5 Reg. 6 Reg. 7 Reg. 8 Reg. 9 

Total North· South· Ariz.· Calif.· Pacif. 

U.S. Central Eastern Okla. Central Plains N.Mex. Nev. No.west Alaska 

LOW RENT PROGRAM 

Units in Mgmt 1994 26,225 3,389 1,241 2,n8 174 9,051 6,346 1,320 1,582 344 

Bui" 1990·94 1,769 191 100 0 0 489 641 202 105 41 

Units in Mgmt 1990 24,456 3,198 1,141 2,778 174 8,562 5,705 1,118 1,4n 303 

% Occupied 

% AlAN Occupied 

95.0 

97.0 

95.0 

n.5 

80.0 

33.1 

70.0 

50.9 

95.0 

97.9 

91.0 

97.0 

93.0 

96.2 

96.0 

97.7 

91.0 

46.4 

AlAN Oce.Units 1990 20,097 2,947 840 736 62 7,963 5,036 1,000 1,385 128 

AlAN Occ.Units 1994 21,664 3,123 914 736 62 8,418 5,602 1,181 1,484 145 

MUTUAL HELP AND OTHER PROGRAMS 

Units in Mgmt 1994 47,847 1,355 2,071 14,666 387 7,114 11,258 3,257 2,787 4,952 

Bui" 1990-94 4,910 179 221 920 20 518 1,615 486 430 521 

Units in Mgmt 1990 42,937 1,176 1,850 13,746 367 6,596 9,643 2,771 2,357 4,431 

% Occupied 92.3 99.7 96.6 96.3 92.8 95.8 96.7 99.0 98.0 

% AlAN Occupied 99.4 99.4 97.8 93.0 98.5 99.3 99.2 98.4 96.4 

AlAN Occ.Units 1990 40,564 1,079 1,834 12,980 329 6,031 9,172 2,657 2,296 4,186 

AlAN Occ.Units 1994 45,221 1,244 2,053 13,849 347 6,504 10,708 3,123 2,715 4,678 

TOTAL AlAN OCC. IHA UNITS (000) 

AlAN Oce.Units 1990 60.7 4.0 2.7 13.7 0.4 14.0 14.2 3.7 3.7 4.3 

AlAN Occ.Units 1994 66.9 4.4 3.0 14.6 0.4 14.9 16.3 4.3 4.2 4.8 

AlAN HOUSEHOLDS, TRIBAL AREAS (000) 

Total 1990 234.4 8.6 17.6 86.6 4.9 25.4 57.9 7.1 13.2 13.1 

Low Income 1990 144.3 6.3 9.8 43.2 2.8 17.9 42.6 5.0 7.9 8.7 

Tolal1994 264.8 9.5 21.4 100.3 6.0 27.6 63.3 7.7 14.6 14.4 

PERCENT SERVED BY IHA PROGRAMS 

Total 1990 25.9 46.8 15.2 15.8 8.0 55.2 24.5 51.8 28.0 32.9 

Low Income 1990 42.0 84.3 27.3 31.7 13.7 78.0 33.3 72.5 46.7 49.7 

Total 1994 25.3 46.0 13.9 14.5 6.8 54.1 25.8 55.9 28.8 33.5 

Housing Problems in Assisted vs. Unassisted Units 

Reliable data on the incidence of housing problems in HUD-assisted units are not 

available. However, crude estimates can be made using the sample household survey data. The 

data were assembled in accordance with the framework of standards defined in Figure 3.2 for 

those units in the sample that were HUD-assisted. The results were that about 14,600 of all 

HUD-assisted units (24 percent) were either overcrowded and/or had physical deficiencies. By 

subtraction from the totals, this would imply that 79,200 unassisted units (or 45 percent of the 
Assessment of American Indian Housing Needs and Programs: Final Report 87 

total unassisted stock) had such problems.31 In comparison, there were about 84,200 Low 

Income households in Tribal Areas that did not live in HUD-assisted units. We know that 

sampling error implies a fairly large range of uncertainty around these estimates of physical 

problems. However, they do indicate at the very least, that a very high proportion of all LowIncome households in Tribal Areas that do not now receive HUD assistance have very serious 

housing problems. 

DIVERSITY IN HOUSING PROBLEMS ACROSS TRIBAL AREAS 

Analysis 

As was noted in Chapter 2, regional variations tell us something about Tribal Area 

diversity, but they by no means explain it all. To provide a better understanding, the same type 

of regression approach has been used to test the relationship between the key variables identified 

in Chapter 2 and the extent of Tribal Area housing problems. 

The evidence above suggests that the share of all units with one or more problems is not 

likely to be a meaningful aggregate for these purposes, since it is made up of two very different 

types of conditions that seem to behave in opposing directions: where the incidence of 

overcrowding and physical deficiencies is high, the share with pure affordability problems seems 

to be low, and vice versa. 

Accordingly, two separate analyses were run. In the first, the dependent variable was the 

share of all units overcrowded and/or with physical deficiencies, and in the second, the dependent 

variable was the share of all households whose only housing problem is affordability. 

Both analyses used the same independent variables. The first two are those that proved 

to be highly significant in the analyses in Chapter 2: (1) the log of the distance between the Tribal 

Area and the nearest large urban area; and (2) the ratio of total population to AlAN population. 

Others included were: (3) PPSE employment per 1,000 population; and (4) the population size 

of the Tribal Area. 

The first regression explained 37 percent of the variance in the share overcrowded and/or 

with facility deficiencies. Both the PPSE and the distance variables were significant at the 99 

I 

31This estimate is based on official Census housing stock counts. If adjustment is made to compensate for the 

undercount discussed earlier, the estimated number of unassisted units overcrowded and/or with serious physical 

deficiencies increases from 79,200 to 90,600. As to the question of sampling error around these numbers, the reader 

should consult the footnote related to estimates of total housing problems in Tribal Areas earlier in this chapter. 
Assessment of American Indian Housing Needs and Programs: Final Report 88 

percent level, and the population size variable at the 95 percent level. The ratio of total to AlAN 

population was less so (level of 0.2615). All signs were as expected. The share with these 

physical problems tends to increase the greater the distance from a large urban center and the 

smaller the ratio of total to AlAN population, the level of PPSE employment, and the total 

population of the area. (See Annex 3A at the end of this chapter). 

The second regression was not as strong (explaining 17 percent of the variation in the 

affordability share), but all independent variables were significant at the 99 percent level, except 

for population size (0.154). And, as expected, the signs were the reverse of those found in the 

analysis above. Affordability problems tend to decrease the greater the distance from a large 

urban center and the smaller the ratio of total to AlAN population, the level of PPSE employment, 

and the total population of the area. (See Annex 38). 

These analyses strongly suggest that proximity to an urban center and a private 

employment base are closely linked to lower levels of physical housing problems. There is a 

tendency for severe housing problems to be closely associated with isolation and inadequate 

employment opportunities. 

The Typology and Housing Problems and Needs 

Again, to illustrate the contrasts between different types of Tribal Area environments, this 

section returns to the typology developed in Chapter 2--this time to examine differences in 

housing problems and needs in the various groups it defines. Table 3.6 shows the distribution 

of housing units by group and type of housing problem in percentage terms. Results are as 

anticipated, given the regression analysis above. 

Total overcrowding and/or facility problems were highest in the Navajo reservation (78 

percent) and Alaska (71 percent), still high in other areas that were not Large, Open, or Near 

Urban (47 percent), and much lower in all other types of areas. 

Affordability problems were highest in all groups in the Near Urban category and the 

Large Open Tribal Areas that were more remote (averaging around 20 percent), and lowest in 

Navajo (5 percent), Alaska (8 percent) and others in the remote category (15 percent). 

All housing problems. The pattern for the totals of these two categories resembles that 

for the incidence of overcrowding and/or facilities, but the variations are not as extreme. 

Housing problems for Very Low-Income Groups. VLI shares tend to be higher in the 

more remote Tribal Areas as does the total incidence of housing problems. It is not surprising 

then that these areas rank highest when both indicators are combined. On the Najavo 
Assessment of American Indian Housing Needs and Programs: Final Report 89 

Table 3.6 
 

MARKET TYPOLOGY OF TRIBAL AREAS, HOUSING PROBLEMS (Pel of households) 
 

HOUSEHOLDS WITH HOUSING PROBLEMS 

All Households Low-Income Households Very Low-lnc.Households 

Total C.F.and Afford. C.F.and Afford. C.F.and Afford. 

Hsehlds Total O.C. only Total O.C. only Total O.C. only 

NEAR URBAN AREAS 
 

Large-Open 
 

Strong Priv.Empl. 

Oklahoma 100.0 28.5 7.1 21.4 23.3 4.7 18.6 17.6 3.2 14.4 

Other 100.0 39.7 15.0 24.6 33.9 11.5 22.5 25.3 7.6 17.7 

Sublotal 100.0 29.7 8.0 21.8 24.5 5.4 19.0 18.4 3.7 14.8 

Lower Priv.Empl. 100.0 35.7 14.5 21.2 29.2 10.3 18.9 24.0 7.3 16.7 

Total 100.0 30.7 9.0 21.7 25.2 6.2 19.0 19.3 4.2 15.1 

Other 

Strong Priv.Empl. 100.0 32.5 12.0 20.6 26.1 7.0 19.1 20.4 4.0 16.4 

Lower Priv.Empl. 100.0 43.0 29.0 14.0 36.6 22.7 13.8 29.3 16.2 13.1 

Total 100.0 38.7 22.0 16.7 32.2 16.2 16.0 25.7 11.2 14.5 

Total 100.0 32.9 12.6 20.3 27.1 9.0 18.2 21.1 6.1 14.9 

REMOTE 

Large-Open 

Strong Priv.Empl. 100.0 31.2 8.7 22.4 26.4 6.1 20.3 20.5 4.2 16.3 

Lower Priv.Empl. 100.0 36.9 16.7 20.2 32.8 13.6 19.3 27.3 9.7 17.6 

Total 100.0 32.8 11.0 21.8 28.3 8.2 20.0 22.5 5.8 16.7 

Navajo 100.0 77.8 73.0 4.8 63.3 58.8 4.5 51.7 47.5 4.2 

Other 

Strong Priv.Empl. 100.0 34.8 23.4 11.4 27.8 16.4 11.4 22.0 11.6 10.4 

Lower Priv.Empl. 100.0 47.6 31.0 16.6 40.7 24.5 16.2 33.6 18.8 14.8 

Total 100.0 46.7 30.5 16.2 39.8 24.0 15.9 32.9 18.3 14.5 

Total 100.0 51.4 36.7 14.7 43.0 29.2 13.8 35.0 22.9 12.1 

ALASKA 100.0 70.7 63.1 7.6 53.2 46.7 6.6 43.0 36.9 6.1 

TOTAL 100.0 44.4 27.6 16.7 36.6 21.3 15.3 29.4 16.3 13.0 

reservation, over half (52 percent) of all households are VLI households with housing problems. 

The comparable share is 43 percent in Alaska, and 33 percent for others that are remote but not 

Large and Open. The comparable share is only 4 percent in Areas that are Near Urban, Large, 

and Open. 
Assessment of American Indian Housing Needs and Programs: Final Report 90 

VARIATIONS IN THE HOUSING PROBLEMS OF URBAN INDIANS 

Contrasts in Housing Conditions for Urban Indians 

As shown in Table 3.7, there are some important contrasts between central city and 

suburban AlAN households with respect to key housing problem indicators in the 15 selected 

MSAs. First, affordability problems in these MSAs are particularly high, affecting 37 percent of 

all AlAN households in the central cities, and 39 percent in the suburbs, on average. In both 

cases, AlAN rates are substantially higher than those for non-Indians in the same environments. 

Second, there is a larger gap locationally, with respect to overcrowding. The overcrowding 

rate for Indians is significantly higher in the central cities (13 percent) than in the suburbs, but 

again, both are much above the comparable rates for non-Indians. 

With respect to shares living in older housing (built in 1949 or earlier), the pattern is 

reversed. In almost all MSAs, central cities have a much larger proportion of older housing than 

the suburbs. But for Indian renters, a higher share of suburban residents live in older units (53 

percent) than city residents (42 percent). In contrast, a smaller share of homes owned by Indians 

in the suburbs is in this age category (16 percent) than is true for non-Indians (21 percent). 

Homeless and Access to Housing Assistance in Urban Areas 

Two aspects of housing problems are more serious for urban Indians than for those who 

live in Tribal Areas. The first is homelessness. Our site surveys indicate that in Tribal Areas, the 

lack of sufficient housing is reflected in overcrowding rather than actual homelessness: i.e., 

virtually all people who have no shelter of their own are taken in by relatives or other tribal 

members. Homelessness per se is a serious problem, however, for the AlAN population in urban 

areas. The survey generally considered the most reliable (see Burt, 1992) indicates that AlAN 

individuals account for 2.3 percent of all homeless people nationally. This translates into an 

incidence rate three times that of the population as a whole. 

The second problem is the low access of poor AlAN urban families to the housing 

assistance programs made available to the general population. In our 15 selected MSAs, very 

low-income groups account for from 23 percent to 44 percent of all AlAN households. Yet the 

number of such households in public housing ranges from none to only 3.5 percent of those in 

the VLI group. This result may be explained in part by the aversion of Indians to public housing, 

but it also appears that public housing authorities have not yet given high priority to outreach and 

education or other program initiatives, so as to better serve eligible Indian families. 
Assessment of American Indian Housing Needs and Programs: Final Report 91 

Table 3.7 
 

Urban Indians: Housing Problems 
 

Percent Percent RatioAIANI 

Indicator AlAN Non-AlAN non-AlAN 

Affordability Problem 

Central Cities 37% 29% 1.3 

Suburbs 39% 21% 1.9 

Overcrowding 

Central Cities 13% 4% 3.3 

Suburbs 10% 2% 5.0 

Unit Built 1949 or earlier, Renters 

Central Cities 42% 38% 1.1 

Suburbs 53% 14% 3.8 

PROSPECTS AND POLICY IMPLICATIONS 

Prospects 

The first question here is how rapidly the number of AlAN households is likely to grow 

overall and in different parts of this country; i.e., where are the pressures for new housing likely 

to be greatest and to what extent? While preparing a serious "forecast" of these changes was 

beyond the scope of this study, a rough approximation was made by assuming rates of total AlAN 

population growth based on Bureau of the Census (1993) estimates, a spatial distribution of that 

growth similar to that observed in the 1980s, and rates of decline in population per household 

ratios also similar to what was experienced in the 1980s (see Kingsley, Mikelsons, and Herbig, 

1995). 

Results are summarized in Table 3.8. They show the national AlAN population growing 

from 2.0 million in 1990 to 2.15 million in 1994 and to 2.4 million at the end of the century. By 

that time, there will be only modest shifts in the spatial distribution. The Tribal Area share will 

have increased from 60 percent to 63 percent, and the Surrounding County share, from 37 

percent to 38 percent. The shares in the rest of the U.S. will have declined (from 31 percent to 

30 percent for other Metropolitan Areas and from 10 percent to 8 percent for other 

Nonmetropolitan Areas). 
Assessment of American Indian Housing Needs and Programs: Final Report 92 

Tabla3.S 

ILLUSTRATIVE ESTIMATES-AlAN POPULATION GROWTH THROUGH 2000 

AlAN COUNTIES REST OF U.S. 

Total Tribal Surr. NonU.S. Total Areas Co. Total Metro. Metro. 

POPULATION (000) 

1980 (Apr.) 1,528.4 826.2 531.2 295.0 702.1 500.5 201.6 

1990 (Apr.) 2,009.5 1,201.3 739.8 461.5 808.2 617.6 190.6 

1994 (Jan.) 2,150.0 1,310.8 800.6 510.2 839.2 651.8 187.4 

2000 (Apr.) 2,400.0 1,505.7 909.0 596.7 894.3 712.6 181.7 

PERCENT OF U.S. POP. 

1980 (Apr.) 100.0 54.1 34.8 19.3 45.9 32.7 13.2 

1990 (Apr.) 100.0 59.8 36.8 23.0 40.2 30.7 9.5 

1994 (Jan.) 100.0 61.0 37.2 23.7 39.0 30.3 8.7 

2000 (Apr.) 100.0 62.7 37.9 24.9 37.3 29.7 7.6 

POP. GROWTH PER YEAR (000) 

1980-1990 48.1 37.5 20.9 16.7 10.6 11.7 -1.1 

1990-1994 37.5 29.2 16.2 13.0 8.3 9.1 -0.9 

1994-2000 38.5 30.0 16.7 13.3 8.5 9.4 -0.9 

PERCENT OF U.S NET INCREASE 

1980-1990 100.0 78.0 43.4 34.6 22.1 24.3 -2.3 

1990-1994 100.0 77.9 43.3 34.7 22.1 24.3 -2.3 

1994-2000 100.0 78.0 43.4 34.6 22.0 24.3 -2.3 

TOTAL POPULATION PER HOUSEHOLD 

1990 (Apr.) 2.47 2.84 3.16 2.46 2.07 2.07 2.06 

1994 (Jan.) 2.44 2.75 2.98 2.45 2.06 2.07 2.06 

2000 (Apr.) 2.36 2.59 2.70 2.45 2.05 2.06 2.05 

NO. OF HOUSEHOLDS (000) 

1990 (Apr.) 812.4 422.3 234.4 187.9 390.2 297.7 92.5 

1994 (Jan.) 882.7 476.3 268.6 207.7 406.4 315.3 91.1 

2000 (Apr.) 1,015.8 580.6 337.3 243.3 435.2 346.6 88.6 

HOUSEHOLD GROWTH PER YEAR (000) 

1990-1994 18.7 14.4 9.1 5.3 4.3 4.7 -0.4 

1994-2000 20.5 16.0 10.6 5.5 4.4 4.8 -0.4 

PERCENT OF U.S. NET INCREASE 

1990-1994 100.0 76.8 48.6 28.2 23.0 25.0 -2.0 

1994-2000 100.0 78.4 51.6 26.7 21.6 23.5 -1.9 

Tribal Areas, however, will exhibit a more substantial growth in total households (both 

because they continue to receive a large share of all national AlAN population growth and 

because their average household size is declining more rapidly). Tribal Areas in total will have 

to accommodate about 10,000 new households per year over the decade, compared to 5,400 in 
Assessment of American Indian Housing Needs and Programs: Final Report 93 

the Surrounding Counties and 4,800 in other Metropolitan Areas. Other Nonmetropolitan Areas 

will continue to suffer a decline in households (by about 400 per year). 

We expect substantial variations in growth by region. The annual number of new 

households to be accommodated would be highest in the Eastern region (5,000), followed by 

Oklahoma (4,500) and Arizona-New Mexico (2,900). All other regions could expect household 

growth increments of less than 2,000 per year. 

In Tribal Areas in 1990, 62 percent of all households were low-income and the data show 

that at least 60 percent of them were overcrowded or lived in units with serious physical 

deficiencies even as defined by Census measures. A perpetuation of those shares through the 

1990s would imply that the number of low-income households in Tribal Areas would grow on 

average by 6,200 per year, and the number overcrowded and with facility problems would grow 

by about 3,700 per year. Yet from 1990 to 1994, the number of HUD units in Tribal Areas 

occupied by AlAN households grew by only about 1,700 per year. We cannot be sure the same 

proportions will hold throughout this decade, but it does seem very likely that HUD assistance is 

falling very short of what is needed even to keep up with the growth of housing problems in Tribal 

Areas. 

For low-income AlAN households outside of Tribal Areas, it is extremely difficult to 

speculate on how their housing problems are likely to change over this decade under current 

policies. In general, U.S. housing problems in the mid-1990s are similar to those discussed 

earlier in this chapter. Affordability problems continue to dominate. The percentage of units with 

physical housing deficiencies still remains at a low level, and while vacancy rates are unusually 

high in many markets, rents and home values continue at high levels as well. We see no reason 

to believe that the housing problems of AlAN households living in metropolitan environments are 

improving through the natural evolution of the private housing market. Federal housing 

assistance grew somewhat during earlier parts of the decade, but not enough to have much effect 

on the sizeable gap between the number provided for and the number eligible. 

Policy Implications 

Part II of this report will assess existing Federal housing assistance programs operating 

in Indian country and Part III will consider policy alternatives. The findings of Part I suggest 

several themes that orient the work in both areas. 

1. 	 The data show that the housing problems of American Indians and Alaska natives 

remain considerably more severe than those of non-Indians in all parts of America. 

This finding simply underscores the importance of the tasks taken on in the 

remainder of this report. 
Assessment of American Indian Housing Needs and Programs: Final Report 94 

2. 	 Given that the housing problems of low-income families in Tribal Areas are both 

deeper and more pervasive than those for Indians living elsewhere, those Areas 

should justifiably remain the focus for national Indian housing policy. From the 

numbers presented above, it seems quite likely that the housing problems of those 

Areas are getting worse in the 1990s. The production rate of HUD housing for 

Tribal Areas appears considerably below than what would be needed to keep up 

with the growth, let alone begin to address the enormous backlog of deficient units 

that existed when the decade began. Accordingly, Federal housing assistance in 

Tribal areas is the central focus for analysis in Parts II and III. 

3. 	 Perhaps the most dramatic contrast presented in this review is that between those 

who are and are not served by HUD housing assistance at this point. Forty 

percent of the households in need in Tribal Areas are receiving very substantial 

subsidies. The remaining 60 percent, many with extremely serious housing 

deficiencies, receive no assistance whatsoever. A key theme in examining present 

programs and considering alternatives, should revolve around the question of 

whether and how this inequity can best be addressed. 

4. 	 One of the strongest findings of Part I has been the diversity of economic, social, 

and housing conditions that exists across Tribal Areas. This diversity suggests 

that, if they are to be both equitable and efficient, local housing strategies cannot 

be uniform. For example, an Area next to a large city will have different 

opportunities for housing delivery than a remote reservation. Even two Tribal 

Areas in similar locations are likely to have a different mix of housing needs and 

opportunities--programs that provide highly efficient and effective incentives for 

housing improvement in one, may not work in another because of cultural, political, 

or economic reasons. Existing programs, and future alternatives, should be 

assessed in relation to how well they can respond to these realities. 

5. 	 The overwhelming housing problem of the AlAN population outside of Tribal Areas 

is affordability, rather than phYSical deficiencies. This suggests the need for an 

approach to housing assistance in those locations that gives primary recognition 

to this need. 

6. 	 Increasing homeownership among AlAN households does appear to be a realistic 

prospect that warrants more attention at the national level; 48 percent of all AlAN 

households nationally are in the moderate and higher income ranges (incomes 

above 80 percent of the local median) but ownership rates for these groups are 

significantly below those of non-Indians at similar income levels in most parts of 
Assessment of American Indian Housing Needs and Programs: Final Report 95 

the country. Examination of prospects for expanding private mortgage lending in 

Indian country is clearly called for as a part of the search for more effective Indian 

housing policy. 

REFERENCES 

AICAE et al. (American Indian Council of Architects and Engineers, the Design Arts Program of 

the National Endowment for the Arts, and the Office of Native American Programs of the 

U.S. Department of Housing and Urban Development). 1992. Our Home: Giving Form 

to Traditional Values. Washington, D.C.: U.S. Department of Housing and Urban 

Development. 

American Public Health Association. 1967. APHA-PHS Recommended Housing Maintenance 

and Occupanc,y Ordinance. Washington, D.C.: U.S. Department of Health, Education, and 

Welfare. 

Baer, William C. 1976. "The Evolution of Housing Indicators and Housing Standards: Some 

Lessons for the Future." Public Policy. Vol. 24, No.3, Summer. 

Bureau of the Census. 1967. Measuring the Quality of Housing: An Appraisal of Census 

Statistics and Methods. Washington, D.C.: Government Printing Office. 

Bureau of the Census. 1993. Current Population Reports: Population Projections of the United 

States by Sex, Race, and Hispanic Origin: 1993 to 2050. Washington, D.C.: U.S. 

Department of Commerce. 

Bums, Leland. 1970. Housing: Symbol and Shelter. Los Angeles: University of California, 

Graduate School of Business Administration. 

Burt, Martha. 1992. Over the Edge: The Growth of Homelessness in the 1980s. New York: 

Russel Sage Foundation. 

Casey, Connie H. 1992. Characteristics of HUD-Assisted Renters and Their Units in 1989. 

Washington, D.C.: Office of Policy Development and Research. U.S. Department of 

Housing and Urban Development. 

Driver, Harold E., and William C. Massey. 1957. "Comparative Studies of North American 

Indians." Transactions of the American Philosophical Society. Vol. 47, Part 2. July. 
Assessment of American Indian Housing Needs and Programs: Final Report 96 

Housing Assistance Council. 1992. A Report on the Bureau of Indian Affairs' Consolidated 

Housing Inventory. Washington, D.C.: Housing Assistance Council. 

HUD (U.S. Department of Housing and Urban Development. 1994. Worst Case Needs for 

Housing Assistance in the United States in 1990 and 1991. Washington, D.C.: U.S. 

Department of Housing and Urban Development. June. 

Jett, Stephen C. and Virginia E. Spencer. 1981. Navajo Architecture: Forms, History, 

Distributions. Tucson: University of Arizona Press. 

Kingsley, G. Thomas. 1991. "Housing Vouchers and America's Changing Housing Problems," 

in William T. Gormley, ed. Privatization and Its Alternatives. Madison: The University of 

Wisconsin Press. 

Kristof, Frank S. 1968. Urban Housing Needs Through the 1980's: An Analysis and Projection. 

Prepared for the National Commission on Urban Problems, Research Report No. 10. 

Washington, D.C.: Government Printing Office. 

National Commission on American Indian, Alaska Native and Native Hawaiian Housing. 1992. 

Building the Future: A Blueprint for Change. Washington, D.C.: National Commission on 

American Indian, Alaska Native and Native Hawaiian Housing. June. 

_______. 1993. Supplemental Report and Native American Housing Improvements 

Legislative Initiative. Washington, D.C.: National Commission on American Indian, Alaska 

Native and Native Hawaiian Housing. January. 

Office of Indian Housing. 1993 The Indian Housing Program: The History and Current Status of 

Indian Housing in the United States. Washington, D.C.: U.S. Department of Housing and 

Urban Development. 

Office of Native American Programs. 1994. Native American Programs Annual Report, 1993. 

Washington, D.C.: U.S. Department of Housing and Urban Development. January. 

Stone, Michael E. 1993. Shelter Poverty: New Ideas on Housing Affordability. Philadelphia: 

Temple University Press. 

Struyk, Raymond J., Margery A. Turner, and Makiko Ueno. 1988. The Future of U.S. Housing 

Policy: Meeting the Demographic Challenge. Urban Institute Report 88-2. Washington, 

D.C.: The Urban Institute. 
Assessment of American Indian Housing Needs and Programs: Final Report 97 

United Nations. 1967. Methods of Estimating Housing Needs. (ST/STAT/SER.F/12). New York: 

United Nations. 

Wilner, Daniel et al. 1962. Housing Environment and Family Life. Baltimore: Johns Hopkins 

Press. 
Assessment of American Indian Housing Needs and Programs: Final Report 98 

Annex 3A 
 

Multiple Regression Analysis 1 
 

Dependent Variables: 

Independent Variables: 

Variation 

R-Square: 

Standard Error: 

Analysis of Variance 

Degrees of Freedom: 

Mean Dep. Variable: 

F Value: 

Probability> F: 

OPROB 

SHARE 

PPSE 

PSIZE 

LNDIS50 

36.70 

28.31 

4 

40.00 

72.75 

.0001 

Variable: Parameter Est.: 

INTERCEPT -1.73 

SHARE -0.08 

PPSE -1.08 

PSIZE -5.78 

LNDIS50 11.76 

Other Than Affordability Problem For AlAN 

Households, (Overcrowding/Facility Mix), AlAN Area 

Ratio Of Total Tribal Area Population To AlAN 

Population 

Private For-Profit and Self-Employed Persons 

Per 1,000 Persons 

If AlAN Area Population Greater Than 400 Persons, 

PSIZE =1, 0 Otherwise 

Natural Log Of Distance From AlAN Area To Nearest 

Urban Place Of 50,000 Or More Persons 

Std. Error: T for HO: Prob.> ITI: 

6.24 -0.27 .7819 

0.07 -1.12 .2615 

0.Q1 -6.70 .0001 

2.67 -2.16 .0312 

1.09 10.70 .0001 
Assessment of American Indian Housing Needs and Programs: Final Report 99 

Annex 38 
 

Multiple Regression Analysis 
 

Dependent Variables: 
 

Independent Variables: 
 

Variation 

R-Square: 

Standard Error: 

Analysis of Variance 

Degrees of Freedom: 

Mean Dep. Variable: 

F Value: 

Probability> F: 

AFFORD 
 

SHARE 
 

PPSE 
 

PSIZE 
 

LNDIS50 
 

17.63 

12.34 

4 

12.38 

26.86 

.0001 

Variable: Parameter Est.: 

INTERCEPT 17.65 

SHARE 0.11 

PPSE 0.02 

PSIZE 1.66 

LNDIS50 -2.11 

Affordability Problem For AlAN Households, AlAN Area 

Ratio Of Total Tribal Area Population To AlAN Population 

Private For-Profit and Self-Employed Persons Per 1,000 

Persons 

If AlAN Area Population Greater Than 400 Persons, 

PSIZE =1, 0 Otherwise 

Natural Log Of Distance From AlAN Area To Nearest 

Urban Place Of 50,000 Or More Persons 

Std. Error: T for HO: Prob.> ITI: 

2.72 6.48 .0001 

0.03 3.51 .0005 

0.00 5.00 .0001 

1.16 1.42 .1539 

0.47 -4.40 .0001 

PART II 
 

PROGRAM ASSESSMENT 
 
Chapter 4 

AMERICA AND INDIAN HOUSING POLICY: 

BACKGROUND AND APPROACH TO 

ASSESSMENT 

Part II of this report is an assessment of current Federal Indian housing programs and 

policies, focusing on the programs operated by the U.S. Department of Housing and Urban 

Development (HUD). In this chapter, we provide background information needed as a basis for 

interpreting the findings: the story of how Indian housing emerged from America's broader policies 

affecting American Indians and Alaska Natives, a description of the programs that will be 

assessed (hOW they work), and data on levels at which they have been budgeted of late to give 

a sense of their comparative magnitudes. We then review the approach taken in this 

assessment. The assessment itself is presented in Chapters 5 and 6. 

FOUNDATIONS OF AMERICA'S INDIAN HOUSING POLICY 

The history of American Indian housing policy dates from the latter developments of 

termination and reform. Even though the 1921 Snyder Act had authorized the BIA to provide a 

broad range of assistance programs in Tribal Areas, it took many years before the Federal 

government seriously addressed the housing problems of Indian country. The United States 

Housing Acts of 1937,1949 and subsequent amendments, had established as a goal decent, safe 

and sanitary housing for all Americans and initiated various housing assistance programs to 

achieve that goal, but even as these new programs were mounted, Indian families in remote 

areas were given little access to them. 

It was not until 1961 that an Interior Department task force recognized that Indians on 

reservations and other Indian areas fell far behind the majority of Americans in realizing decent, 

safe, and sanitary housing. In that year, the Office of General Council in the Public Housing 

Administration (later to become a part of HUD), in collaboration with the Bureau of Indian Affairs, 
Assessment of American Indian Housing Needs and Programs: Final Report 101 

Administration (later to become a part of HUD), in collaboration with the Bureau of Indian Affairs, 

determined that American Indian tribal governments were eligible "municipalities" with respect to 

participation in the rental assistance program authorized by the 1937 Housing Act. In 1962, the 

Mutual Help Homeownership Program was created as a program designed specifically to meet 

Indian housing needs.32 The administration of both the Rental and Mutual Help programs were 

transferred to HUD when that agency was created in 1965. 

The design of the Mutual Help Program was unique. A "self-help" approach was 

envisioned which would instill pride of participation and enhanced owner involvement. It was also 

believed that the program would serve a greater number of Indian families than the low rent 

program at a lower cost. Contributions of land, labor or materials would reduce the amount of 

subsidy needed and the participant's maintenance of the unit would likewise reduce the need for 

Federal outlays. When Mutual Help was initiated, utility costs were low, and the Rental Program 

required fixed rents which were higher than the requirement for Mutual Help. The plan for Mutual 

Help was for the family's monthly contribution to go into an operation and maintenance account 

which, if not fully used, would go to payoff the unit, thus allowing the family to obtain 

homeownership. In essence, Mutual Help was to be a lease/purchase program for low-income 

Indian families. 

The Bureau of Indian Affairs (BIA) worked closely with the Public Housing Administration 

in the development of Indian housing programs. The BIA actually played a direct role in the field 

administration of the Rental and Mutual Help programs in their early years as IHA and HUD 

capacity was being developed. The BIA had the statutory authority to develop its own housing 

assistance program since the 1921 Snyder Act, but never took advantage of it until 1965 when 

it established its Housing Improvement Program (HIP). HIP was initiated then primarily as a 

response to the devastating South Dakota floods of 1964. The program was set up to serve only 

the "neediest" Indians, and it has always been very small in relation to HUD's programs in Indian 

country. 

In addition, some Indians living in Indian areas have received housing assistance from the 

Farmers Home Administration (FmHA), the Veterans Administration, and a few other sources such 

as tribal credit programs. Initially, the Indian Health Service (IHS) of the Department of Health, 

Education and Welfare provided water and sanitation facilities in support of Indian housing and 

communities. Today, water and sewer services for HUD-funded housing are developed by the 

Indian Housing Authorities (IHAs) that administer HUD programs in the field. In addition, the BIA 

provides land acquisition/leasing services and maintenance services for roads. 

32 Mutual Help was created administratively as an ahernative mechanism under existing law rather than by a 

separate act of Congress. In 1988, it was codified under a separate statute. 
Assessment of American Indian Housing Needs and Programs: Final Report 102 

At HUD, Indian housing programs were administered simply as a part of the public housing 

program until the mid-1970s when HUD created the separate Office of Indian Housing. In 1976, 

the first Indian housing regulations were published as separate from the regulations for public 

housing. This move, acknowledged that (in particular due to tribal jurisdiction and the land tenure 

arrangements discussed in Chapter 1) problems in Indian housing were unique and required 

different solutions than general public housing programs. 

The 1970s were the decade of maximum allocation of funds for the development of Indian 

housing units. A major effort began in 1969 with an Interdepartmental Memorandum of 

Understanding among HUD, BIA and IHS setting a goal to produce 40,000 units from 1970 

through 1974 (HUD alone was to produce 6,000 units per year). While that goal was never met, 

nearly 25,000 units were built in Indian Country during the period (General Accounting Office, 

1978). The Memorandum of Understanding served as a policy statement intended to increase 

the production of Indian housing. 

In 1974, a special program to develop units in Alaska was initiated, again through the joint 

efforts of HUD, BIA and IHS. However, problems specific to Alaska housing development 

surfaced. In particular, due to the remoteness of most villages and the extreme climate, the costs 

of developing and operating housing with sanitation facilities were extremely high in relation to 

those elsewhere. 

While problems of interagency coordination have surfaced throughout the evolution of 

Indian housing programs, the 1969 Memorandum of Understanding was subsequently updated 

to address those issues. It dealt with production processes, differences in budget cycles, 

communication and responsibilities. Another effort of the 1970s was the beginning of training 

programs for IHA staff and homebuyers. 

In reality, in order to address a pressing need, an Indian housing program was created 

very quickly, attempting to deliver large numbers of housing units where no such program had 

existed before, with no administrative infrastructure existing at the local level. Housing programs 

also brought additional responsibilities to tribal governments who themselves were in a process 

of developing their own legal and institutional structures, such as tribal courts. 

In 1978, the General Accounting Office published the report, Substandard Indian Housing 

Increases Despite Federal Efforts: A Change Is Needed, which assessed problems in the delivery 

of Indian housing assistance. It described the findings from various sources which supported the 

conclusions that existing Indian housing programs were not successful because they were 

underfunded, had not received enough attention, required too many complex procedures, lacked 

flexibility, required more trained personnel, and had coordination problems. Numerous 

altematives were suggested including administratively changing the existing programs, creating 
Assessment of American Indian Housing Needs and Programs: Final Report 103 

special programs for Indian housing using different criteria than those used for other programs, 

and consolidation of all Indian housing programs into one Federal agency. No major program 

changes were initiated, however, directly as a result of this report. 

The early 1980s ushered in a more austere era for Indian housing, as it did for many other 

housing programs. The first Reagan administration budget recommended a final appropriation 

for Indian housing units in FY1982, and then a closeout of the HUD Indian housing program. 

Congress rejected that proposal but limited HUD's Indian housing production to 2,400 units in that 

year. In 1982 and 1983, the Indian Affairs staff of the House Committee on Interior and Insular 

Affairs, in consultation with Congressional, agency and Indian groups, drafted legislation providing 

for a new Indian housing program in the Bureau of Indian Affairs to replace the existing HUD 

programs. While passed out of Committee favorably, the proposed legislation was never brought 

to the floor for a vote. Backers of the existing programs strongly opposed that initiative as they 

did Administration proposals for block grant funding of Indian housing. 

In response, HUD formed a "Secretary's Committee on American Indian and Alaska Native 

Housing" to advise the Secretary on major Indian housing issues. This reflected President 

Reagan's official Indian Policy Statement which declared that strong, effectively functioning tribal 

governments were needed to improve the social and economic conditions of Indians. This policy 

reiterated that of the Nixon administration Indian policy to encourage and strengthen tribal 

governments consistent with the Indian Self-Determination and Education Assistance Act. 

A major recommendation of the Secretary's Committee was the separation of the Indian 

Housing Program from the Public Housing Program. While the Administration did not promote 

this initiative, Congress took the lead in separating the programs by passing the "Indian Housing 

Act of 1988" which, for the first time, established a statutory commitment to the provision of Indian 

housing assistance outside of the general framework of the 1937 act. Concurrently, HUD was 

developing consolidated regulations for Indian housing. These two actions were major steps in 

recognizing the need for a distinct approach to Indian housing problems. 

Since then, HUD has implemented several initiatives (discussed in more depth later in this 

chapter) to improve efficiency and service to Native Americans. In addition, in 1989, Congress 

designated a National Commission on American Indian, Alaska Native and Native Hawaiian 

Housing to investigate the status of native housing and recommend solutions to the housing 

problems of native people. After extensive hearings, site visits and discussions throughout Indian 

Country and Hawaii, the Commission reported its findings in a 1992 report entitled, Building the 

Future: A Blueprint for Change. In September 1993, the Commission concluded its activities with 

the publication of its final report and recommendations: Supplemental Report and Native 

American Housing Improvements Legislative Initiative. Many of the administrative changes 

recommended by the Commission have been implemented by HUD. In addition, HUD has 
Assessment of American Indian Housing Needs and Programs: Final Report 104 

revised its program regulations to significantly reduce and simplify operating rules and provide 

much more flexibility to local problem implementers. 

THE CURRENT PROGRAMS AND HOW THEY WORK 

Program Framework 

As noted, while the BIA was empowered through the Snyder Act to provide a broad range 

of social, economic, and educational assistance to American Indians in 1921, it was not until 40 

years later that the federal government began to provide significant resources for Indian housing 

needs. 

The Federal government now offers a broad array of housing assistance programs in 

Tribal Areas. It is helpful to view them in a framework in which they are categorized into four 

basic types: (1) production programs; (2) tenant-based assistance; (3) block grants; and (4) 

financing assistance. In summary, they work as follows: 

• 	 PRODUCTION PROGRAMS. In these programs, Federal funds support the 

construction, acquisition, and rehabilitation of housing specifically for low-income 

households and may also cover part of the subsequent costs of operating that 

housing. Major programs of this type include: 

• 	 HUD's Rental Program--essentially the national Public Housing program, 

implemented in Indian country with very little adaptation. HUD grants go 

to IHAs who use them to acquire the rights to land and build new units, or 

acquire and rehabilitate existing ones, for rent by low-income families. The 

IHAs then manage the properties and receive additional HUD funds to 

cover the difference between allowable operating costs and tenant 

payments toward rent (set not to exceed 30 percent of the tenant's 

adjusted income). 

• 	 HUD's Mutual Help Program--one of a very few Federal programs that 

have offered home-ownership opportunities to low-income families. As in 

the Low Rent program, IHAs develop new housing with HUD grants, but 

purchasers are responsible for all operating and maintenance costs. The 

purchasing household must make an initial $1 ,500 contribution (but tribes 

often meet this requirement on behalf of the household by contributing the 

land), and make a monthly uhomebuyer paymentU (set by the IHAs at 
Assessment of American Indian Housing Needs and Programs: Final Report 105 

between 15 and 30 percent of household income} for up to 30 years. The 

program is actually a "lease-purchase" arrangement. Families do not 

actually gain title to their properties until all of their payment obligations are 

met. 

• 	 The Bureau of Indian Affairs (BIA) Housing Improvement Program (HIP), 

which provides grants for housing improvements, targeted to very lowincome households. HIP is nonnally administered by the tribal 

governments. Most funds have been used for modest rehabilitation and 

repair of existing units rather than new construction, although the latter is 

allowable under the program. 

• 	 TENANT-BASED ASSISTANCE. This includes HUD's Section 8 Certificate and 

Voucher programs which are variations on the same theme. Both help low-income 

households rent housing of their choice in the private housing stock (rather than 

locating them in projects built or managed by government). The tenants must 

select housing in standard condition--HUD subsidy payments to the landlord then 

make up the difference between the market rent for the unit and the tenant's 

payment (set not to exceed 30 percent of adjusted household income). 

• 	 BLOCK GRANTS. The two examples of this type are parts of nationwide HUD 

initiatives: the Indian Community Development Block Grant (ICDBG) program and 

the HOME program. Compared to the "categorical" programs above, both give 

tribal governments (who administer them) much more latitude in deciding how, and 

for what, subsidy funds will be spent. HOME funds must be used for housing 

assistance but a broad variety of approaches are eligible (including all of the 

production modes noted above, tenant-based assistance, and variations entailing 

mixed public-private ventures). ICDBG funds can be used to support land 

acquisition, economic and infrastructure development and a limited range of social 

services, as well as a variety of housing programs. 

• 	 FINANCING ASSISTANCE PROGRAMS. These are programs designed to 

encourage the provision of private mortgage financing in Tribal Areas. The first 

initiative in this direction was the FHA Section 248 mortgage insurance program, 

established in 1987. More recently, the Section 184 Loan Guarantee program has 

been established in support of this goal. In addition, the Fanners' Home 

Administration (FmHA) offers direct loans for new units in Indian country. 
Assessment of American Indian Housing Needs and Programs: Final Report 706 

Institutional Relationships and Responsibilities 

Today the delivery of Indian housing programs is primarily coordinated through three 

Federal agencies: HUD, the SIA, and the Indian Health Service (IHS) in the Department of Health 

and Human Services. This relationship was formally established in 1976 by the Interdepartmental 

Agreement on Indian Housing, which sought to increase housing production by bringing these 

agencies together. An updated version of the Interdepartmental Agreement (September 1994) 

establishes a general foundation for this cooperative effort and guidelines by which each of the 

agencies interacts with tribal governments and Indian housing authorities (IHAs). Their general 

responsibilities are: 

• 	 HUD provides financial assistance for the development and management of low 

income housing and community development in Indian and Alaska Native areas 

through the traditional Indian housing development program. 

• 	 BIA reviews and approves all required trust land leases, easements and real 

estate appraisals; provides maintenance services to those I HA constructed roads 

and streets accepted into the SIA road systems; and provides other support, when 

available, for the timely development of housing. It also administers a non-HUD 

housing program, the Housing Improvement Program (HIP). 

• 	 IHS assists Tribes by providing technical and financial assistance in the 

development of tribal sanitation facilities (water, waste water, and solid waste 

facilities and operation and maintenance infrastructure). When requested by the 

Tribe and IHA, IHS may participate in the construction of sanitation facilities funded 

under the traditional Indian (HUD-assisted) housing development program. 

HUD's administration of its Indian housing programs has recently undergone a change as 

a result of the implementation, in May of 1993, of changes authorized by Congress in the Housing 

and Community Development Act of 1992. Previously, HUD's Indian housing programs, with the 

exception of the Indian CDSG program and mortgage insurance programs, were administered 

through the Office of Indian Housing (OIH) at HUD central headquarters, and by six regional 

Offices of Indian Programs (OIPs). The six OIP offices, established in 1980 at the request of 

Congress and the Indian constituency, are located as access pOints for the Indian population 

(Chicago, Oklahoma City, Denver, Phoenix, Seattle and Anchorage). In Oklahoma City and 

Anchorage, the OIPs report to the Manager of the HUD office, while in Seattle, Phoenix, Chicago, 

and Denver the OIPs reported directly to the Regional Administrator. Prior to the recent 

administrative changes, the OIPs worked more or less closely with OIH to administer Indian 

housing and community development programs and provide technical assistance to both IHAs 

and tribes, but were not directly supervised by OIH. 
Assessment of American Indian Housing Needs and Programs: Final Report 	 107 

The changes implemented in May of 1993 act to further consolidate the coordination of 

all Native American programs within HUD. First, the OIP has been renamed the Office of Native 

American Programs (ONAP), better reflecting the inclusion of Alaskan and other American 

natives. Second, the responsibility for administration of the Indian CDBG program has been 

moved from HUD's Office of Community Planning and Development, which administers the overall 

CDBG program, to ONAP. Finally, since October 1993, the six OIP offices (now called Field 

Offices of Native American Programs, or FONAPs) report directly to ONAP, rather than to the 

Regional Administrator or Field Managers. 

IHAs, which are comparable to public housing agencies in structure and function in 

developing and managing assisted housing units under the U.S. Housing Act, can be established 

by tribes under either tribal or state law. Through most of the history of these programs, tribally 

formed IHAs had to have ordinances consistent with a HUD-approved format and had to be 

favorably reviewed by the Department of the Interior before HUD gave final approval (this "model 

ordinance" requirement has recently been dropped). At present, 187 IHAs represent 267 

American Indian tribes and about 200 Alaska Native villages. IHAs are normally operated by a 

board of five or more members, usually selected by the tribal goveming body, although some 

tribes now have an election process for IHA board members. An Executive Director is hired by 

the board to manage the IHA. 

HUO's Production Programs: Rental and Mutual Help 

HUD's Rental Program. As noted, the Rental Housing program for American Indians is 

the basic low-rent public housing program established by the U.S. Housing Act of 1937. The first 

IHA recipient of Rental Housing funds was the Oglala Sioux tribe of Pine Ridge, South Dakota, 

in 1961. In this program, HUD allots funds to IHAs for housing construction and development 

through an Annual Contributions Contract (ACC). It also subsidizes operating costs in the amount 

of the difference between expected rental income and anticipated maintenance, utility, and 

administration costs. Operating funds are formula-based and are provided through HUD's 

Performance Funding System (PFS).33 In theory, expenses are estimated against the model of 

a well-managed housing authority. 

A tenant's total monthly payment is based on the highest of the following factors: 

• 	 30 percent of monthly adjusted income 

• 	 1 0 percent of monthly income 

• 	 the designated portion of housing assistance provided by a public agency in line 

with the family's standard of need 

33 The PFS system affects all IHAs except those in Alaska. 
Assessment of American Indian Housing Needs and Programs: Final Report 108 

In some cases HUD will allow an IHA to adopt "ceiling rents" under authority of the 

Housing and Community Development Act of 1987. In this situation the IHA determines a 

maximum rent which includes debt service and operating expenses for a class of units. When 

ceiling rents apply, tenants pay the lower of their calculated rent or the approved ceiling rent. 

Tenants will also receive a utility reimbursement if the utility allowance is greater than the tenant 

payment. 

HUD's Mutual Help Program. The Mutual Help Homeownership Opportunity Program 

became available to American Indians in 1962. The purpose of the program is to provide 

opportunities for lower-income families to purchase decent, affordable housing and to participate 

more fully as homeowners. 

Mutual Help is available to qualified Indian families on Indian reservations, in Alaska 

Native villages, or in other Indian areas. Over the past thirty years this program has evolved into 

three components: 

• 	 "Old" MH Program - Homeownership units developed before March 9, 1976, 

authorized under HUD administrative directives and handbooks. 

• 	 "New" MH Program - Homeownership units developed since March 9, 1976, under 

the first consolidated Indian housing regulations. 

• 	 "Self-Help" MH Program - Homeownership units built by homeowners under a 

cooperative arrangement with the IHA. This new program was authorized under 

the Indian Housing Act of 1988. 

A Mutual Help Occupancy Agreement between the IHA and each participating family spells 

out the homeowner's responsibilities during the contract period. Each potential homeowner must 

initially contribute a minimum of $1,500 in money, land, materials, or labor towards the housing 

unit. The tribe is allowed to contribute everything for the family except labor, which, if this option 

is utilized, must be done by a family member. Frequently, tribes contribute land on behalf of the 

family member to meet this requirement. In addition to the initial contribution, the family makes 

a monthly payment between 15 and 30 percent of adjusted income. Participating families are 

also responsible for all maintenance and utility charges. Buyers are considered eligible to 

purchase the home when their equity accounts and reserves are large enough to pay the 

outstanding balance as calculated by the IHA. 

Modernization Funds for HUD Programs (ClAP and CPG). Funds for modemization 

of IHA housing are provided through the ClAP and CGP programs. The National Affordable 

Housing Act of 1990 expanded the allowable uses for Comprehensive Improvement Assistance 
Assessment of American Indian Housing Needs and Programs: Final Report 109 

Program (ClAP) funds beyond just the Rental Housing program, to include modernization grants 

for Mutual Help units, some grants for the Turnkey III units and management improvement grants 

for other homeownership developments. The Comprehensive Grant Program (CGP), which 

became effective in 1992, provides larger IHAs (now specified as 250 units or more) with a more 

flexible program which is distributed by a formula allocation (unlike ClAP funds which are 

distributed under a competitive allocation process). 

Special Policies. In general, Indian housing programs have closely paralleled regular 

public housing programs. However, an "Indian preference" policy was adopted in 1976 through 

Section 7(b) of the Indian Self-Determination and Education Assistance Act. The Act gives 

preference to American Indians in contracting and providing labor for development projects. 

Indian preference for eligibility of residency is a consideration in the Mutual Help program, since 

the Indian Housing Act of 1988 requires that non-Indians be admitted into the program only under 

special circumstances. The Rental program has no such statutory provision and will not allow 

IHAs to prohibit non-Indian renters. 

HOPE. Established under the National Affordable Housing Act (NAHA) of 1990, the HOPE 

1 and 3 Programs were designed to permit the conversion of units in assisted housing projects 

to homeownership for low income persons. Scattered-site, non-contiguous, single-family 

structures that are not part of the Rental Housing Program were eligible under HOPE 3; all other 

units and any single-family rental housing units were to be converted under HOPE 1. At least two 

of the initial grantees for HOPE 1 Planning Grants were Indian tribes (the Menominee of 

Wisconsin and the Lummi of Washington State); the HOPE 1 interim guidelines, in fact, required 

the funding of at least one Indian project. Several IHAs and tribes were initially examining the 

feasibility of converting Mutual Help units under HOPE 3, because HOPE funds would enable 

homeownership to be achieved within fewer than the up to 25 years formerly required under 

Mutual Help. Funding for HOPE initiatives has been virtually eliminated, however, so the HOPE 

programs are unlikely to be a factor in the operation of IHA projects in the future. 

The BIA's Production Program: HIP 

As noted earlier, the Bureau of Indian Affairs did not act upon the statutory authority 

established under the 1921 Snyder Act until it initiated its Housing Improvement Program (HIP) 

in 1965. HIP provides grants to very low income homeowners who had no other source of funds 

for housing repair or renovation. While housing rehabilitation or enlargement is the major 

emphasis of this program, the BIA also permits funds to 'be used for downpayments or new 

housing construction in isolated rural areas where no other means exist to meet the housing need 

(although in recent years, the BIA has recommended dropping down payment assistance). 
Assessment of American Indian Housing Needs and Programs: Final Report 110 

Grant requests are not made through a customary proposal process; instead, Indian 

families and tribes determine their priorities, with consideration for family size, income, condition 

of present housing, and availability of other federal housing assistance. Indian families must 

make application for these grants to the tribe or the nearest BIA office. The HIP grants are 

awarded through tribes or through the BIA primarily to individual homeowners. HIP funds can be 

awarded as: (1) direct grants to individuals; (2) contracts with Indian tribes; (3) contracts with 

private Indian or non-Indian contracting firms; or (4) programs directly administered by the BIA. 

The HIP program provides for two types of repairs. In cases where substandard housing 

is to be inhabited for an interim period until better housing can be obtained, HIP will provide up 

to $2,500 for repairs and additions. A second category of repairs provides up to $20,000 per 

dwelling for rehabilitation or enlargement of a deteriorated unit. Repair costs per housing unit 

under the HIP program have averaged approximately $10,000. 

There are also two forms of assistance for new housing construction. Downpayment 

grants are made to prospective homebuyers to help them become eligible for tribal, federal, or 

other housing loans. These grants are only made for houses in standard condition, and they 

must not exceed: (1) the amount necessary to secure the loan plus the cloSing costs; (2) 10 

percent or the purchase price of the house plus the closing costs; or (3) $5,000, whichever is 

less. As a last resort, if an Indian family has absolutely no other source for housing and is not 

eligible for HUD, VA, FmHA, or any other federal assistance, the HIP program will finance the 

construction of a new house, the grant for which is not to exceed $45,000 (more in Alaska). 

The HIP program is available on most Indian reservations. The BIA supervises the 

construction process, but it is not required to provide continuing monitoring or services to the 

family after construction is completed. 

Tenant-Based Assistance 

As noted earlier in this chapter, HUD provides tenant-based assistance through the 

Section 8 Certificate and Voucher programs which help low-income households rent housing of 

their choice in the private housing stock (rather than locating them in projects built or managed 

by government). The tenants must select housing in standard condition, and then HUD makes 

subsidy payments to the landlord in amounts that make up the difference between the market rent 

for the unit and the tenant's contribution to the rent (set not to exceed 30 percent of the 

household's adjusted income). Tenant-based assistance has not been used extensively in Indian 

country to date. 
Assessment of American Indian Housing Needs and Programs: Final Report 111 

Block Grant Programs 

Indian Community Development Block Grant (ICDBG). The Indian CDSG program is 

HUD's principal vehicle for American Indian communities to carry out community and economic 

development activities, although it can also be used for housing development. One percent of 

the total national CDSG funding is set aside for the Indian CDSG program. Eligible recipients for 

ICDSG funding are Federally (not state) recognized tribes. 

The ICDSG program is important to tribes because its discretionary nature allows them 

flexibility to pursue a variety of activities, even though the total funding is much smaller than for 

Rental and Mutual Help Housing. The funds are allocated to regions by a formula which takes 

into account the proportion of the Indian population that resides in the region, and its rates of 

poverty and overcrowded housing. Within regions, tribes compete for the funds, and are allowed 

to use them for four types of activities: housing, public infrastructure, economic development, and 

community facilities. 

In 1990, housing projects constituted the largest (32 percent of total funds) activity by 

Indian tribes receiving ICDSG funds. Community facilities were next at 26 percent of total funds, 

followed by public infrastructure at 23 percent, economic development at 17 percent, and land 

acquisition related to all of these activities at 2 percent. Allowable activities in the housing area 

are rehabilitation of existing units, new construction, land, and direct assistance to homeowners. 

HOME. The HOME Investment Partnership Program was established by the National 

Affordable Housing Act (NAHA) of 1990. NAHA required that one percent of HOME 

appropriations be set aside for Indian housing. The funds are awarded to Indian tribes under a 

competitive application process, administered by the HUD FONAPs. Like CDSG, HOME is 

important to tribes in that it is a more flexible, discretionary program than Rental Housing or 

Mutual Help. HOME funds may be used for housing rehabilitation (moderate or substantial), 

housing acquisition, new construction of rental or homeownership housing, and for tenant-based 

assistance. 

There has been considerable interest in the American Indian community in the new HOME 

program, although the allocation of funding remains very small compared to HUD's other Indian 

h<?using programs. In 1992, the first year of the program, twenty-nine applications were received 

from tribes, of which 17 projects from 15 tribes were funded. , 

Through NAHA, Congress intended to unify the planning and coordination of many housing 

programs and activities that are funded with Federal dollars. To this end, it was required that 

localities prepare a Comprehensive Housing Affordability Strategy (CHAS). This was instituted 

to replace earlier planning requirements with a Single local housing strategy, identifying and 
Assessment of American Indian Housing Needs and Programs: Final Report 112 

setting priorities among all housing needs. However, the Congress did not explicitly apply the 

CHAS requirement to Indian tribes or IHAs, and HUD determined that the States, in preparing 

their own CHAS, have no legal jurisdiction to determine housing needs or strategies for tribes. 

Therefore, tribes and IHAs are not presently required to prepare any comprehensive housing plan 

or strategy as a basis for HOME funding. 

Other special rules apply to Indian HOME funding. Where an Indian Housing Authority 

has received no ICDBG funding in the current Fiscal Year, the match requirement under the 

HOME Program is waived. And, where a match is required, Indian trust funds and the sales 

proceeds of Mutual Help and Turnkey III programs can be used. 

Financing Assistance 

Established in 1985, FHA Section 248 allows for the insurance of mortgages for single 

family properties on trust lands, but not on allotted trust lands or fee lands. The program, 

administered by the Single-family division of HUD's Federal Housing Administration (FHA) was, 

through 1994 at least, seldom used. Problems have included the lack of adequate marketing, the 

lack of allowance for insurance of the construction loan, and the fact that the program adheres 

to underwriting, mortgage credit, and appraisal standards of the non-Indian single-family mortgage 

insurance program which may not be appropriate in some parts of Indian country. 

A new program to stimulate mortgage lending in Tribal Areas was enacted under the 

Housing and Community Development Act of 1992: the Section 184 Indian Housing Loan 

Guarantee Fund. Section 184 is a loan guarantee program rather than a loan insurance program. 

It was designed to further broaden public options to facilitate mortgage lending in Indian Country. 

Like Section 248, it can be used in support of loans to Indian families or IHAs to construct, 

acquire, or rehabilitate one- to four-family dwellings. Loans can be made by lenders who have 

been approved by the Secretary of HUD or the Secretary of Agriculture, or who are supervised, 

approved by, or regulated by any agency of the Federal government. 

Finally, the Farmers Home Administration (FmHA), of the Department of Agriculture34 has 

provided direct loans for very low-income families in Tribal Areas for many years. Its Section 502 

program offers loans to families to build or purchase single family homes. Interest rates may be 

reduced to as low as 1 percent, and low-cost approaches (including self-help), have been 

emphasized. To receive a loan, applicants must meet income restrictions and must have been 

turned down at least twice in applying for the same loan from a private financial institution. Under 

34 The Farmers Home Administration has been recently renamed the Rural Housing and Community Development 

Service; it is still located within the U. S. Department of Agriculture. 
Assessment of American Indian Housing Needs and Programs: Final Report 113 

Section 504, it offers loans and grants for home repair and rehabilitation (grants, ranging up to 

$5,000, have been given mainly to the elderly--Ioans may range up to $20,000). 

Recent Changes in Indian Housing Programs 

In response to continuing implementation and program effectiveness problems with the 

Indian housing programs, HUD has implemented changes since the Indian Housing Act of 1988 

to ameliorate perceived problems in its programs. Some of the major program changes made 

by HUD in recent years include: 

• 	 Establishing Indian set-asides in some national programs (e.g. Emergency Shelter 

Grant program); 

• 	 Increasing funding levels for modernization and rehabilitation of existing Indian 

housing units; 

• 	 Consolidating and streamlining of regulations for various Indian programs into one 

rule; revision of the rule to reduce and simplify the number of regulatory 

requirements, and provide more flexibility in the administration of the Indian 

housing programs; 

• 	 Establishing a new Notice of Funding Availability for various programs to 

streamline the previously fragmented application and administration process; 

• 	 Preparing completely new program handbooks for the first time in the history of the 

Indian housing programs; 

• 	 Starting to address the issue of "culturally relevant" design and construction; and 

• 	 Emphasizing the applicability of the new HOME program to Indian communities, 

particularly because of its flexible rules in allowing varying uses of funds. HUD 

also has urged, at the Headquarters level, the use of McKinney Act funds and 

other programs which could be used to a much greater extent than they have been 

to date. 
Assessment of American Indian Housing Needs and Programs: Final Report 114 

PROGRAM FUNDING 

Data on the levels at which these Federal Indian housing assistance programs were 

budgeted from Fiscal Years (FY) 1992 through 1994 are presented in Table 4.1 (actually, 

complete data could be obtained only for FY 1993--only partial information is available for the 

other years). 

To obtain a completely accurate account of the flow of funds in any year, it would have 

been preferable to obtain data on Outlays in all categories. Unfortunately, such data were not 

available and, where so, the amounts of Budget AuthOrity provided have been inserted instead. 

Strictly speaking, these two categories should not be combined. Outlays represent funds actually 

spent (or to be spent) in the year cited, whereas Budget Authority is an amount authorized now, 

that may be intended for expenditure over a period of several years. It is possible, for example, 

for large amounts of Budget Authority to be provided for a program in one year, and very little 

added over the next few years, while outlays remain constant. In these programs, however, such 

"lumpy" allocations of Budget Authority were not made during these years, so the figures on the 

table represent a reasonably consistent approximation of the flow of funds. 

Clearly, the most important finding is that the two HUD production programs dominate all 

Federal housing assistance to Tribal Areas. Together, they were budgeted at a level of 

$516 million in FY1993, representing 88 percent of the total for all programs. Within the allocation 

for these programs, amounts provided for production (figures for new construction plus related 

amendments) account for 55 percent of the total, modernization funding accounts for another 30 

percent, and the remaining 15 percent were allocated for operating subsidies and smaller 

supporting programs. 

In comparison, the amounts provided for all remaining programs are quite small: 

$24.8 million for other production programs (BIA's HIP program and HUD's provision of 

emergency shelter facilities--4.3 percent of the total); $15.5 million for tenant-based assistance 

(2.6 percent); and $28.8 million for block grant programs (4.9 percent). Although some funding 

has been set aside to cover possible losses in the financing assistance programs, none was 

expended during these years. 

Altogether, the Federal government budgeted for a flow of $585 million in Indian housing 

assistance in FY 1993. This is the equivalent of only 2.3 percent of the total $25.2 billion HUD 

budget for outlays in 1993 (the total amount of Budget Authority provided for HUD in that year 

was $26.5 billion). 
Assessment of American Indian Housing Needs and Programs: Final Report 115 

Table 4.1 
 

FEDERAL FUNDS BUDGETED FOR INDIAN HOUSING ASSISTANCE, 1992-84 
 

OL Budget ($ millions) 

or Percent 

BA ~Y1992 !=Y1993 FY1994 FY1993 

PRODUCTION PROGRAMS 

HUD Low Rent and M.H. 

New Conslr. BA 241.12 257.32 263.61 43.9 

Amendments BA 38.00 25.60 22.00 4.4 

Modernization BA 112.94 155.60 166.94 26.6 

Subtotal Cap_aI BA 392.06 438.52 452.54 74.9 

Operating Subsidy OL 67.85 70.82 NA 12.1 

Other 

Drug Elimination OL 4.74 5.26 NA 0.9 

Youth Sports OL NA 1.12 2.54 0.2 

Res.MgmtJCh.Care OL NA 0.53 NA 0.1 

Subtotal OL NA 77.74 NA 13.3 

Total NA 516.26 NA 88.2 

HUD Emerg. Shelter OL 0.00 1.59 NA 0.3 

BIA HIP Program BA 23.71 23.51 NA 4.0 

Total Production NA 541.36 NA 92.5 

TENANT BASED ASSISTANCE 

HUD Section 8 BA NA 15.46 17.70 2.6 

BLOCK GRANTS 

Indian CDBG* BA 25.76 16.00 17.60 2.7 

HOME BA 15.00 12.75 12.75 2.2 

Total BA 40.76 28.75 30.35 4.9 

RNANCING ASSISTANCE 

Sec. 248, 184 OL 0.00 0.00 0.00 0.0 

TOTAL HOUSING NA 585.57 NA 100.0 

SOURCE: Data provided by HUD Office of Native American Programs 
 

NOTES: OL = Outlays; BA =Budget Authority (see text for interpretation); NA =not available 
 

• Assumes 40 percent of total budget authority lor housing. 

APPROACH TO ASSESSMENT 

The major challenge presented by this component of the study is to provide a 

comprehensive and reliable account of how existing Federal programs, primarily HUD programs, 
Assessment of American Indian Housing Needs and Programs: Final Report 116 

are working in Indian communities. A number of reports are available that present an historical 

perspective on the development of Indian housing programs and the barriers which have 

prevented them from providing adequate housing to American Indians and Alaskan Natives. 

What has been missing, however, is an objective and quantitative assessment of how Federal 

Indian housing programs are working at this point in time. 

As discussed in Chapter 1, this study has relied on a variety of interrelated sources of 

information to respond to this assignment. The main assessment questions to be addressed, and 

the methods and data sources used to address them are discussed below. 

Assessing HUD Production Programs 

Given their dominance in the funding stream, it has been appropriate to focus the work 

of this assessment on HUD's Rental and Mutual Help programs. For these programs, the key 

questions fall in three areas: (1) outcomes and impacts; (2) process and efficiency; and (3) 

institutional effectiveness. However, we also examine with respect to each of these: (4) diversity 

in findings across tribal areas; and (5) possible causes of diversity and change. 

Outcomes and Impacts. How much housing has been produced in relation to the need 

and what are the recent trends in production levels? What are the physical conditions and 

characteristics of that housing produced and how is it assessed by its occupants? Who are the 

beneficiaries--is the housing being provided to the right types of households in accord with 

congressional intent? Are program resources being distributed equitably across Tribal Areas? 

Responding to these questions generally entailed a straightforward analysis of statistical 

data files. Data on volume of program production over time, by types and locations, are found 

in HUD's MIRS information and characteristics of the beneficiaries are found in its MTCS system. 

Relationships of production to need required comparisons of data from these sources to Census 

files covering housing problem measures (see Chapter 3), location by location. Information on 

the quality of HUD housing and occupant perceptions of that housing, however, are not 

systematically recorded by HUD. For answers here, we relied on our sample household surveys. 

With regard to most of these topics, we also compare quantitative data on results to perceptions 

held by tribal, IHA, and HUD officials, as recorded in telephone and on-site interviews. 

Process and Efficiency. There are two main processes to be considered corresponding 

to the two main responsibilities entailed in implementing housing programs: (1) the development 

of new housing; and (2) the operation, maintenance, and modernization of housing already built. 

On both scores, the first task was to analyze costs per unit of output, and related measures (such 

as the length of the development process). Data costs and other financial measures, as well as 

timing, are provided in HUD's MIRS system. On-site and telephone interviews, however, were 
Assessment of American Indian Housing Needs and Programs: Final Report 117 

the primary source of information to explain current processes in each area and to provide a basis 

for assessing them. With regard to development, for example, what are the factors that constrain 

IHA efforts to reduce both costs and timing? To what extent are current approaches and results 

influenced by HUD rules and administrative styles, tribal values and customs, IHA creativity and 

capacity, and special circumstances in Tribal Areas that limit housing development in ways not 

typical in housing markets elsewhere? 

Institutional Effectiveness. This analysis occurs at two levels. First is the performance 

of the Federal agencies involved. Review here is necessarily softer and more judgmental than 

the quantitative assessments noted above. It is based on both published accounts by, and 

interviews with, relevant officials and observers on events that have occurred, rules and 

procedures being followed (and how they have changed), and operating styles. 

The second level is performance by institutions in the Tribal Areas themselves (for the 

most part, tribal governments and IHAs). HUD management information systems provided explicit 

and implicit indicators of comparative IHA performance on a number of grounds. In addition, 

surveys asked for facts related to performance (e.g., mechanisms of IHA-tribal relationship, 

turnover in IHA Directors, descriptions of key procedures) as well as perceptions about 

performance and key factors affecting it. 

Diversity and its Determinants. Given the broad diversity in social, economic, and 

housing conditions among Tribal Areas found in Part I of this report, it should come as no surprise 

that we also find considerable diversity in program outcomes and performance. We examine the 

range of results across Tribal Areas, section by section in the assessment. Surveys asked both 

local and national respondents for their views on why such differences occur, but more formal 

means of analysis were also employed (ranging from examination of cross-tabulations to 

regression analysis). 

Assessment of Other Programs 

To assess other types of Federal housing assistance in Indian country (BIA's HIP program, 

tenant-based assistance, block grants, and financing assistance), essentially the same framework 

for inquiry is appropriate. Similarly comprehensive data sources for these programs do not exist, 

but in all cases, data from program offices and other published accounts permit tabulation of basic 

levels of activity and some measures of performance. Surveys conducted for this study also 

asked tribal, IHA, and Federal officials what they knew about the performance of these other 

programs in their Areas, what they thought about their use,fulness, what barriers they saw to 

applying them more effectively, and how such barriers might be overcome. 
Assessment of American Indian Housing Needs and Programs: Final Report 118 

Perspective Related to the Timing of this Assessment 

HUD's Indian housing programs have evolved, through a sometimes painful process, from 

their start in the 1960s as a stepchild of public housing to a more (although not completely) 

independent status today. Much of the progress toward autonomy has occurred recently and 

rapidly. Many important changes (including the reorganization of HUD's Office of Native 

American Programs (ONAP), the consolidation of Indian financing programs and the Indian 

Community Development Block Grant program into ONAP, and a further significant reduction in 

program regulations) have occurred just during the past two years while this assessment has 

been underway. 

This assessment emphasizes an account of conditions as they existed just before this 

latest round of reforms was devised. As far as possible, however, we explain how those 

conditions relate to the (generally more onerous) program environment of the past, and how they 

may relate to what the new reforms will provide. 

REFERENCES 

Cornell, Stephen, and Joseph P. Kalt, Eds. 1992. What Can Tribes Do?: Strategies and 

Institutions in American Indian Economic Development. American Indian Handbook and 

Manual Series No.4. Los Angeles: American Indian Studies Center, University of 

California at Los Angeles. 

General Accounting Office. 1978. Substandard Indian Housing Increases Despite Federal 

Efforts: A Change Is Needed. Washington, D.C.: U.S. General Accounting Office. 

Housing Assistance Council. 1987. Indian Housing in the U. S.: A History. Washington, D.C.: 

Housing Assistance Council. 

HUD (U.S. Department of Housing and Urban Development. 1993. The Indian Housing 

Program: The History and Current Status of Indian Housing in the United States. 

Prepared by The Office of Indian Housing. Washington, D.C.: U.S. Department of 

Housing and Urban Development. January. 
Assessment of American Indian Housing Needs and Programs: Final Report 119 

National Commission on American Indian, Alaska Native and Native Hawaiian Housing. 1992. 

Building the Future: A Blueprint for Change. Washington, D.C.: National Commission on 

American Indian, Alaska Native and Native Hawaiian Housing. June. 

______. 1993. Supplemental Report and Native American Housing Improvements 

Legislative Initiative. Washington, D.C.: National Commission on American Indian, Alaska 

Native and Native Hawaiian Housing. January. 
ChapterS 

HUD'S PRIMARY PRODUCTION PROGRAMS: 

RENTAL AND MUTUAL HELP 

Since program inception in the early 1960s, Federal housing assistance has had a 

significant impact on the provision of housing in Tribal Areas. Chapters 5 and 6 provide 

information on the performance of these programs, following the framework just outlined at the 

end of Chapter 4. 

The two major HUD production programs, Rental and Mutual Help, are assessed in this 

chapter. Data, and interpretation are offered concerning outcomes and impacts (the size and 

characteristics of the assisted housing stock and the characteristics of beneficiaries), process and 

efficiency (with respect to development and stock operation and maintenance), and institutional 

performance (both at the Federal and local levels). 

Chapter 6 assesses the other forms of Federal housing assistance being provided in 

Indian country (the HIP program, tenant-based assistance, block grant programs, and financing 

programs), reviews innovative housing initiatives undertaken by several tribes, and offers 

conclusions concerning the performance of Federal housing assistance in AlAN Tribal Areas 

overall. 

Form of Data Presentation 

Data for the assessment in this chapter have been assembled in a unified manner from 

several of the sources described in Chapter 1 (particularly, the HUD MIRS and MTCS information 

systems, but also the IHA telephone surveys and Census files). In most tables here, the unit of 

observation is IHA and its own service area, rather than Tribal Areas, which were the basis for 

much of the analysis in earlier chapters (in many cases IHA service areas include more than one 

Tribal Area--see the listing in Annex A at the end of this report). 
Assessment of American Indian Housing Needs and Programs: Final Report 121 

For many of the topics addressed, we begin by examining simple cross tabulations, 

showing variations in IHA measures in relation to a standard set of variables that might be 

generally expected to influence outcomes. Where this approach raises questions of interest, we 

then examine variations more systematically using regression techniques. 

The standard variables are: (1) level of IHA administrative performance (as measured by 

HUD's Administrative Capability Assessment, or ACA, rating system); (2) IHA size (as measured 

by the number of housing units it manages); (3) income levels in the IHA service area;35 

(4) region (as defined earlier in this report); and (5) IHA and market type. 

HUD's ACA ratings (scale from 1 to 100) are composites, built up from a sizeable number 

of pre-specified indicators of various aspects of performance (generally objective and verifiable). 

While this system has imperfection (e.g., probably gives too much emphasis to administrative 

compliance, compared to end results), review in this study suggests that the system is wellspecified and employs reasonable quality control procedures to promote reliability for these 

purposes. (More information is given on ACAs later in this chapter). 

IHA size is measured by the number of housing units in management (largest IHA 

manages 6,314 units and the smallest IHA has only eleven units in management--newly formed 

IHAs without completed units are not included). Area income is derived from census data: IHAs 

have been grouped in quartiles based on the percentage of all households in their service areas 

that have low-incomes (Le., below 80 percent of the local median). 

It is important to point out that these first three variables are not correlated with each 

other; e.g., ACA ratings do not vary depending on whether IHAs are large or small or whether 

their service areas are comparatively rich or poor; the large IHAs are no more likely to be found 

in higher income service areas than lower income service areas.36 

The "IHA and Market Type" categorization is a variation of the market typologies described 

in Chapters 2 and 3,37 with an additional component describing different types of housing 

35With respect to the first three of these variables, individuallHA scores were ranked and averages are presented 

by quartile. 

36"fhe Pearson correlation coefficient between the ACA rating and the area income variable is only 0.26. For the 

other relationships it is even lower: 0.07 between IHA size and the ACA rating; 0.06 between IHA size and area 

income. 

370n the tables here, as in Chapter 2: "Near Urban" means within 50 miles of an urban area with a 1990 population 

of 50,000 or more; "Large" means having an AlAN population of 400 or more; ·Op." refers to open, where the Tribal 

Area population contains at least as many non-Indians as Indians; "HI" refers to higher-income and "LI" to lower-income, 

where the dividing line is where half of all AlAN households have incomes below 80 percent of the local median. All 
Assessment of American Indian Housing Needs and Programs: Final Report 122 

authorities. An IHA that serves more than one Tribal Area has been designated as an "umbrella 

IHA" (these include all of the Alaska IHAs and eleven others in other states). 

THE ASSISTED HOUSING STOCK AND ITS BENEFICIARIES 

This section opens with a brief review of the magnitude of HUD-assisted housing in Tribal 

Areas, and how it developed over time. It then addresses key questions in the assessment. How 

equitably has this housing been distributed in relation to need? What are the characteristics of 

assisted housing units and how do these relate to the needs and perceptions of the occupants? 

Are the types of households being served by these programs those for which assistance was 

intended? 

Program Size and the Production Record Over Time 

Under HUD's two major Indian housing programs, almost 100,000 housing units had either 

been completed, or were in various stages of the production pipeline, at the end of 1993 (Table 

5.1). A total of 84,300 had been completed and, of these, 75,400 were still under IHA 

management (the remaining 8,900 being Mutual Help units for which owners had met their 

obligations under the Mutual Help agreement and the units had been conveyed to the families). 

Of the 14,300 units still in the production pipeline, 20 percent were in construction and the others 

in earlier stages of planning and preparation. 

About one third of all units in management were in Rental projects. Almost all of the rest 

were Mutual Help units (the exception being 2,300 units that were built under the since-terminated 

Turnkey III program). 

As shown on the bottom panel of Table 5.1 , only 5 percent of the completed units in these 

programs were in place by the end of the 1960s, another 39 percent were added in the 1970s, 

and the largest production decade was the 1980s, with 46 percent. 

Patterns differed somewhat for the two programs. In the 1960s, when they both began, 

there were a number of sizeable Rental developments, but momentum had begun to swing to 

Mutual Help toward the end of that decade. Mutual Help has generally been the most actively 

used and this was evidenced by its dominance in the production statistics of the 1970s (an 

IHA service areas not classified as Near Urban on this table are labeled as "Remote" (the Navajo reservation is broken 

out separately in many of these tables because its inclusion in that category could give a misleading impression of 

typical conditions). 
Assessment of American Indian Housing Needs and Programs: Final Report 123 

Table 5.1 

HUD PROGRAMS COMPLETED UNITS AND PRODUCTION PIPELINE 

Mutual 
 

Total Rental Help/Other 
 

IHA HOUSING UNITS (000) 

In Management 75.4 27.2 48.2 

Paid Off 8.9 8.9 

In Development 

Pre-construction 11.5 4.0 7.5 

In construction 2.8 1.1 1.7 

Subtotal 14.3 5.1 9.2 

Total 98.6 32.3 66.3 

% BY COMPLETION DATE 

1963-69 5.0 9.0 3.0 

1970-79 39.0 36.0 42.0 

1980-89 46.0 49.0 44.0 

1990-93 9.0 7.0 11.0 

Total 100.0 100.0 100.0 

Source: ONAP, 1994 

average of 2,400 units completed annually, compared to only about 1,000 in the Rental program). 

The dominance of Mutual Help is explained partially by the strong preference for homeownership 

in Indian country. However, many were clearly enticed by the low (near 15 percent) monthly 

payment requirement compared to the Rental program. 

The emphasis changed somewhat during the 1980s. With rapidly escalating utility costs 

in the preceding few years, it became even harder for low-income Indian households to be able 

to afford the costs of ownership. There were pressures to shift to more Rental units where, unlike 

Mutual Help, utility and maintenance costs are heavily subsidized by HUD. In the first four years 

of the 1990s, however, the emphasis has shifted back again with annual completion rates of 

about 1 ,500 units for Mutual Help and 500 for the Rental program. 

The overall pattern of production since 1980 deserves comment. Amounts budgeted for 

these programs peaked in the late 1970s and early 1980s. Funding was then sharply cut back 

during the rest of that decade, but has increased again in the early 1990s. The composition of 

the budget, however, has also changed markedly. In the 1980-82 period, funds for new 
Assessment of American Indian Housing Needs and Programs: Final Report 124 

construction were dominant (operating subsidies and modernization funds amounted to only 11 

percent of the total). By the 1991-93 period, operating subsidies and modernization accounted 

for 39 percent. 

This pattern is shown in Figure 5.1 (expressed in constant 1993 dollars). The average 

total budgeted per year over 1980-82 was $464 million. The level dropped to about half of that 

rate over 1984-86, but the average has since gone up again, reaching about the same level in 

the early 1990s that had been achieved in at the start of the preceding decade. The share of the 

total provided for new construction,_ however, has not rebounded to the same extent. The new 

construction average for 1984-86 was only 43 percent of what it had been over 1980-82; the 

comparable 1991-93 average was 68 percent of that level. 

This explains why program completion rates have declined in absolute tenns. Output had 

peaked in the early 1980s (1980-84 average of 3,800 units completed per year). Production 

levels have since declined: to 3,000 per year over 1985-89, and 2,000 over 1990-93. It should 

be noted, however, that enough units are now in the later stages of planning and construction that 

completion rates should pick up somewhat over the next few years. 

[] Operating Subsidy 

m Modemization 

500 • New construction 465 

450 

'0 400

6 

! 350 


tit 300 
 ~ 01 

-­C 

250 

J!I 

tD 

c: 200 

8 150 


100 


50 


0 


1980-82 198+86 1991-93 

FIGURE 5.1 Faderal Budgets for Rental and Mutual Help Programs, 1980-1993 
Assessment of American Indian Housing Needs and Programs: Final Report 125 

Table 5.2 shows how the timing of production varied for IHAs according to the different 

categories introduced at the beginning of this chapter. On this table, groupings by performance 

rating, IHA size, and area income do not show marked variations. However, differences by region 

are more pronounced. Older IHAs in Oklahoma and the Plains regions had well over half of their 

units produced by the end of the 1970s. Other regions with newer IHAs produced a larger share 

of their stock since then. This is most pronounced in Alaska (all of its Rental units and 71 percent 

of its Mutual Help units completed since 1980), and California-Nevada (91 percent of its Rental 

units and 63 percent of its Mutual Help units since 1980), but it is also true for the North Central 

and Eastern regions. 

The table also shows that the 72 IHAs in the Remote category have program units that 

are on older on average (51 percent of their Rental units and 53 percent of their Mutual Help units 

built before 1980) than those in the Tribal Areas closer to urban areas. 

The Distribution of HUD-Assisted Indian Housing 

Table 5.3 contains data on the distribution of all 1993 units in management in both 

programs by our standard categories. It provides the basis for examining two issues in more 

detail. First, how equitable is the allocation of units across IHAs? Second, to what extent do 

IHAs differ with respect to the mix of Rental and Mutual Help units they provide? 

The process by which HUD has allocated resources to IHAs has changed in a number of 

ways over the years, but it has always been a two stage process. In the first stage, HUD has 

allocated funds to its field office regions on the basis of indicators of comparative need. In the 

second, the field offices have allocated funds to individuallHAs based on assessments of several 

criteria (which have included factors such as perceived capacity to perform, as well as need). 

It seems clear now that the methods used in the past created some biases. As will be 

discussed below, ONAP has recently changed the allocation system to reduce these biases, but 

it should be useful here to note the nature of the difficulties in the past system. Two problems 

were evident. First, HUD used housing inventory data prepared by the BIA to indicate need in 

making allocations to regions in the first stage (recent studies have shown that data to be 

unreliable for that purpose38). Second, regional offices has substantial discretion in making 

allocations within the region in the second stage; i.e., the criteria for choice were not always clear 

or standardized. 

38See discussions in Housing Assistance Council (1992), and Kingsley, Mikelsons, and Herbig (1995). 
Assessment of American Indian Housing Needs and Programs: Final Report 126 

Table 5.2 

AGE OF IHA HOUSING STOCK 

PERCENT OF UNITS BY YEAR COMPLETED 

Percent Rental UnHs Percent MH and Other Unns 

No. 

IHAs Total 1963-69 1970-79 1980-89 1990-93 Total 1963-69 1970-79 19ao-89 1990-93 

ACA Performance Rating 

Highest 25% 44 100 4 34 54 8 100 2 47 43 8 

2nd 25% 44 100 9 37 46 7 100 6 37 45 12 

3rd25% 44 100 11 33 48 7 100 3 35 48 14 

Lowest 25% 44 100 10 41 45 4 100 2 55 36 6 

AlllHAs 176 100 9 36 49 7 100 3 42 44 11 

IHA Size (No. units) 

Highest 25% 45 100 10 40 44 6 100 4 43 44 10 

2nd 25% 43 100 9 27 56 8 100 2 37 48 13 

3rd25% 44 100 2 32 58 8 100 3 45 39 13 

Lowest 25% 44 100 3 13 69 15 100 3 33 48 16 

AlllHAs 176 100 9 36 49 7 100 3 42 44 11 

Area Income 

Highest 25% 43 100 4 44 48 4 100 1 48 44 7 

2nd 25% 43 100 8 33 53 7 100 2 42 43 13 

3rd25% 43 100 12 34 46 8 100 9 40 42 8 

Lowest 25% 43 100 10 34 48 8 100 3 32 48 18 

Unknown 4 100 0 24 76 0 100 0 27 52 21 

AlllHAs 176 100 9 36 49 7 100 3 42 44 11 

Region 

1. No. Central 26 100 11 24 60 6 100 6 35 44 15 

2. Eastern 12 100 8 22 61 9 100 0 25 62 13 

3. Oklahoma 20 100 3 52 45 0 100 1 49 43 6 

4. So. Central 6 100 0 0 100 0 100 0 71 19 10 

5. Plains 28 100 11 49 33 6 100 10 50 31 8 

6. AriZ.-N.Mex. 22 100 11 22 56 10 100 4 40 42 15 

7. Calit.-Nev. 25 100 0 8 76 15 100 3 34 48 15 

8. Pac.No.West 23 100 2 41 49 7 100 2 27 56 15 

9. Alaska 14 100 0 0 88 12 100 0 29 60 11 

AlllHAs 176 100 9 36 49 7 100 3 42 44 11 

IHA and Market Type 

Umbrella - Alaska 13 100 0 0 88 12 100 0 29 59 11 

Umbrella - other 11 100 0 12 72 16 100 1 41 50 8 

Near Urban - Lg/OplHl 6 100 3 65 32 0 100 1 47 46 6 

Near Urban - Lg/CIIHI 100 0 0 100 0 

Near Urban - Lg/Opll.l 22 100 11 29 54 6 100 2 47 43 8 

Near Urban - Lg/CIIl.I 29 100 5 29 56 10 100 2 37 49 12 

Near Urban - Small 17 100 0 15 78 7 100 3 46 37 15 

Navajo 1 100 20 19 52 9 100 5 29 37 30 

Remote 72 100 9 42 43 6 100 7 46 38 9 

Unknown 4 100 0 24 76 0 100 0 27 52 21 

AlllHAs 176 100 9 36 49 7 100 3 42 44 11 

Source: MIRS. 
Assessment of American Indian Housing Needs and Programs: Final Report 127 

T...5.3 

IHA UNITS IN MANAGEMENT, 1993 

Svc. Area 

Units In Management Pet. All Ratio: Pet. Pet. of Units Renlal 

No. Low Income In Mgmt.! Pet. of 

IHAs Total Rantal MH Households Pet. Low Inc. Total Rantal MH Total 

ACA Performance Rating 

Highest 25% 44 22,038 6,450 15,588 39 0.78 30 25 33 29 

2nd 25% 44 14,231 4,756 9,475 12 1.64 19 18 20 33 

3rd25% 44 26,729 10,217 16,512 41 0.88 36 39 35 38 

Lowest 25% 44 11,074 4,602 6,272 9 1.71 15 18 13 43 

AIiIHAs 178 74,072 26,225 47,647 100 1.00 100 100 100 35 

IHA Size (No. units) 

Highest 25% 45 50,643 16,905 33,738 68 1.00 88 84 71 33 

2nd 25% 43 13,984 5,159 8,625 14 1.31 19 20 18 37 

3rd25% 44 6,652 2,656 3,996 14 0.68 9 11 8 42 

Lowest 25% 44 2,593 1,305 1,288 4 0.98 4 5 3 50 

AN IHAs 178 74,072 26,225 47,847 100 1.00 100 100 100 35 

AnIIIlncome 

Highest 25% 43 23,367 4,820 18,547 48 0.69 32 18 39 21 

2nd 25% 43 13,843 4,741 9,102 11 1.69 19 18 19 34 

3rd25% 43 16,962 7,784 9,178 13 1.72 23 30 19 48 

Lowast25% 43 19,188 6,715 10,473 30 0,87 26 33 22 45 

Unknown 4 712 165 547 1 23 

AIiIHAs 178 74,072 26,225 47,647 10 1.00 100 100 100 35 

Region 

1. No. Central 26 4,744 3,389 1,355 4 1.63 6 13 3 71 

2. Eastem 12 3,312 1,241 2,071 6 0.76 4 5 4 37 

3. Oklahoma 20 17,444 2,778 14,666 39 0.60 24 11 31 16 

4. So. Central 6 561 174 387 o 3.30 1 31 

5. Plains 26 16,165 9,051 7,114 12 1.82 22 35 15 56 

6. Ariz.-N.Mex. 22 17,604 6,346 11,258 27 0.87 24 24 24 36 

7. Callf.-Nav. 25 4,577 1,320 3,257 3 2.35 6 5 7 29 

8. Pac.No.West 23 4,369 1,582 2,787 4 1.59 6 6 6 36 

9. Alaska 14 5,296 344 4,952 6 1.30 7 10 6 

AIlIHAs 178 74,072 26,225 47,847 100 1.00 100 100 100 35 

IHA and Marllat Type 

Umbrella - Alaska 13 5,256 344 4,912 6 129 7 10 7 

Umbrella - Other 11 5,755 869 4,886 9 0.89 8 3 10 15 

Naar Urban· Lg/OplHl 6 6,566 1,506 5,080 10 0.91 9 6 11 23 

Near Urban· Lg/CIIHI 1 56 56 o 2.00 o o 100 

Near Urban· Lg/OplLl 22 9,330 2,700 6,630 27 0.48 13 10 14 29 

Near Urban - Lg/c11L1 29 8,654 3,288 5,366 6 1.83 12 13 11 38 

Naar Urban - Small 17 1,417 514 903 3.18 2 2 2 36 

Navajo 1 6,317 3,063 3,254 17 O.SO 9 12 7 48 

Remote 72 29,989 13,720 16,269 25 1.60 40 52 33 48 

Unknown 4 712 165 547 1 23 

AIiIHAs 178 74,072 26,225 47,647 100 1.00 100 100 100 35 

Source: MIRS. 
Assessment of American Indian Housing Needs and Programs: Final Report 128 

The first six columns on Table 5.3 show the distribution of units in management that has 

resulted from these methods, first in absolute and then in percentage terms.39 Clearly, there is 

substantial variation, but that is not surprising given the variation Chapter 2 noted in the 

population size of Tribal Areas. 

The only way to sensibly assess the equitability of this distribution is to relate it to some 

measure of comparative need. This is done in the next two columns. The first shows the share 

of all low-income households residing in Tribal Areas in each category, as the need indicator. 

The second shows what we have termed the "allocation ratio": the ratio of the group's share of 

all units in management to its share of low-income households. If the distribution was perfectly 

equitable in this sense, all the measures in this column would read 1.00; i.e., each group would 

have the same share of assisted units that it had of low income households. But as the table 

shows this is not the result. Some groups have a considerably larger'than an equal share (ratio 

well in excess of 1.00) and some have less (ratio below 1.00). 

Chapter 3 of this report has already shown that HUD programs have made an impressive 

contribution to the housing needs of Tribal Areas overall, serving from 37 percent to 42 percent 

of all low-income households in those areas in 1990. That chapter also showed (Table 3.5), 

however, that some regions were serving much larger shares than others. This result is mirrored 

in Table 5.3.40 The South Central, California-Nevada, Plains, North Central, and PacificNorthwest regions all have shares of HUD units at least 50 percent greater than their shares of 

low-income households. The two regions containing the largest numbers of low-income AlAN 

households (Oklahoma and Arizona-New Mexico) are those that have received the least equitable 

shares of HUD assistance. 

One plausible hypothesis for explaining some of these differences was offered by several 

HUD staff we interviewed. For example, HUD's FONAP in Phoenix is responsible for both the 

Arizona-New Mexico and California-Nevada regions as we have defined them. Based on needs 

criteria, the Navajo reservation (which alone accounts for 57 percent of the Low-Income 

households in both regions, and 17 percent of the national total) has drawn in a substantial 

amount of resources to the Phoenix office in the first stage of the allocation process. It would 

appear that office, in the second stage of the process, has subsequently allocated a proportionally 

39The total number of units shown on this table differs slightly (by about 2 percent) from the official totals for the end 

cif 1993 given in Table 5.1 because this analysis used a MIRS data file prepared shortly before the end of that year 

which did not include all final completions. 

4<>rhe measures shown here are somewhat different from those in Chapter 3. Table 3.5 contained 1990 data for 

both low~income households and assisted units. Here we relate the 1990 distribution of low income households to the 

1993 distribution of units in management. Since differences in outcomes are inconsequential, it was felt that the 

complex task of recreating 1990 data on units in management for alliHAs to achieve exact comparability would not be 

justified. 
Assessment of American Indian Housing Needs and Programs: Final Report 129 

small share of the total it received back to Navajo, and has used a larger share to give some 

housing assistance to many of the small Tribal Areas that exist in Califomia and Nevada. As a 

result, the allocation ratio for the Navajo reservation is 0.50 (Le., the number of units it has in 

management is just half of the number it would have had if the allocation had been made strictly 

in proportion to the distribution of Low-Incomes households), while the ratio for the CalifomiaNevada region is 2.35 (Le., it has 135 percent more units that it would have had with a strict fare 

share allocation). A similar phenomenon may explain differences in the allocation ratios for our 

Oklahoma and South Central regions (both of which are administered by the Oklahoma City 

FONAP). 

There is a reasonable justification for some of this. In the case of the Phoenix office, for 

example, if its intemal allocation had been strictly on a fair share basis, the shares calculated for 

many of the small California Rancherias would have been below the minimum threshold 

necessary to start a viable housing program.41 There was also a historic bias. A strict fair share 

allocation would have meant that some tribes that had never participated in HUD programs before 

but wanted to do so, would have had to wait a much longer time to begin. Thus there may be 

good reasons for not allocating funds rigidly by a fair share formula. The question, however, is 

whether it is justifiable to move as far away from such a formula as the HUD allocation systems 

appear to have done historically. 

Is there any simple explanation of which types of tribes have received more than their fair 

share, and which have received less, in the allocations to date? Considering the allocation ratios 

for the other groupings shown in Table 5.3, no easily understandable pattern emerges. With 

respect to ACA performance, IHAs in the 2nd and 4th quartiles have gained substantially more 

than their fair share; with respect to IHA size, ratios are not as disparate, but those in the 2nd 

largest quartile have received as somewhat higher share that the others; with respect to area 

income IHAs in the two middle quartiles have a larger than fair share of HUD units, while both 

the poorest and least poor areas have less. 

This issue was examined more systematically using regression techniques. The number 

of units in management for each IHA was the dependent variable, and independent variables 

included: the number of low-income households in the area, the ACA performance rating, the age 

of the IHA (in years), the percent of all IHA units in the Rental program, and dummy variables 

representing the regions. This analysis explained only 89 percent of the variation the amount of 

41Another problem of particular relevance to this case (but also having an effect in other parts of the country) is the 

limitation of the Census data base related to Tribal Area boundaries as discussed in Chapter 1. It was noted that 

Census counts (including counts of the number of Low-Income residents which we have used as a basis for fair share 

assumptions) are not as reliable for smaller tribes (particularly those in California) where the real geographical expanse 

of the Indian community may be substantially larger than the trust land portion the Census used for its Tribal Area 

definitions. 
Assessment of American Indian Housing Needs and Programs: Final Report 130 

HUD-assisted housing the IHAs had received (see Annex 5A at the end of this chapter). Only 

two variables were significant (99 percent level): the number of low-income households in the 

area, and the age of the IHA; i.e., ACA performance, the Rental share, and regional location had 

little influence on the allocation. 

This would seem to imply that, while there are some serious individual inequities, the 

allocation of HUD-assisted units has been reasonably related to comparative needs overall and, 

not surprisingly, that IHAs that have been operating a program for a longer period of time have 

accumulated a larger share in comparison to need. 

The recent changes in the allocation system implemented by ONAP should improve the 

faimess of future allocations. Most important, has been the decision to rely on U.S. Census 

measures of need (rather than the BIA inventory) as the basis for making allocations to the 

regions (first implemented in 1994). Once the percent of need is established, regional allocations 

of funds are made on a "Fair share" basis with an adjustments made for regional differences in 

total development costs. 

Second, a new annual "Notice of Fund Availability" (NOFA) process has been 

implemented that gives clearer standard criteria for allocation within regions. Each application 

for new housing development is rated and ranked on the following factors: the relative unmet 

need compared to other applicants (based on waiting lists related to the number of units already 

in management and development); the IHA occupancy rate (data from MIRS); length of time since 

the last Program Reservation; and ACA performance ratings concerning IHA development and 

physical improvements activity. Additional points are provided for IHAs that have not been 

previously funded and for IHAs that are preplanning site selection and following other innovative 

approaches to development or financing which will reduce delivery time or expand the number 

of houses developed. ONAP is now conSidering the possibility of modifying this process to give 

much more weight to Census determined need across the board in making allocations within 

regions. 

Differences in the Mix of Rental and Mutual Help Housing 

Overall, 35 percent of all HUD-assisted units in management are in the Rental program. 

The last column of Table 5.3 shows that the Rental share varies considerably in different 

environments. 

In the categories shown, the Rental share appears to grow higher as ACA scores, IHA 

size, and area incomes decrease. For example, only 29 percent of the IHA stock are Rental units 

in the top quartile with respect to ACA performance, compared to 43 percent in the bottom 
Assessment of American Indian Housing Needs and Programs: Final Report 131 

quartile; the Rental share is 33 percent in the top quartile by IHA size, but 50 percent in the 

bottom quartile. 

Contrasts by region, however, are more pronounced. The clearest outlier is Alaska where 

only 6 percent of all IHA units are Rental units. Alaska FONAP personnel told us that this was 

a clear policy decision--for umbrella IHAs serving a number of small and very remote Villages, 

it is extremely difficult from a cost standpoint to provide the regular day-to-day operating and 

maintenance services that the Rental program requires. Oklahoma also has a comparatively low 

Rental share (at 16 percent). At the other extreme is the North Central region where 71 percent 

of all units are in the Rental program. The Plains region is also on the high side with 56 percent. 

As to market type, the Rental shares for the Remote group (46 percent) and Navajo (48 percent) 

are high compared to the average for those in or near large urban areas. 

Again, regression analysis was employed to analyze these variations more systematically. 

Here, the dependent variable was the Rental program share of alilHA units in management, and 

the independent variables were: the ACA performance rating, IHA size, the age of the IHA (in 

years), the percent of all households in the service area with low incomes, the distance of the 

Tribal area to the nearest large urban area, and dummy variables representing differences 

between the regions. This regression explained 52 percent of the variation in the dependent 

variable, but the only significant independent variable was the age of the IHA: i.e., the more 

recently the IHA was established, the higher its Rental program share of all units. (See Annex 

58 at the end of this chapter).42 

This is consistent with the history of the programs as already discussed. The older IHAs 

started building HUD-assisted housing in a period in which Mutual Help was being emphasized. 

IHAs that began their programs later were more likely to do so in the period when the Rental 

option appeared more attractive. And some regions developed the bulk of their programs in 

different eras than others. 

Characteristics of the Current HUD-Assisted Housing Stock 

While there are no square footage limits on HUD-assisted units, there are congressionally 

established development cost limits. Like other Federally-assisted housing, Mutual Help and 

Rental units are generally modest in size and design compared with typical new homes being 

offered on the private market. Almost all of these units, even in the Rental program, are detached 

single-family houses. The major difference is that Rental units tend to be built in clusters at 

42 Regional dummy variables were also significant in the regression, but these were set up only to reflect 

differences between Alaska, as the "reference region" and all other regions. Since the Alaska Rental share is quite 

different in this regard, this analysis does not reflect meaningful differences between other regions. 
Assessment of American Indian Housing Needs and Programs: Final Report 132 

densities which, while low by urban standards, are higher than is typical for Mutual Help homes 

(the latter, which do not have to be maintained or serviced by the I HAs, are often built in quite 

dispersed locations). 

Until recently, HUD standards required that all assisted units be provided with piped water, 

decent sanitation, and electricity, and that abutting roads be paved.43 While these expectations 

are commonplace in cities, they set HUD-assisted housing well above what is typical of other 

housing in many Tribal Areas. For example, one of our site survey staff remarked on how odd 

it seemed, "after a long drive on a minimal dirt road in an isolated part of South Dakota, to come 

upon a cluster of HUD assisted units where all the internal roads were paved and concrete curbs, 

gutters, and sidewalks had been provided." 

Expectations as to unit size and design have varied over the years. In the late 1970s the 

average size of HUD units had been increasing (reaching a peak of over 1,250 square feet in 

1980). HUD field office interviews indicate that strong management efforts were applied in the 

early 1980s to reduce per-unit costs. In response, average sizes for units completed between 

1984 and 1986 fell in the range from 500 to 900 square feet. Field offices received many reports 

that units at this level were too small to meet the needs of the families to be housed. 

Accordingly, while efforts were continued to try to reduce costs in other ways, pressure on unit 

size has been relaxed to some extent. Unit size increased during the late 1980s, and from 1990 

through 1993, averages for completed units have ranged between 1,250 and 1,500 square 

feet.44 

Another way to look at the size of Rental and Mutual Help units is in terms of the number 

of bedrooms they contain. Data are presented for our standard groupings in Table 5.4. Among 

all Rental units in management, 37 percent have 0-2 bedrooms, 42 percent have 3 bedrooms and 

the remaining 21 percent have 4 or more bedrooms. This appears to be a reasonable match to 

the household sizes of Rental program tenants reported by MTCS: 31 percent have 1-2 persons, 

38 percent have 3-4 persons, and 31 percent have 5 or more persons. 

43HUD's revised regulations for these programs no longer require that IHA units meet specific "HUD standards", but 

they must meet applicable local codes which, in turn, must conform to basic standards in national model codes. The 

latter generally expect the provision of water, sanitation, and electricity in all housing. However, there remains 

uncertainty as to how all of this is to be enforced, since HUD staff are no longer obligated to review and approve IHA 

building plans before construction. It seems likely that full infrastructure for IHA housing will remain the general 

expectation, but it may be possible now for less stringent requirements to be followed depending on local 

circumstances. 

44Data on unit sizes in this paragraph were tabulated from the MIRS system. Also see Figure 5.3 later in this 

chapter. 
Assessment of American Indian Housing Needs and Programs: Final Report 133 

Table 5.4 

IHA HOUSING STOCK 

PERCENT OF UNITS BY NUMBER OF BEDROOMS 

Percent Rental Unns Percent MH and Other Unns 

No. 

IHAs Total o-2BR 3BR 4+BR Total 0-2 BR 3BR 4+BR 

ACA Performance Rating 

Highest 25% 44 100 48 36 15 100 24 59 17 

2nd 25% 44 100 38 39 22 100 9 62 29 

3rd25% 44 100 31 45 23 100 11 55 34 

Lowest 25% 44 100 35 45 20 100 10 61 29 

AlIlHAs 176 100 37 42 21 100 15 58 27 

IHA Size (No. units) 

Highest 25% 45 100 37 41 22 100 16 58 26 

2nd 25% 43 100 38 44 19 100 10 61 29 

3rd25% 44 100 37 44 19 100 15 57 28 

Lowest 25% 44 100 39 44 17 100 18 59 24 

AlllHAs 176 100 37 42 21 100 15 58 27 

Area Income 

Highest 25% 43 100 59 29 12 100 24 59 17 

2nd 25% 43 100 39 41 19 100 6 59 34 

3rd25% 43 100 35 43 22 100 8 62 30 

Lowest 25% 43 100 26 48 25 100 12 54 34 

Unknown 4 100 61 24 15 100 8 68 24 

AlIlHAs 176 100 37 42 21 100 15 58 27 

Region 

1. No. Central 26 100 32 48 20 100 2 76 21 

2. Eastern 12 100 44 40 17 100 1 63 37 

3. Oklahoma 20 100 68 24 8 100 28 59 13 

4. So. Central 6 100 76 17 7 100 0 66 34 

5. Plains 28 100 34 44 22 100 2 63 35 

6. AriZ.-N.Mex. 22 100 27 47 26 100 9 58 33 

7. Callf.-Nev. 25 100 27 48 25 100 23 50 27 

8. Pac.No.west 23 100 39 40 21 100 8 53 39 

9. Alaska 14 100 90 9 1 100 18 54 28 

AlllHAs 176 100 37 42 21 100 15 58 27 

IHA and Market Type 

Umbrella - Alaska 13 100 90 9 1 100 18 54 28 

Umbrella - Other 11 100 39 39 22 100 7 60 32 

Near Urban - Lg/OplHl 6 100 65 25 10 100 24 57 18 

Near Urban - Lg/CIIHI 1 100 16 79 5 

Near Urban - Lg/Oplll 22 100 55 33 12 100 27 55 18 

Near Urban - Lg/CIIlI 29 100 27 46 27 100 10 58 32 

Near Urban - Small 17 100 54 35 11 100 14 55 31 

Navajo 100 23 53 25 100 8 58 33 

Remote 72 100 34 44 22 100 12 61 27 

Unknown 4 100 61 24 15 100 8 68 24 

AIIIHAs 176 100 37 42 21 100 15 58 27 

Source: MI RS. 
Assessment of American Indian Housing Needs and Programs: Final Report 134 

As would be expected, (since they are more oriented to serving families and less likely 

to have to accommodate independent elderly households, broken families, and individuals), 

Mutual Help units are more commodious on average: only 15 percent are 0-2 bedroom units, 58 

percent have 3 bedrooms and 27 percent have 4+ bedrooms. Again, there appears to be a 

reasonable fit in relation to household sizes reported by MTCS: 27 percent are 1-2 person 

households, 40 percent are 3-4 person households, and 32 percent have 5 or more persons. 

Table 5.4 shows that the distributions of units by number of bedrooms does not vary much 

in relation of IHA size. However, there are some other differences of interest. For example, IHAs 

in the highest quartile with respect to performance ratings seem to stand out from the rest in 

having a higher share of small units (48 percent of Rental units and 24 percent of Mutual Help 

units with 0-2 bedrooms). Similarly, the highest quartile with respect to area income also has 

shares of 0-2 bedroom units much above the average (59 percent for Rentals and 24 percent for 

Mutual Help). 

There is also considerable variation by region. The Alaska, South Central, and Oklahoma 

regions all have shares of Rental units in the 0-2 bedroom category that are significantly above 

average. Regions with above-average shares of small Mutual Help units are Oklahoma, 

California-Nevada, and Alaska. This appears reasonable for Oklahoma and California-Nevada 

where AlAN household size in Tribal Areas is comparatively small. It may indicate a problem, 

however, in Alaska Native villages which have higher than average shares of large families. (See 

Kingsley, Mikelsons, and Herbig, 1995, Table 3.2). 

Overall, these distributions (even in the Rental program, but particularly in Mutual Help) 

offer a stark contrast to the unit mix provided by the national public housing program (where 68 

percent of all units are 0-2 bedroom, 24 percent are 3 bedroom and only 7 percent are 4+ 

bedroom units). In other words, the IHAs have generally oriented the stock to respond to the 

unusually high proportion of large households found in Tribal Areas.4s Recall (from Chapter 2) 

that 27 percent of all AlAN households in Tribal Areas are families with five or more persons 

(compared to 16 percent for Indians in metropolitan areas and only 11 percent for the non-Indians 

on average nationally). Still, is the IHA unit-size distribution adequate? To answer that question 

it is necessary examine estimates of the extent of overcrowding, which is done in the section 

below. 

4S During the 1980s and early 1990s, it was in fact a legal requirement that large families be served first. 
Assessment of American Indian Housing Needs and Programs: Final Report 135 

The Quality of IHA Housing 

As noted in Chapter 3, comprehensive and objective measures of the incidence of housing 

problems in HUD-assisted units are not available. However, it is well-recognized that these units 

are not free from problems. 

Of the many interviews conducted as a part of this study, there was general consensus 

on several points. First, although they are in better condition than unassisted units, a 

considerable number of HUD-assisted houses in Tribal Areas do have physical deficiencies. 

Second, Rental program units, which are maintained by the IHAs, are in better condition generally 

than Mutual Help units.46 Third, overcrowding in IHA units is a significant problem. Relevant 

interview results are as follows: 

• 	 72 percent of the IHA directors responding to on-site survey questions on this topiC 

said that IHA units are in better condition than other units in their service areas. 

• 	 However, in telephone interviews (where almost all IHAs were contacted), IHA 

directors roughly estimate that, on average, 49 percent of their units needed some 

type of repair. 

• 	 When asked to rate the condition of different types of housing on a 5 point scale 

(1 being the worst and 5 the best), only 19 percent of tribal staff interviewed gave 

a 1 or 2 rating to IHA units; 30 percent, however, gave a rating in that range to 

unassisted units in their areas. 

• 	 On a similar scale, none of the tribal staff interviewed gave a 1 rating with respect 

to the "general physical condition" of IHA Rental housing; 7 percent did so with 

respect to IHA Mutual Help housing. 

• 	 Again using the same scale, 22 percent of tribal staff gave 1 or 2 ratings to the 

"adequacy of space" in Rental units whereas 29 percent did so for Mutual Help, 

indicating that overcrowding is often regarded as a serious problem in the I HA 

stock. 

While these indications are impressions of knowledgeable observers, they are nonetheless 

"impressions". A more accurate sense of the magnitude of these problems can be gained from 

4&rhis is due in particular to a problem already alluded to. In essence, Mutual Help families generally have quite 

low incomes in relation to the costs of homeownership--when utility prices accelerated in the 1970s, many simply did 

not have enough money for the maintenance needed to keep their units in good repair. 
Assessment of American Indian Housing Needs and Programs: Final Report 136 

the household survey data on Tribal Area housing conditions described in Chapter 3--the sample 

was small but the approach was systematic. 

According to this survey, 21 percent of all IHA units have serious facility or condition 

deficiencies as per the standards defined in Figure 3.2. The comparable shares work out to 14 

percent in Rental program housing and 24 percent in Mutual Help units. Estimates from this 

source of the total overcrowded (more than one person per room) and/or with facility/condition 

problems is 24 percent overall (18 percent in Rental units and 28 percent in Mutual Help). 

There is considerable overlap in this last category; i.e., many units are both overcrowded 

and have facility/condition deficiencies. Estimates vary, however, as to the total that are 

overcrowded. Estimates based on the household survey suggest that the share of alilHA units 

that are overcrowded is around 9 percent (95 percent confidence interval from 6 percent to 15 

percent). MTCS data, indicates a total of about 13 percent are overcrowded. When told about 

these results, several members of our panel of advisors said they thought these estimates might 

still be too low. All felt that overcrowded households in IHA units often understate the number 

of persons actually living in the unit when they contribute information used by the MTCS system, 

out of fear that they might face sanctions for having so many people living in their unit. 

Resident Perceptions of IHA Housing 

Another way to learn about the quality of IHA housing is to ask its residents for their 

perceptions. This was also done as a part of the household survey. Relevant findings are 

presented in Table 5.5. Again, due to the small sample size, 95 percent confidence intervals 

around the point estimates shown are fairly broad. Still, the overall patterns described below 

appear meaningful and generally consistent with findings reported above. 

Data on the top panel of this table tend to confirm the general reasonableness of the 

physical problem estimates given above. Respondents were asked how satisfied they were with 

their current housing unit. Those saying they were "most unsatisfied" represented only 5 percent 

of all households in IHA Rental units, and 19 percent in IHA Mutual Help units, but 51 percent in 

unassisted units. In other words, among the housing available in Tribal Areas, residents are most 

satisfied with the living conditions in IHA Rental units and most troubled with the condition of 

unassisted units--they see the quality of Mutual Help housing falling in-between. 

The table also indicates some consistency between resident perceptions and the 

independent observations of conditions provided in the household survey. In all cases a much 

higher percentage of the residents of units that actually have physical problems (as identified by 

the independent observations) indicated they were "most unsatisfied" with their units. In housing 

where no actual problems were observed, none of the Rental program tenants and only 6 percent 
Assessment of American Indian Housing Needs and Programs: Final Report 137 

TableS.S 

RESIDENT ATTITUDES ABOUT HOUSING IN TRIBAL AREAS 

IHA IHA NonRental MH IHA 

Total Units Units Units 

No. households responding 414 107 141 166 

PCT. SAYING "MOST UNSATISFIED" WITH UNIT 

Units with Census prob. 37 0 52 40 

UnHs other severe 38 18 13 49 

Units with no problems 7 0 5 13 

Total 25 10 20 35 

(95% confidence internal) 19-31 2-17 11-29 23-46 

PCT. RATING ITEMS AS SERIOUS PROBLEMS 

Storage space 29 16 29 37 

Insulation against cold 26 16 21 37 

Design/conlig. 01 rooms 17 10 20 19 

Water source/system 17 16 19 16 

Unit size 16 11 18 19 

Exterior appearance 16 13 11 22 

Heating 14 10 14 16 

Too close to neighbors 14 23 13 10 

Roads/accessibility 14 12 13 17 

Neighborhood appearance 12 15 11 10 

Solid waste disposal 11 4 13 15 

Source: Household Survey 

of the Mutual Help residents and 12 percent of the residents of unassisted units indicated they 

were "most unsatisfied". 

The bottom panel of the table shows some of the reasons for dissatisfaction. 

Respondents were also asked to identify features of their current house and location that they felt 

represented a "serious problem." The features most often identified were: inadequate storage 

space (29 percent), inadequate insulation against the cold (26 percent), design/configuration of 

rooms (17 percent), water source and system (17 percent), exterior design and appearance (16 

percent), and unit size (16 percent). 

Although the shares with "serious problem" ratings were almost always lower in IHA 

housing than in unassisted housing, the comparative priorities were generally similar. However, 

some differences are of interest. First, the most serious dissatisfaction among IHA Rental 
Assessment of American Indian Housing Needs and Programs: Final Report 138 

program tenants (23 percent) is that their units are too close to those of neighbors (corroborating 

the general desire for widely scattered settlement patterns noted in Chapter 3). This was much 

less of a problem to residents of Mutual Help and unassisted units. Second, "neighborhood 

appearance" was also seen as more of a problem for Rental program tenants, even though this 

was not the highest priority on their list. 

It is of interest that perceptions of overcrowding (as indicated by the share saying that their 

unit size was a serious problem) were somewhat more frequent than the 13 percent measure 

noted above as derived from MTCS data. This problem was identified by 11 percent of Rental 

program tenants, 18 percent 0 Mutual Help residents, and 19 percent of the residents of 

unassisted units. 

Tribal Views and Cultural Preferences 

As noted above, tribal staff interviewed on-site had generally favorable views of the HUDassisted units: only 19 percent giving it a "poor" (1 or 2) rating from the standpoint of physical 

condition. 

As to the location of units, a similarly defined poor rating was given by 19 percent for the 

Rental program and 7 percent for Mutual Help. That the Rental rating is this low is somewhat 

surprising, considering the fact that many residents think the density of the Rental projects is too 

high. However tribal interviews reflect the fact that IHAs often had very limited choice as to where 

to place Rental housing. 

Tribal staff were somewhat more critical of the design of HUD units, but those assigning 

a poor rating were still clearly in the minority. For the Rental program, poor ratings were given 

by 30 percent for exterior design and 26 percent for interior design. There was even less criticism 

of design in Mutual Help: poor ratings by 26 percent as to the exterior and 15 percent as to the 

interior. 

This was also something of a surprise considering much recent public criticism of the 

cultural insensitivity of housing built in Tribal Areas. More specifically, 75 percent of the tribal staff 

and 75 percent of the IHA directors interviewed on site said lack of sensitivity to cultural design 

features was not a major problem. As we interpret these responses, we do not believe they 

mean that cultural design issues are not important--it is just that they are not the highest priority 

in areas where the lack of basically adequate shelter is so great. As one respondent put it, "A 

safe, warm home of whatever style is more important." 

A more serious concern to the tribes appears to be a concentration of drug and crime 

problems in IHA Rental projects: 56 percent of tribal respondents said they "agree or strongly 
Assessment of American Indian Housing Needs and Programs: Final Report 139 

agree with the statement": There are drug problems in IHA units"--52 percent said the same 

about crime problems. 

Our surveys also asked about homelessness as a Tribal Area problem in on-site 

interviews: 67 percent of tribal leaders and 69 percent of IHA directors said it was indeed a 

problem. However, there was a strong consensus that it was a problem that, in Tribal Areas, gets 

fully converted into the problem of overcrowding. They indicate that many individuals and families 

do not have their own homes but, as one said, " ... because of family ties, people take in other 

families, there's a lot of overcrowding." Another told us, "homeless people are not living on the 

streets but within families . . . transient people move around from family member to family 

member in order to have a place to stay." 

Program Beneficiaries 

Data from HUD's MTCS system show that the Rental and Mutual Help program are 

overwhelmingly serving the types of beneficiaries they were intended to serve--poor American 

Indian and Alaska Native households. 

Overall, 92 percent of all occupants of IHA housing are American Indians and Alaska 

Natives. The Mutual Help Program, for which Indian preference is a statutory requirement, is 98 

percent AlAN occupied, while the Rental Program is 84 percent AlAN occupied. Mutual Help 

requirements prohibit occupancy by non-Indians except in a few limited circumstances. This is 

not true in Rental program housing. 

AlAN occupancy is close to 100 percent for Mutual Help units in virtually all locations, but 

there is notable geographical variation in this share in the Rental program. Most of the non-Indian 

occupants are located in two regions (Oklahoma and Alaska) where IHAs were formed under 

state law as public housing authorities and were prohibited from favoring any racial group for 

occupancy (see data presented on this topic in Chapter 3, Table 3.5). 

Households must be Low-Income (income less than 80 percent of the local median) to be 

eligible for these programs, but the data show that the income of the typical resident of IHA 

housing is well below even that level: 68 percent of all occupants of IHA units have Very LowIncomes (less than 50 percent of median). VLI households make up 90 percent of the total in 

the Rental program and 52 percent in Mutual Help. 
Assessment of American Indian Housing Needs and Programs: Final Report 140 

The average annual income of the tenants in the Rental Program is $8,800 (Table 5.6).47 

The 90 percent VLI share in Rental units is about the same as the public housing program 

nationwide. 

The average income of Mutual Help occupants is higher: $18,300. The original intent of 

the Mutual Help Program was to provide homeQwnership opportunities to very poor AlAN families. 

When the program started in 1962, in fact, it appeared more feasible for a poor Indian family to 

participate in Mutual Help than in the Rental program because the latter required a higher 

occupant contribution to housing costs (Housing Assistance Council, 1988). Also, with the 

contribution of land, materials, or labor, it was expected that Mutual Help would entail a lower 

aggregate subsidy cost than the financing and operating charges of the Rental program. As 

noted earlier, however, that rationale changed as costs of homeownership (particularly utility 

costs) accelerated in the 1970s, and Rental program revisions allowed the provision of significant 

operating subsidies. Today, that families in Mutual Help units have higher incomes than those 

in Rental units is essential to make Mutual Help operationally feasible. Still, the Mutual Help 

averages remain well in the Low-Income range. 

Table 5.6 shows that, for both programs, average incomes do not vary substantially by 

IHA performance, IHA size, or area income levels. There is, however, more noticeable income 

variation by region. In the Rental program, average tenant incomes in the Alaska and North 

Central regions are more than 30 percent above the program average, while those in the 

Oklahoma and South Central regions are more than 20 percent below that average. In Mutual 

Help there is generally less regional variation, but Alaska again stands out with a level much 

above the program's national average. Nonetheless, we doubt that these variations imply that 

the regions at the extremes are serving a very different clientele. Regional differences in living 

costs probably explain much of the variation shown here. Living costs in Alaska, for example, 

are much higher than is typical in the "lower forty-eight." 

Probably the most striking finding conveyed in Table 5.6 relates to the sources of resident 

incomes in IHA housing. The popular image is that most of the tenants in the national public 

housing program do not work, and indeed MTCS data show that only one quarter of them derive 

income from wages. This is a marked contrast to Mutual Help occupants in Tribal Areas, 71 

percent of whom have wage income. Even the share of wage earners in the Indian Rental 

program (34 percent) is much above that for public housing. Thus, HUD-assisted Indian housing 

is not serving a dominantly "public assistance oriented" clientele. Most residents work, but as the 

income data imply, their wages are typically extremely low. 

47Note that this table includes data for only 148 IHAs. As mentioned in Chapter 1, the MTCS is a relatively new 

data base and it does not yet provide full coverage. The total household reporting rate for the MTCS data cited in this 

table is 59 percent. 
Assessment of American Indian Housing Needs and Programs: Final Report 141 

Table 5.6 

HOUSEHOLD INCOME AND SOURCES OF INCOME 

Rental Households MH Households 

No. 

IHAs 

Avg. Hhld 

Inc. 

Pd. 

Wage 

Pd. 

Ss/Pen. 

Pd. 

Public 

Avg. Hhld 

Inc. 

Pd. 

Wage 

Pd. 

SS/Pen. 

Pd. 

Public 

ACA Performance Rating 

Highest 25% 

2nd 25% 

3rd25% 

Lowest 25% 

A1IIHAs 

40 

41 

36 

31 

148 

7,722 

8,377 

8,967 

10,374 

8,821 

26 

34 

40 

40 

34 

34 

27 

22 

23 

27 

46 

39 

42 

35 

42 

17,781 

18,415 

19,023 

17,647 

18,259 

71 

74 

69 

75 

71 

24 

18 

21 

19 

21 

14 

13 

16 

11 

14 

IHA Size (No. units) 

Highest 25% 

2nd 25% 

3rd 25% 

Lowest 25% 

A1IIHAs 

39 

40 

40 

29 

148 

7,862 

9,258 

8,046 

10,882 

8,821 

30 

41 

43 

46 

34 

29 

25 

23 

28 

27 

47 

36 

30 

26 

42 

17,386 

19,972 

17,606 

17,964 

18,259 

69 

75 

78 

72 

71 

22 

21 

16 

20 

21 

15 

15 

9 

16 

14 

Area Income 

Highest 25% 

2nd 25% 

3rd25% 

Lowest 25% 

Unknown 

A1IIHAs 

36 

34 

39 

36 

3 

148 

8,372 

9,317 

8,344 

9,333 

7,545 

8,821 

28 

33 

30 

42 

36 

34 

39 

24 

24 

23 

29 

27 

41 

44 

46 

37 

35 

42 

18,734 

19,723 

17,423 

17,406 

16,420 

18,259 

70 

77 

72 

69 

75 

71 

25 

19 

17 

21 

20 

21 

13 

11 

15 

18 

11 

14 

Region 

1. No. Central 

2. Eastern 

3. Oklahoma 

4. So. Central 

5. Plains 

6. Ariz.-N.Mex. 

7. Calif.-Nev. 

8. Pae.No.West 

9. Alaska 

A1IIHAs 

22 

9 

19 

4 

24 

21 

19 

18 

12 

148 

11,554 

8,639 

6,811 

6,314 

7,902 

8,395 

8,373 

8,342 

11,689 

8,821 

45 

40 

23 

28 

28 

41 

37 

31 

14 

34 

25 

28 

44 

39 

26 

20 

20 

22 

79 

27 

38 

35 

42 

26 

48 

38 

39 

47 

42 

42 

19,098 

17,687 

14,430 

16,330 

18,370 

17,692 

18,266 

16,868 

26,733 

18,259 

75 

79 

67 

77 

73 

72 

72 

69 

74 

71 

17 

18 

27 

24 

18 

18 

18 

18 

23 

21 

16 

7 

14 

5 

14 

13 

14 

19 

19 

14 

IHA and Market Type 

Umbrella - Alaska 

Umbrella - Other 

Near Urban - Lg/OplH 

Near Urban - Lg/OpAJ 

Near Urban - Lg/CIA.I 

Near Urban - Small 

Navajo 

Remote 

Unknown 

A1IIHAs 

12 

10 

6 

20 

20 

15 

1 

61 

3 

148 

11,689 

7,534 

7,264 

9,122 

9,585 

8,437 

10,963 

8,488 

7,545 

8,821 

14 

31 

23 

28 

45 

35 

48 

32 

36 

34 

79 

25 

42 

37 

20 

31 

24 

24 

29 

27 

42 

47 

44 

44 

34 

26 

38 

44 

35 

42 

i 

26,733 

16,640 

15,093 

16,972 

17,079 

17,681 

17,807 

18,114 

16,420 

18,259 

74 

69 

65 

70 

77 

76 

69 

71 

75 

71 

23 

20 

28 

24 

16 

17 

20 

21 

20 

21 

19 

14 

15 

15 

9 

10 

18 

14 

11 

14 

Source: MTCS. 
Assessment of American Indian Housing Needs and Programs: Final Report 142 

Summary and the Question of Demand for IHA Housing 

The sections above make it clear that housing provided by HUD's Rental and Mutual help 

programs does have its problems. The share of all units with physical deficiencies, though much 

lower than that for unassisted housing in Tribal Areas, is Significant nonetheless. And the extent 

of overcrowding is far from trivial. Also, past allocations systems have resulted in some 

inequities--IHAs serve a much larger share of all families in need in some areas than they do in 

others. 

Still, it is difficult not to be impressed by the contributions these programs have made in 

Indian country. They now provide decent shelter to around 67,000 Low-Income American Indian 

and Alaska Native households--from 37 to 42 percent of all Low-Income households in Tribal 

Areas (almost twice the share served by HUD-assisted programs in the rest of the nation). And 

a very large share of those being served are among the poorest of the poor in America. 

There is no way to accurately estimate what would have happened if these programs had 

not existed, but it seems certain that housing conditions in Tribal Areas would be much worse 

than they are today. It is likely that those conditions would have furthered additional outmigration 

from many traditional centers of Indian culture. In fact, it seems quite possible that some small 

tribes that now have high percentages of HUD units might have been forced to disband as 

recognizable communities altogether. 

There is also evidence that demand remains high for additional assisted housing in these 

areas. While the overall vacancy rate in the national public housing program is 8.0 percent, the 

program's image has been tarnished by many-big city programs where very large shares of their 

apartments remain vacant and unused. Nothing similar exists in HUD's Indian housing programs 

and the overall vacancy rate is significantly lower than that of public housing (averaging 6.0 

percent). Furthermore, our IHA telephone survey indicates that waiting lists for Rental and Mutual 

Help units remain enormous; the number of households on waiting lists averages about half of 

the total number of existing IHA units. 

However, while these data show that an important contribution has been made, they do 

not yet address the question of whether that contribution has been made efficiently. The 

remaining sections of this chapter examine that issue as a basis for considering possible 

alternative forms of delivery. 
Assessment of American Indian Housing Needs and Programs: Final Report 143 

DEVELOPING NEW HUD-ASSISTED HOUSING 

The Context 

This section reviews the steps in the process followed to develop new IHA housing in 

Tribal Areas (and the time required for it), considers the extent of pre-planning and difficulties in 

site selection, examines variations in the cost of new housing provided, and offers interpretations 

regarding the efficiency of this process. 

Before beginning the review, it is important to comment on the context in which this 

development process takes place. Most IHA projects are built in rural setting many of them quite 

remote from urban areas. This in itself has important implications, creating challenges that do 

not exist in building housing in a major metropolis. 

Perhaps the most important difference relates to the provision of physical infrastructure. 

In metropOlitan settings, basic off-site infrastructure systems are largely already in place near the 

new development site, including: sewers, landfills, electricity, water availability and water 

treatment, and paved roads. It is a comparatively simple and inexpensive matter to connect up 

to them. In Indian country, however, these broader systems often do not exist. Very large capital 

investments may be required to provide this infrastructure for new IHA developments. 

A second problem might be thought of as the lack of adequate "institutionallnfrastructure." 

In large cities, many well-staffed institutions exist to facilitate and implement the development of 

new housing. These include a variety of private developers and contractors with specialized skill, 

a range of competitive materials suppliers,48 private financial institutions, and a number of 

governmental actors (ranging from planners to building inspectors). 

In addition, Tribal Area settings often imply special problems that constrain land 

availability. These clearly include the complexity of trust land relationships discussed in Chapter 

1 , but they also include special environmental and other restrictions. Notable in this regard is the 

prevalence of archeological and traditional burial sites which must be avoided. 

481HA directors interviewed in the telephone survey, however, generally appear to be more concerned aboutthe cost 

of construction materials than problems in obtaining them from suppliers. Nearly 90 percent of IHA directors reported 

that they saw the cost of construction materials as a serious problem, while only 45 percent said supply was a problem. 

Supply problems were most often reported by directors in the North Central, Oklahoma, Pacific-Northwest and, as 

expected, Alaska regions. 
Assessment of American Indian Housing Needs and Programs: Final Report 144 

The Development Process 

The IHA development process begins when the IHA receives a "reservation" for new 

housing as a result of the allocation discussed earlier in this chapter. 

The next important step is a "coordtnation meeting" which, until 1994, was always 

convened by HUD regional staff.49 This meeting is attended by the IHA along with 

representatives of the BIA, IHS, and other relevant tribal and/or government officials. In some 

cases, wherelHAs have done a considerable amount of pre-planning and negotiating, these 

meetings may result in brief reviews and confirmations of IHA plans, along with establishing 

mutual agreements about roles and timing in the development schedule. 

In other cases, they may be more extensive. All partiCipants may visit and provide 

suggestions about alternative sites being suggested, and consider alternative development 

concepts for each site. The meetings may result in a list of additional tasks the IHAs have to 

perform before they can proceed (e.g., additional engineering and environmental studies to assure 

a site is suitable for housing as proposed). In some cases, problems may emerge with respect 

to the BIA's ability to provide the necessary road access or the timing of IHS infrastructure 

provision that must be resolved. 

After any issues arising in the coordination meeting are settled and sites and development 

concepts have been approved, the IHA has preliminary building plans and a development budget 

prepared. 

These are then submitted to HUD for review and approval. In the past, these reviews 

were often extensive. HUD has gradually reduced its review of the architectural plans over the 

years and with the new regulations (eliminating separate HUD standards and requiring only that 

IHA structures meet local code requirements) it eliminated this aspect of the review altogether. 

HUD must still review the development budget, however. Total Development Cost (TDC) 

limits for different areas within each region in the country are established by Congress to reflect 

real locational variations in the prices of construction inputs. These are revised annually. The 

process entails estimating the baseline cost of a prototype (1,080 square foot) house, and then 

making adjustments for different areas using standard private indexes that reflect local price 

variations (Marshall and Swift, and Boeks).50 In the past, HUD regional offices could approve 

49HUD's new 1994 regulations for Indian housing permit the IHAs to arrange for and conduct these meetings 

themselves. HUD staff no longer need to be involved. 

50Consistent with requirements of the Davis-Bacon act, which must be complied with in all IHA construction, union 

wage rates are assumed throughout. 
Assessment of American Indian Housing Needs and Programs: Final Report 745 

amounts up to 110 percent of the TDC--under the new regulations, IHAs can go up to that level 

without HUD approval. 

When approval has been granted, the IHA can enter into the necessary contractual 

arrangements and begin construction. It may use one of several methods: conventional (where 

the IHA acts as the developer and hires and manages the work of contractors); turnkey (where 

the IHA contracts with a developer to schedule and manage the entire construction process); 

force account (where the IHA manages all of the work directly using local tribal labor); and selfhelp (where Indian families build their own units with limited assistance and supervision from the 

IHA). IHAs may also bring new housing into their inventory by acquiring existing units (with or 

without rehabilitation). 

IHA on-site survey data indicate that 70 percent use the conventional method (although 

no IHAs in Oklahoma or the South Central region do so). Thirty-five percent use force account 

for new construction; less than 20 percent use turnkey. Not surprisingly, only 25 percent use 

acquisition, due to the lack of available units in most Tribal Areas. Acquisition is used as a major 

method only in Oklahoma. No IHA interviewed uses the self-help method. 

In the mid-1980s HUD considered that typical project development periods were 

unreasonably long and took a number of steps managerially to expedite the process. These 

efforts, in cooperation with those of the IHAs, have made a significant difference. The average 

period from funds reservation to construction start dropped from 38.7 months in 1985 to 28.4 

months in 1993. The average construction period has not changed as much (from 13.1 months 

in 1985 to 12.8 months in 1993). 

Because these averages include a number of projects that had been much delayed, they 

overstate modal performance. Most IHA directors interviewed in the on-site survey felt that it was 

now possible to move through this process much more quickly than these averages suggest. Of 

those making estimates, 70 percent said they currently have a development time frame of 20 

months or less from reservation to final occupancy. This almost always requires careful preplanning before the initial coordination meeting. At least one IHA has recently moved a project 

from reservation to completion in less than six months. 

Program Planning 

Clarity in program strategies can expedite the delivery of housing and assure that what 

is provided matches real needs effectively. Yet fewer than half of IHAs (41 percent) reported in 

the telephone survey that they had a comprehensive housing plan; only 51 percent said they had 

a formal housing needs assessment. The best record in this regard was in the Eastern region 

where 60 percent had a comprehensive plan; the worst was among the 10 umbrella IHAs outside 
Assessment of American Indian Housing Needs and Programs: Final Report 146 

of Alaska, only one of which had such a plan. Only a third of the tribal staff interviewed on-site 

said that the tribe had comprehensive housing plans and most told us the plans they had were 

old and out of date. Only 14 percent said the tribe had a housing needs assessment. 

Although the question was not asked directly in the survey, several IHA directors 

volunteered that they felt their operations were most hampered by the lack of a clear tribal land 

use plan. One remarked: "If the tribe had a plan, I would know were the future areas for housing 

were going to be and I could start working to get the infrastructure coordinated for those locations 

... as it stands, site selection decisions are very political and based on short-term thinking. We 

wind up wasting a lot of money by taking the infrastructure out to locations in all directions." 

Providing Land 

While the dominant visual impression in many Tribal Areas is one of vast expanses of 

unused land, land availability appears to be an important constraint on IHA housing development 

in many of them. The land is there, but legal, regulatory, and political problems often make it 

difficult to assemble sufficiently large parcels in reasonable locations for new housing. Interviews 

with IHA directors and tribal staff yielded the same assessment of the extent of these problems-­

40 percent of both groups mentioned the availability of land as a major barrier. 

In some cases these were problems related to ownership or rights of use; 53 percent of 

the IHA directors who responded noted difficulties beyond the basic trust relationship (such as 

conflicts over assigned or allotted lands, problems in getting agreements from multiple-heirs to 

an allotted parcel, or use restrictions due to tribal ordinances or customs). Responses to this 

question varied (e.g., all directors in the Pacific-Northwest said they faced such problems), but 

in no case was the rate much below 50 percent. 

In the field interviews, one IHA director said, "There are historical land assignments that 

can't possibly be taken away ... many of these pieces are very fractionated ... it makes it very 

hard to do rational planning and development." Another, in Oklahoma, said his major problem 

was" getting extension of original 25 year agreements to other than original landowners ... BIA 

has now authorized extensions but there is still confusion as to whether they have the authority 

to do so." Yet another said, "Land ownership issues are a huge obstacle ... lots of this land is 

not developable for the IHA because the tribe wants to keep the flat portions for agriculture ... 

the tribe gives land allotments to various families and often these allotments are in dispute." 

One aspect of land assembly that did not appear to be perceived as a major problem by 

the IHAs was BIA processing of land leases. In the telephone survey, only 16 percent of the 

directors said the BIA was "not very cooperative" in this regard. 
Assessment of American Indian Housing Needs and Programs: Final Report 147 

A second class of constraints relates to environmental or similar restrictions that prohibit 

the use of a considerable amount of tribal land for housing. Responses on these issues from the 

IHA telephone survey are given in Table 5.7. Overall, such problems reported as adding to costs 

were wetlands restrictions (mentioned by 16 percent), restrictions related to archeological or burial 

sites (12 percent), water quality problems (9 percent), and contaminated soils (6 percent). The 

frequency of these problems varied by region; for example, the incidence of wetlands issues was 

significantly higher in the coastal regions than in the nation's mid-section. However, most of 

these difficulties were noted at least to some extent in most regions. 

Providing Infrastructure 

The major developmental problem related to infrastructure is simply the conflict between 

triballocational preferences and costs. As noted in Chapter 3, with some exceptions (e.g., the 

Pueblos), Indians in Tribal Areas generally appear to prefer dispersed locations for their housing. 

When standards require paved roads and utilities for IHA units, high costs are inevitable if such 

locational preferences are to be adhered to. 

Some tribal and IHA officials interviewed in the field surveys felt strongly that the 

requirements should be more flexible. One tribal chairman said, "Many of my people want to live 

in the remote valleys where they can earn their livelihood raising their animals in the traditional 

way, and it will never make sense to provide electricity there ... they have done just fine with 

kerosene lamps and wood stoves for a very long time--it is a great frustration to me that we can't 

use HUD money to build decent basic shelter for them there." One IHA director remarked that, 

"electrical hookups, paved roads, and curbs and gutters certainly should be dropped ... Although 

the reservation is 90 percent wired for electricity, many people do not use it, even if it's in the unit, 

because they cannot afford it ... HUD should let us fund the construction of a basic house with 

a hope that people will add on amenities and other things when they can." 

But these views appear to be a minority opinion, albeit a sizeable one: in the telephone 

survey, 24 percent of IHA directors said they thought requirements for infrastructure should be 

dropped. The only region where a majority of directors thought they should be dropped was 

Arizona-New Mexico. 

There are no indications that coordination with other Federal agencies is a major problem 

in the provision of infrastructure for IHA projects. Of alliHAs responding to the telephone survey, 

91 percent still rely on the IHS for water and sewer construction (although they are no longer 

obligated to do so), and 77 percent rated their working relationship with the IHS as good or 

excellent. One third rated the BIA as "not very cooperative" in coordinating the funding and 

construction of roads. However, several pOinted out that the problem here was more one of 

insufficient funding holding up the provision of needed roads for new IHA developments, rather 
Assessment of American Indian Housing Needs and Programs: Final Report 148 

TableS.7 

IHAs REPORTING REGULATORY BARRIERS TO DEVELOPMENT 

Contain- Arch! 

No. Wet­ inated Burial Water 

IHAs lands Soil Site Quality Other 

ACA Performance Rating 

Highest 25% 42 11 15 19 4 33 

2nd 25% 44 31 0 3 7 24 

3rd 25% 40 14 7 21 11 25 

Lowest 25% 41 9 3 6 13 31 

AlllHAs 167 16 6 12 9 28 

IHA Size (No. units) 

Highest 25% 43 9 3 26 9 20 

2nd 25% 42 17 3 7 7 37 

3rd25% 41 22 13 9 9 26 

Lowest 25% 41 21 7 4 11 32 

AlIIHAs 167 16 6 12 9 28 

Area Income 

Highest 25% 42 27 7 13 3 30 

2nd 25% 41 18 4 14 7 36 

3rd 25% 40 7 7 10 10 23 

Lowest 25% 40 12 8 12 15 27 

Unknown 4 50 0 0 0 0 

AlllHAs 167 16 6 12 9 28 

Region 

1. No. Central 26 19 0 13 13 31 

2. Eastern 10 29 14 14 0 43 

3. Oklahoma· 20 18 0 27 9 36 

4. So. Central 4 0 0 0 0 50 

5. Plains 28 9 4 13 17 17 

6. Ariz.-N.Mex. 20 7 0 29 7 36 

7. Calif.-Nev. 23 6 25 0 0 38 

8. Pac.NoWest 23 40 0 7 13 20 

9. Alaska 13 17 8 0 0 17 

AlllHAs 167 16 6 12 9 28 

IHA and Market Type 

Umbrella - Alaska 12 18 9 0 0 18 

Umbrella - Other 10 0 29 14 0 43 

Near Urban· Lg/OplH1 6 0 0 0 25 75 

Near Urban· Lg/CIIHI 0 0 0 0 100 

Near Urban - Lg/OplL1 21 33 0 13 7 27 

Near Urban - Lg/CIILI 29 13 0 13 7 53 

Near Urban - Small 16 40 0 0 20 20 

Remote 68 10 8 18 10 20 

Unknown 4 50 0 0 0 0 

AlIIHAs 167 16 6 12 9 28 

Source: Telephone Survey. 
Assessment of American Indian Housing Needs and Programs: Final Report 149 

than one of lack of effort or effectiveness by local BIA staff. 

The Indian Preference Requirement 

The IHA telephone survey indicated, on average, that 20 percent of IHA units in 

management had been built by an AlAN developer; regionally, this response ranged from a high 

of 25 percent in Arizona-New Mexico to a low of 12 percent in the North Central region. Clearly, 

the use of legitimate Indian developers and contractors to build IHA housing can provide an 

important economic development bonus from HUD assistance for the tribe. There appears to be 

substantial doubt, however, that the current requirement for "Indian preference" in this regard is 

working effectively. 

Of alllHA directors who responded to the telephone survey, more than half (52 percent) 

said that Indian preference regulations had not met their goal of employing more Indians. This 

varied significantly by region; almost all directors in the North Central and Arizona-New Mexico 

regions said it was meeting its goals, but those in the Eastern and Pacific-Northwest regions 

overwhelmingly said it was not. 

Most IHA directors approve of the intent of Indian preference but many find it difficult to 

put into practice, and feel that it adds unnecessarily to the time and cost of the bidding process. 

Major reasons cited include: a lack of qualified Indian contractors in the area, the use of fronts 

and fraudulent joint ventures which make firms Indian in name only, and sometimes being forced 

to use qualified firms outside the region who do not understand local conditions. 

Development Costs 

Earlier in this chapter we noted the effort by HUD to reduce the development costs of IHA 

housing in the early 1980s. Initially this took the form of exerting pressure to build smaller units, 

but this aspect of the policy was reversed and (as discussed earlier and shown on Figure 5.2) 

the average unit-size increased again through the early 1990s. What is of most interest is that 

the average development cost per square foot did not follow a similar path. Rather, it has 

declined fairly consistently in real terms over the past decade, dropping from a 1981-83 average 

of $96 to the 1991-93 average of $65 (constant 1993 dollars). 

Analysis to gain a full and reliable understanding of how this was accomplished was 

beyond the scope of this study, but we were told by HUD field office personnel that it occurred 

through a combination of: (1) consistent management pressur~s to promote more efficient designs 

and construction practices; and (2) some reduction in standards (e.g., the provision of less 

storage space, selection of lower cost materials). 
Assessment of American Indian Housing Needs and Programs: Final Report 150 

crsr/ 19) ,-----------------------, 1,50(~FL 

s:lFT. LNT 

1,250 

1,000 

750 

500 

250 

o~______________________________ ~ 0

19/8 lIB) 11l!6 1!Bl 

FIGURE 5.2 Unit Size and Development Cost per Square Foot, 1978-1993 

Figure 5.3 shows that there is considerable regional variation in per square foot 

development costs around the 1991-93 $65 average.51 Alaska is clearly the outlier, with a cost 

of $121, almost twice the national average. Costs in all other regions fall in a narrower range, 

from $49 (in the North Central and Eastern regions) to $76 (Pacific-Northwest). 

There were also variations in the average size (square footage) of the units produced 

during the 1991-93 period, and this led to a pattern of total costs per unit that did not always 

match the pattem evidenced for cost per square foot. The 1991-93 average development cost 

per unit was $85,700. The lowest totals were recorded in the Eastern, Oklahoma, and Plains, 

and Arizona-New Mexico regions (all in the $50,000-$60,000 per unit range). But these were 

offset by much higher costs in the Alaska, California-Nevada, and North Central regions (all with 

averages over $1 00,000). Unit costs for Arizona-New Mexico ($76,900) and the Pacific-Northwest 

($85,600) fell in between. 

51A cost figure for the South Central region is not provided in this chart because information for only one completed 

project in this region was available in the data base for the 1991-93 period, 
Assessment of American Indian Housing Needs and Programs: Final Report 151 

Average Cost/Sq. Ft. (1991-93) $ 

o 20 40 60 80 100 120 140 

AVERAGE 65 

REGIONS 

No. Central •••••••111 49 I 

Eastern •••••••11 49 I 

Plains •••••••••: 59 

Ariz-N. Mexico •••••••••: 59 

Cal-Nev •••••••••• 67 I 

Pac. No. West •••••••••••111 16 

Alaska ••••••••••••••••••• 121 

FIGURE 5.3 IHA Development Costs per Square Foot, 1989-1993 

Even though this range is substantial, there is no evidence that it reflects any major 

differences in production efficiency. Other factors play an important role in determining these 

outcomes. First, there are substantial differences between regions in local input prices for 

construction (labor, materials, and equipment). These are reflected in the TOCs which constrain 

what any IHA can produce. In the 1991-93 period, construction prices in Alaska and Califomia, 

for example, were substantially higher than those typical of the rest of the country.52 

Second, there are legitimate differences in the way various IHAs and tribes choose to use 

the allocations they receive. Some design somewhat less costly units (smaller and/or with less 

expensive fixtures, etc.) so that, for a given amount of funding, they can serve a larger share of 

all families in need. In other words, they deliberately choose to spend less per unit that the TOCs 

would allow. Others choose to produce larger and higher quality units and spend close to the full 

TOC limitation--necessarily therefore, they can afford fewer units for the same allocation of funds. 

Interviews with central and regional HUO staff indicate that important differences in individual 

tribal approach along these lines exist within almost all regions. 

52For example, Davis-Bacon wage rates in California are more than half again as high as in Arizona due to 

California's higher union labor rates. 
Assessment of American Indian Housing Needs and Programs: Final Report 152 

Interpreting Standards and Costs 

A full analysis of the cost-efficiency of the IHA development process would require detailed 

comparisons of IHA and private costs for different housing types in a number of areas of the 

country--a task much beyond the resources available for this study. Available evidence seems 

to suggest, however, that: (1) some inefficiencies probably remain in the IHA process; but (2) it 

is difficult to argue that the resulting costs are substantially above what they should be given the 

type of housing being produced, particularly in many of the remote regions. 

Indications that costs could be reduced largely relate to unreasonable delays that remain 

in the system and, as is well known in construction, delays cost money. As FONAP and ONAP 

staff generally admitted to us, ten years ago the HUD review process would probably have been 

cited as the most serious factor in this regard, but this issue seems mostly to have evaporated 

with recent changes in regulations and practice. 

Yet, IHA directors cite other factors that still slow down the development process: (1) the 

lack of overall planning which frustrates project site selection and infrastructure provision; 

(2) increasing difficulty in securing appropriate land for IHA housing developments; (3) the well 

intended requirement to give preference to Indian contractors (at least in some areas); and, to 

a more modest extent (4) some interagency coordination problems in infrastructure provision. 

Several IHAs mentioned other factors they believe push cost up unreasonably (most 

frequently, Davis-Bacon requirements). Nonetheless our review of the cost results for the regions, 

on average, did not suggest that IHA costs were significantly different from private construction 

in the same areas, given the type of unit being produced and, in particular, considering the basic 

problems of developing housing in more remote locations (as discussed in the context section at 

the beginning of this chapter). 

Nonetheless, the type of unit being produced does remain an issue. Under the present 

system, while a significant fraction of the households in need are benefiting from substantial 

subsidies, even larger numbers in similar circumstances receive nothing. This inequity could be 

remedied if more families could be assisted for the amount of HUD funding provided, with 

programs producing decent basic homes at lower cost. Given our conclusion above, it would 

appear that the only way to significantly reduce costs would be to reduce infrastructure and other 

standards and rely more on self-help techniques, at least for some portion of the IHA 

development pipeline. 

Through the early 1980s HUD regulations mandated fairly high technical standards for IHA 

units and these clearly set limits on how much costs could be trimmed. HUD-imposed standards 

have now been largely eliminated, but compliance with minimums in accepted national codes is 
Assessment of American Indian Housing Needs and Programs: Final Report 153 

still required and old traditions with respect to standards linger on--a natural tendency to use 

housing designs that have worked in the past rather than search for lower-cost, potentially 

controversial, altematives. 

Still, there remains a great need to find a way to provide decent basic shelter for more 

families at lower costs per unit. Most IHA directors interviewed on-site saw this as possible 

(although all did not necessarily endorse doing so); 62 percent answered yes to the question as 

to whether they could build more units if standards and other HUD requirements related to 

construction were relaxed.53 

Some tribes are experimenting with lower cost approaches as a part of the HOME 

program--the national average development cost for projects proposed under the Indian HOME 

program in 1992 was $51,600 per unit (see further discussion in Chapter 6). On the whole, 

however, most IHAs do not appear to be pressing to try lower cost solutions. Indeed, many do 

not seem to recognize that the old HUD standards have been dropped, even through this fact has 

been clearly publicized. 

OPERA TlNG AND MAINTAINING THE ASSISTED HOUSING STOCK 

This section opens with a review of the functions IHAs have to perform in the ongoing 

operation of the Rental and Mutual Help programs, once units are built. It then reviews the costs 

of operating these programs and how they are funded (mix of HUD, tenant, and other 

contributions) and problems associated with collecting payments from the residents. Finally, it 

examines key operating functions: tenant selection, maintenance, and modernization. 

IHA Functions 

When new units are built under the Rental program, IHAs take on comprehensive 

responsibility for their subsequent operation and maintenance. This begins with selecting tenants 

to occupy the units and then includes collecting and accounting for their monthly rent payments. 

Some IHAs arrange for utility services themselves (water and electricity), but in many cases 

tenants pay their own utility bills individually (being reimbursed for the subsidized portion by the 

IHA). IHA staff usually handles routine maintenance and minor repairs directly and/or contracts 

out such services to local individuals and firms. The IHA is also responsible for conducting 

53As noted earlier, HUD standards have since been eliminated, and replaced with the requirement of adherence to 

local codes. 
Assessment of American Indian Housing Needs and Programs: Final Report 154 

assessments of needs for modernization of their older structures, and for planning, securing HUD 

funding for, and implementing modernization programs.54 

In the Mutual Help program, IHA functions are less extensive. IHAs are required to select 

households to occupy the new units and to set up and maintain financial accounts related to their 

payment obligations. They are not expectedJo be involved in the ongoing provision of utilities 

and maintenance services--those functions are solely the responsibility of the home purchaser. 

IHAs do provide counseling programs to help the new purchasers better fulfill the obligations of 

homeownership and, since the move in the 1980s authorizing the use of HUD modernization 

funding for Mutual Help, IHAs plan and implement modernization programs for Mutual Help units. 

Operating Costs 

Data on operating costs in both programs, as of 1993, are summarized in Table 5.8 and 

shown in more detail in Table 5.9. As would be expected, given the functions involved, there are 

substantial differences between the programs. 

Operating costs in the Rental program are much higher. Also, these costs are carefully 

controlled by HUD through its Performance Funding System (PFS). This system was created in 

the mid-1970s to provide constraints and guidelines on expenditures in Public Housing as well 

as Indian Housing. Baseline "Allowable Expense Levels (AELs) were established on the basis 

of studies examining the level of costs that should be expected in a "well-managed Public 

Housing Authority" and they have been revised regularly since then to reflect inflation. 

The IHAs' 1993 Rental program costs averaged $217 per unit in management per month 

(PUM). This cost is in the lower range of cost experience for the national public housing program 

where 1992 allowable expenses per unit-month ranged from around $140 for small housing 

authorities in the Midwest to $358 for large public housing programs in the Northeast (Abt 

Associates, Inc., 1994). 

The IHA Rental costs exhibit comparatively little variation by ACA rating, IHA size, or area 

income (Table 5.9). Looking at the results by region, the only notable outlier is the cost in Alaska, 

which is more than three times the average. It should be remembered that extremely high costs 

for Rental operations were expected in Alaska and this is the primary reason why that program 

is so small there--because of its small scale, this rate of expenditure does not have much effect 

on national outlays. Among the other regions, variation is much narrower--costs in Oklahoma and 

the South Central region are no more than 35 percent below the average, and those in Arizona54As with new construction, modernization implemented under alternative approaches, including force-account as 

well as the conventional method. 
Assessment of American Indian Housing Needs and Programs: Final Report 155 

TableS.8 

IHA OPERATING EXPENDITURES (Per Unit Month) 

Total Rental Owner 

IHA AVERAGE COST 131 217 91 

SmalilHAS «100 units) 

Large IHAs (>457 units) 

163 

99 

206 

221 

127 

62 

Highest Quartile ACA 

Lowest Quartile ACA 

122 

146 

201 

235 

85 

106 

Range Public Housing - 140-358 -

PERCENT COVERED 

BY HUD SUBSIDY 

IHAs 

Public Housing 

68% 

- 83% 

44% 

41% 

Source: MIRS System 

New Mexico, Califomia-Nevada, and the Pacific Northwest are less than 17 percent above the 

average. The lack of more extensive variations in these costs may well be explained in large part 

by the rules and limitations that exist under the PFS system. 

The operating cost experience for the Mutual Help program presents a quite different 

picture. The average ($91 per unit month in 1993) is less than half of that of the Rental program. 

These outlays, of course, are only supposed to cover basic record keeping and administration, 

counseling, insurance, and some utility allowances (not full project management and maintenance 

as is required of IHAs in the Rental program). 

Mutual Help costs are also much more variable across IHAs. For example, the average 

cost for smaller IHAs (less than 100 units in management) is $127, compared to only $62 for 

larger IHAs (457 units or more). The average for the lowest quartile according to ACA 

performance is 25 percent above the average for the highest quartile. By region, the lowest costs 

are again achieved in Oklahoma and the South Central regions ($58) and the highest, again by 

far, are in Alaska ($190). 

More research would be required to understand these Mutual Help variations fully. 

However, there does appear to be some relationship to scale. The correlation between Rental 
Assessment of American Indian Housing Needs and Programs: Final Report 156 

TableS.9 

IHA OPERATING EXPENDITURES 

Rental Un"s ($) MH and Other Units ($) 

No. Ave. Per Per Unit Ave. Per Per Unit 

IHAs Unit Month Unit Month 

ACA Pertonnance Rating 

Highest 25% 44 2,412 201 1,025 85 

2nd 25% 44 2,329 194 954 80 

3rd25% 44 2,884 240 1,154 96 

Lowest 25% 44 2,826 235 1,271 106 

AIlIHAs 176 2,598 217 1,087 91 

IHA Size (No. units) 

Highest 25% 45 2,653 221 744 62 

2nd 25% 43 2,792 233 1,107 92 

3rd25% 44 2,450 204 1,143 95 

Lowest 25% 44 2,473 206 1,520 127 

AIIIHAs 176 2,598 217 1,087 91 

Area Income 

Highest 25% 43 2,419 202 906 75 

2nd 25% 43 2,753 229 1,050 88 

3rd25% 43 2,486 207 1,109 92 

Lowest 25% 43 2,777 231 1,159 97 

Unknown 4 1,341 112 2,120 177 

AIiIHAs 176 2,598 217 1,087 91 

Region 

1. No. Central 26 2,179 182 1,188 99 

2. Eastem 12 2,420 202 1,269 106 

3. Oklahoma 20 1,457 121 701 58 

4. So. Central 6 1,534 128 699 58 

5. Plains 28 2,089 174 950 79 

6. AriZ.-N.Mex. 22 2,446 204 935 78 

7. Caln.-Nev. 25 2,577 215 1,060 88 

8. Pac.No.West 23 2,388 199 1,198 100 

9. Alaska 14 9,383 782 2,277 190 

AlllHAs 176 2,598 217 1,087 91 

IHA and Market Type 

Umbrella - Alaska 13 9,383 782 2,005 167 

Umbrella - Other 11 2,208 184 1,077 90 

Near Urban - Lg/OplHl 6 1,960 163 547 46 

Near Urban - Lg/CIIHI 1 2,431 203 

Near Urban - Lg/OplLl 22 2,019 168 847 71 

Near Urban - Lg/CIILI 29 2,468 206 917 76 

Near.Urban - Small 17 2,357 196 1,216 101 

Remote - Closed 1 2,110 176 755 63 

Other - Navajo 1 3,103 259 780 65 

Other - Other 71 2,197 183 1,065 89 

Unknown 4 1,341 112 2,120 177 

AlllHAs 176 2,598 217 1,087 91 

Source: MIRS. 
Assessment of American Indian Housing Needs and Programs: Final Report 157 

program costs PUM (where there is less variation) and IHA size (measured by the number of 

units in management) is negligible (+0.016) and not significant. But the correlation coefficient 

between Mutual Help operating costs PUM and IHA size is higher, negative, and significant, 

although not terribly strong (-0.28): Le., other factors being equal, the smaller the IHA the larger 

the Mut1,Jal Help operating cost. 

Some IHA directors claim that the AELs for their Rental programs under the PFS are 

inadequate to operate the program proper1y; 74 percent of those who responded to the question 

on this topic in the on-site interviews said that the AEL established for their IHA was "not 

appropriate." 

In overall IHA programs, however (considering Rental and Mutual Help together), scale 

effects were not very pronounced. For example, the number of full-time IHA employees per 100 

units did not vary much by IHA size. The median in 1993 was 3.85 employees (the middle half 

fell in the range from 2.74 to 5.02).55 

Receipts 

Total Rental program receipts in 1993 averaged $254 per unit-month, $180 of which (71 

percent) was the HUD subsidy payment. Most of the remaining receipts were net payments from 

tenants. 

Total Mutual Help program receipts averaged $94 per unit-month in 1993, only $37 of 

which (39 percent) was accounted for by the HUD subsidy. This subsidy, then, is well below 

(only 20 percent of) that in the Rental program, but it must be kept in mind that the incomes of 

Mutual Help occupants are much higher. The monthly payment for Mutual Help purchasers is 

set between 15 percent and 30 percent of income. IHA's can grant utility allowances to these 

households and, there is little evidence of IHA efforts to increase payments much beyond the 

minimum (Le., it seems likely that household payments on average come much closer to the 15 

percent than the 30).56 

551n a regression model relating the number of employees to IHA size (number of units in management), the 

coefficient was negative and significant, but the value of the coefficient was very small and the R-square was only 

0.023; Le., not much of the variation is explained by IHA size. 

561t also appears that the $1,500-in-value up front contribution required for Mutual Help occupancy is only 

infrequently made out of the family's personal funds. In on-site interviews, 76 percent of IHA directors said this 

contribution is usually donated by the tribe. When asked what form the contribution took in their areas: 91 said land, 

30 percent said family labor, 20 percent said money, and only 3 percent said materials. There are regional and local 

variations in this pattern, however. For example, in Oklahoma, where there is a substantial amount of "individual trust 

land," more families make the contribution out of personal income. 
Assessment of American Indian Housing Needs and Programs: Final Report 158 

In both programs, the HUD subsidy PUM was fairly strongly correlated with total operating 

costs PUM (correlation coefficients of 0.59 in the Rental program and 0.73 in Mutual Help). 

Tenants Accounts Receivable (TARS) 

A major problem in both programs ha~ been in enforcing the obligations of beneficiaries 

to keep up with their rent and homeowner payments. 

In the Rental program, delinquencies were substantial. At the end of 1993, 36 percent of 

all program tenants were delinquent in their rent payments and cumulative Tenant Accounts 

Receivable (TARS) at the end of the year averaged $208 per unit in management. TARS are 

also serious in Mutual Help: 36 percent of new Mutual Help occupants, and 56 percent of old 

Mutual Help occupants are delinquent, cumulative TARS per unit in management are even higher 

than in the Rental program ($294 in new Mutual Help units, and $628 in old Mutual Help units). 

This record is considerably below that achieved in the national public housing program. 

In contrast to the 36 percent delinquency rate in the Indian Rental program and most of Mutual 

Help, the average rent delinquency rate in public housing is only 12 percent. And serious rent 

delinquencies in public housing tend to be concentrated in a limited number of housing 

authorities. In authorities accounting for two thirds of the public housing stock, the delinquency 

rate is 5 percent or less. 

In Indian housing too, however, the averages are misleading because they mask wide 

differences. Some IHAs have an excellent record with respect to TARS while, for others, the 

problem is severe. For the ten percent of all IHAs with the best record in this regard, for 

example, Rental program TARS averaged only $5 per unit in management; for the ten percent 

with the worst record, the average was $1,256. Regression analysis was employed to gain a 

better understanding of the variation. The R-square was 0.47--see Annex 5C. Many of the 

variables we have discussed in this chapter were not significant: i.e., variations in TARS does not 

seem to be influenced by IHA size, the number of IHA staff per 100 units, area income, or 

distance from a large urban area. The two variables that were significant and had a large positive 

impact were: the ACA performance rating, and the rate of turnover in IHA directors (number of 

executive directors the IHA has had in the past 10 years). The close relationship between these 

variables will be discussed more later in this chapter. 

HUD gave emphasis to stabilizing TARS in the late 1980s, and this appeared to be 

working for a time, but cumulative TARs has been growing again in the past few years (ONAP, 

1994). Why some IHAs have such a problem with TARS is not fully understood, but there are 

some persuasive hypotheses. On-site interviews suggest that while some tribes enforce strong 

eviction policies (and therefore avoid large TARS), others either are unwilling or unable to do so. 
Assessment of American Indian Housing Needs and Programs: Final Report 759 

Percent 

0 10 20 30 40 50 60 70 

DELINQUENT UNITS AS 

PERCENTAGE OF TOTAl. 1993 

Rental 36 

New Mutual Help 36 

Old Mutual Help 56 . 

Total Program 38 

TARS AS PERCENT OF 

TENANT PAYMENTS. 1993 

Rental 53 

Mutual Help 62 

Total Program 56 , 

FIGURE 5.4 Tenant Accounts Receivable 

Explanatory factors include the existence of weak tribal court systems and the conflict of such 

policies with tribal culture, as well as the lack of forceful management. 

Tenant Selection 

AlllHAs maintain waiting lists of households in their tribal areas who have applied for new 

units in both programs. Means tests to assure income-eligibility are supposed to be applied 

before households are placed on the lists. IHAs use these lists almost solely as the basis for 

selecting program beneficiaries. Most often selections are made on a first-come-first-served 

basis; i.e., the household that has been on the waiting list longest gets the next unit that becomes 

available. 

As a very rough indicator of need, the 171 I HAs who responded with waiting list estimates 

for their community in the telephone survey indicated that the total number of households on their 

waiting lists equalled about half (49 percent) of the total number of existing units in management. 

The waiting lists for smaller IHAs were proportionally much longer. Figures from the smallest 

quartile of IHAs indicate that the number of households on their waiting lists averaged 97 percent 

of the total number of units currently in management. 
Assessment of American Indian Housing Needs and Programs: Final Report 160 

Maintenance Policies and Problems 

Maintenance, and most particularly preventive maintenance, is an essential function of 

managing any housing program. If units are not well-maintained, major expenditures can be 

expected later as units are allowed to deteriorate. Maintenance and repair activity is an 

increasing challenge in both IHA programs with the aging of a large share of the assisted housing 

stock in Tribal Areas. The nature and cause of the problems in the two programs differ, however. 

As explained earlier, IHAs have direct responsibility for the maintenance of their Rental 

units and, as data from the household surveys indicate, Rental units are, on average, in better 

condition than those in the Mutual Help program. IHAs typically make routine visual inspections 

of their rental units and some have systematic preventative maintenance programs. For most, 

however, tenant complaints are most often the events that trigger maintenance and repair actions 

by IHA staff. 

Data from the MIRS system show IHAs spend, on average, 38 percent of their Rental 

program operating budgets for ordinary maintenance, a figure that exhibits little variation by ACA 

performance, IHA size, or area income. There are some regional variations. Alaska spends the 

least (25 percent) and the South Central region, the most (49 percent). 

When asked what contributes most to maintenance costs for Rental units, 65 percent of 

IHAs in the telephone survey identified tenant abuse and vandalism. Less than 10 percent 

identified any of the other options given (poor materials, poor construction, or lack of preventive 

maintenance) . 

There is wide agreement among IHAs that the physical problems of Mutual Help are more 

serious than those in the Rental program, and this was corroborated by sample survey results 

noted earlier. IHAs are not directly responsible for maintaining these units (only an average of 

4 percent of Mutual Help operating budgets go for maintenance), but they have obvious concerns 

for their physical condition. 

IHAs, asked about the leading causes of Mutual Help physical deficiencies in the 

telephone survey, cited the simple failure of residents to make needed repairs (30 percent of the 

national total), poor original construction (22 percent), inadequate resident income to cover 

maintenance (20 percent), and age of the unit (10 percent). There were some important 

differences of opinion on this issue in different regions, however. For example, bad construction 

was identified as most important in the Eastern (67 percent), Alaska (45 percent), and North 

Central (38 percent) regions. Resident failure to maintain stood out most strongly in the Plains 

(45 percent) and Oklahoma (44 percent) regions. 
Assessment of American Indian Housing Needs and Programs: Final Report 161 

A clear majority of IHA directors (80 percent in on-site interviews) felt that Mutual Help 

residents clearly understood that it was their responsibility to maintain their homes.57 Still, 63 

percent of them answered yes to the question, "Has getting homebuyers to take responsibility for 

maintenance been a problem?" Again, the enticement of the low (near 15 percent) payment 

requirement, and inadequate counseling on maintenance obligations, is a factor here. Many 

Mutual Help Occupants simply do not have sufficient income to maintain their units properly. 

Modernization 

Chapter 4 explained that, substantial additional funding has been provided for 

modernization of Rental and Mutual Help housing in recent years (modemization accounted for 

only 6 percent of capital expenditure funds authorized over 1980-84, but 28 percent over 1990­

93). It also explained differences between the two main programs by which these funds are 

delivered: ClAP (the Comprehensive Improvement Assistance Program) and CGP (the 

Comprehensive Grant Program--which offers a more flexible approach and substantially more 

funding, but only to IHAs with 250 units or more in management). The telephone survey indicates 

that 86 percent of all IHAs have taken advantage of one or both of these approaches in the 

Rental program and 75 have done so in Mutual Help (which was first authorized for such funding 

much more recently). 

The scope of work for this study did not call for a full assessment of ClAP and CGP, but 

some findings are of interest. One (from on-site surveys) is that, unlike the experience in new 

development, 80 percent of IHAs responding use the force account method for modemization. 

It appears to be the dominant mode in all regions. Force account offers obvious benefits in 

providing jobs to tribal members. It is used more frequently for modernization because the jobs 

are smaller, may require less skill, are more easily managed by IHAs of all sizes. 

Other findings come from more detailed interviews about CGP conducted with three of the 

IHAs where on-site surveys were conducted. Generally, all three agreed that CGP is more 

reliable and predictable in terms of funding, and this helped them keep their promises as to when 

work would be completed. They were particularly complementary about the requisition system. 

One commented that with CGP's longer term funding commitment they were able to modemize 

more efficiently; i.e., do all that needed to be in one house at one time (their experience under 

ClAP was that they often did a series of quick-fixes in a house that might not have been needed 

if they could have settled underlying defects all at once). One commented that the 7 percent 

allowable administrative fee was fine for larger agencies, but too small for smaller IHAs.58 

57Although when tribal staff were asked the same question they were divided on the issue (almost exactly half and 

half). 

58This limit has since been changed to 10 percent unless a higher amount is approved by HUD. 
Assessment of American Indian Housing Needs and Programs: Final Report 162 

The required resident participation in CGP planning also varied, with some areas more 

organized than others. Mutual Help residents generally participated more than tenants in Rental 

units. It appears that this participation did have an influence as priorities were changed based 

on resident requests (in one case giving greater attention to project security than the IHA had 

originally planned). 

All of these IHAs were very supportive of the fact that CGP puts the burden on them 

directly and there is no week-to-week involvement and oversight from HUD. One said that this 

has made their relationship with HUD "less confrontational and more cooperative." Another said, 

"CGP is the pre-cursor to how HUD is moving toward flexibility ... although some HUD staff are 

still stuck in the old mentality." 

Suggestions for improving CGP include: (1) permitting a range of administrative fees to 

allow for differences in IHA size, age of housing, severe weather conditions and distances that 

affect administrative costs; (2) cutting back the requirements for documentation in the CGP plan 

(still too cumbersome and costly, particularly for smaIiIHAs). One other issue was raised by one 

member of our Advisory Panel; i.e., that, "given the limitation of CGP participation to IHAs with 

250 or more units, and the funneling of such a large share of the funds through CGP, many of 

the smaller IHAs are now strapped for modernization money whereas the larger IHAs are flusher 

than they have ever been." 

Turnkey Conversion 

The Tumkey III Homeownership Opportunities Program was a lease-purchase program 

authorized by administrative action in the 1970s. It was based on a cooperative form of home 

ownership in which all participating families paid, at minimum, operating expenses, debt service, 

and routine maintenance. As noted earlier, this program accounted for a little over 2,300 units 

during its development period. 

One of the research questions for this study related to whether any special actions were 

needed to expedite the phasing out of the units originally funded under this program. Over half 

of the units have already been sold or converted to Rental or Mutual Help units. In our on-site 

interviews, 21 percent of the IHAs said they still had Turnkey III units to convert. Subsequent 

HUD data show a much lower percentage--12 percent. No surveyed IHA volunteered that they 

saw any problems with completing their remaining conversions. One noted that "The process just 

takes time, given the legal actions required and the willingness of the residents to do what they 

have to do." There were no indications that this conversion warranted a higher priority than HUD 

has been giving it. 
Assessment of American Indian Housing Needs and Programs: Final Report 163 

INSTITUTIONAL PERFORMANCE 

National Administration and Oversight 

Assessing the character of HUD's administration of the Rental and Mutual Help program 

is difficult, because few relevant quantitative measures are available and HUD's administrative 

approach has been undergoing substantial change, particularly over the past several years. 

However, interviews with current HUD officials (at both the central and field office levels) and with 

IHA directors yield virtually unanimous conclusions about two main points. 

First, through most of their history, born out of their heritage in Public Housing, HUD's 

Indian housing programs suffered through overly detailed and complicated regulations. These 

created an onerous operating environment where HUD officials reviewed in depth, and required 

approval of, almost alllHA plans and activities before they could be implemented. The process 

often yielded substantial procedural delays and, no doubt, stifled IHA initiative. To complicate 

matters, regulations pertaining to Indian housing were scattered throughout HUD's massive 

regulations for Public Housing. HUD field staff responsible for Indian programs reported to 

Regional Administrators rather than a central Indian program office. This permitted considerable 

inconsistency in administrative approaches and styles in different regions, which added to the 

frustration of IHAs and tribes. Several interviewees used the phrase, "an atmosphere of 

confrontation" between HUD and the IHAs. 

Second, there is consensus that the changes made since the mid-1980s have been 

substantial, and generally in the right direction (while there were differing opinions about some 

details, no one we interviewed opposed the main themes). 

These changes have concentrated on separation from Public Housing, consolidation, 

management improvements, and deregulation. The Indian Housing Act of 1988 provided the 

impetus to complete the consolidation of separate Indian housing regulations and handbooks. 

The 1990 Interim Consolidated Indian Housing Regulation represented the first major change in 

the Indian housing program rules in 13 years. In 1986, HUD implemented the Administrative 

Capability Assessment (ACA) for the first time establishing a systematic approach for evaluating 

IHA performance. In the past four years, extensive consultation with tribes and tribal 

organizations has resulted in revised regulations, the latest (April 1995) purported to reduce 

Indian housing rules by 45 percent. Reorganization of the Office of Indian Programs (OIP) into 

the Office of Native American Programs (ONAP), with Field Offices (FONAPs) reporting directly 

to the Director of ONAP, substantially enhanced its ability to coordinate HUD initiatives in Tribal 

Areas and respond to the Native American community. 
Assessment of American Indian Housing Needs and Programs: Final Report 164 

In addition to the development of the ACA, HUD made several other efforts to improve 

management in key problem areas. Results include the 27 percent reduction in processing times 

from 1985 to 1993 (the period from program reservation to start of construction being reduced 

from 38.7 months to 28.4 months) and the consistent decline in per square foot development 

costs reported earlier in this chapter. These initiatives also included the effort to stabilize TARS 

which, again as noted earlier, has not proven as successful. 

How have the IHAs reacted to these changes? In our telephone survey (mid-1994), 79 

percent of ail IHAs reported that their relationship with their HUD field office was "good or 

excellent"--only 3 percent said the relationship was "poor or very poor"; 59 percent said that HUD 

had been "very helpful" in improving IHA program performance over the past two years; 69 

percent said changes in HUD regulations over the past few years have improved the delivery of 

service; and 64 percent said HUD has been more responsive to IHA concerns about program 

structure and funding during the last few years than it was previously. There was little variation 

in these responses based on differences in ACA performance ratings, IHA size, or area income. 

There were some variations in regional averages, but no consistent patterns: i.e., no single region 

or group of regions was conSistently more positive or negative on these indicators than the others. 

Difficulties in the transition were noted in interviews with HUD field offices. One mentioned 

that while ONAP has instructed the FONAPs to provide more assistance to IHAs and improve 

communication, funds have been cut back, especially travel funding, so they are frustrated in their 

ability to implement changes. Field offices vary in their reported desire to grant autonomy to IHAs 

and expand the IHA role beyond its current role of just providing HUD-financed housing. Some 

regions and IHAs appear to be more progressive in this area than others. 

Generally, it would appear that ONAP initiatives to improve the performance of Indian 

housing programs over the past decade are moving in a positive direction. However, given the 

newness and complexity of the reforms underway, it is not possible to predict their effects with 

certainty. 

Local Implementation-IHAs and Tribes 

Indian Housing Authorities (IHAs) are corporate, public bodies established by tribal 

ordinance or under state law. They are responsible for the planning, construction, purchasing or 

leasing, and managing of housing units funded by HUD. They are governed by a Board of 

Commissioners appOinted or elected by the tribe, in accordance with tribal ordinance or state law. 

An Indian housing program has four key players: the tribal government, Board of Commissioners, 

IHA staff, and program participants. All have a critical role in making the program succeed and 

must work cooperatively together. 
Assessment of American Indian Housing Needs and Programs: Final Report 165 

As we have seen in earlier sections of this chapter, IHAs differ from each other in many 

ways. Differences in size, for example, are important managerially (the top quarter ranked by size 

manage an average of 1 ,155 housing units whereas the bottom quarter manage on average only 

59). Of the 187 total, 6 have only recently been founded and have not yet completed any units. 

Of the remainder, 24 are "umbrella IHAs" that provide services to two or more Tribal Areas and 

157 serve only one tribe. 

IHAs can well be thought of as small business operations. They have an average of 15 

full-time employees. IHAs in the smallest quartile by number of units in management have only 

three full-time employees on average, while those the largest have 35. As noted earlier, this 

median number of employees per 100 units in 1993 was 3.85 (the middle half of alilHAs fell in 

the range from 2.74 to 5.02), and this ratio does not change much with IHA size. IHAs also differ 

by age, and this can also influence the character of their management. In 1993, the median IHA 

age was 24 years (the middle half fell in the range from 17.5 to 28.0 years). 

The terms of IHA Board members range from two to five years. According to the 

telephone survey, over half of the IHAs said that their board members served for four year terms. 

For the majority (54 percent), Board members are appointed by the tribal government, rather than 

being elected. The appointment approach was used least in Oklahoma and Alaska (15 percent), 

but was dominant in the North Central, Plains, and Arizona-New Mexico regions (all over 70 

percent). Some Board chairs have served for long periods but, generally, turnover is high--on 

average, IHAs reported that they have had four different chairs in the past 10 years. 

Generally, the Boards seem to be active in IHA policy formulation and management, but 

the pattern is clearly uneven. In on-site interviews, 83 percent of IHA directors said their Boards 

were "somewhat or very involved" in overall planning decisions, project design, and monitoring 

and overall quality control; 86 percent said the same regarding selection of architects and 

contractors; 81 percent for tenant selection and assignment; and 72 percent for project site 

selection. 

Direct involvement by the tribal govemment is also mixed. One director we interviewed 

said, "they are always looking over my shoulder at every step" while for several others, it appears 

the tribe gives the IHA considerable latitude in regular operations. The shares of IHA directors 

who said their tribal councils were "somewhat or very involved" varied considerably depending 

on the topic: 58 percent for site selection; 47 percent for lease enforcement, collections, and 

evictions; 44 percent for overall planning decisions; 33 percent for project design; 31 percent for 

monitoring and overall quality control; and 25 percent for selection of architects and contractors 

and tenant selection. 
Assessment of American Indian Housing Needs and Programs: Final Report 166 

IHA directors also have a very high rate of turnover, with over half having held their 

positions for two years or less; half of the IHAs reported in the telephone survey having had four 

or more directors in the past ten years. This means that many IHAs are experiencing frequent 

changes in leadership and direction. 

The IHAs have an active national network. Most directors and many board members 

attend the annual conferences and other activities of the National American Indian Housing 

Council (NAI HC) which also serves as a clearing house for information, provides technical 

assistance, generally works to improve professional practice in IHA management, and promotes 

support for housing assistance in Indian country. Many experienced IHA directors in this network 

have been employed by different tribes at different times. 

An issue of great concern for management--but one that is not easy to quantify--is the 

character of the relationship between the tribes and the IHAs. Members of our site survey team 

reported quite different experiences in this regard. In most cases, they felt that good working 

relationships had been established, but in some, they felt relationships had become divisive. 

The latter may seem surprising in that the tribes ultimately have control (they select the 

IHA boards which, in turn, can hire and fire the directors). However, IHA-HUD relationships 

(including special rules to promote fiscal and procedural integrity) insulate IHAs from their tribes 

to some extent. In some cases, resentment has built up as the IHAs are seen as "well-funded 

agencies paying high salaries, while the tribal staffs themselves operate on a shoestring." 

Conflicts can easily arise (e.g., where HUD rules press for evictions of tribal members who fail 

to keep up with rent payments and tribal culture resists). 

Also, other research has shown that their is considerable variation in the strength and 

capacity of tribal governments around the country. The work by Cornell and Kalt, cited in Chapter 

2, indicates there are major differences in performance depending on the structure of governance 

in the tribe and how well that structure meshes with tribal culture. It seems likely that IHAs would 

generally find it more difficult to conduct their business in areas where tribal government is weak 

and that, in itself, could lead to divisiveness even when the IHA was performing effectively. It 

also seems most likely that these issues playa role in the high rate of turnover of IHA directors. 

IHA Performance--ACA Ratings 

As noted at the start of this chapter, HUD implemented the Administrative Capability 

Assessment (ACA) as a systematic approach to rating IHA performance in the mid-1980s. HUD 

regional staff conduct the assessments, using lists of specific questions that generally require 

objective and verifiable responses. Separate rating lists are prepared for several separate topics: 

development, modernization, administration, financial management, occupancy and maintenance. 
Assessment of American Indian Housing Needs and Programs: Final Report 167 

Scores are tabulated to create independent ratings for each topic on a scale of 1 to 100. These 

are averaged to create the overall composite ACA rating, also on a scale of 1 to 100. As noted, 

our review of this system suggests that it is well specified and employs reasonable quality control 

procedures to promote reliability. 

HUO has carried out an ACA assessment of each IHA annually, along with recurrent 

audits. Applicable statutes, HUO regulations, contracts, HUO handbooks and other program 

requirements must be adhered to with no serious deficiencies. If an I HA has serious deficiencies, 

HUO issues a: notice of deficiency; a corrective action order; or classifies the IHA as a "high risk" 

authority (which may affect its funding allocation); or any combination of the above. 

The overall ACA ratings exhibit considerable variation. In 1993, the median score was 67; 

the middle half of the distribution had scores ranging from 53 to 81. We found that ACA scores 

for the independent topics seemed generally to be well correlated with each other (e.g., IHAs that 

did poorly in administration also tended to have low scores for development and financial 

management), and therefore with the composite score. The measurements include a number of 

"yes or no" questions (e.g., regarding compliance with procedures), but also include some 

statistical measures (for example, TARS, which as noted earlier also vary substantially--median 

of $125 per unit in management, with the middle half falling in the range from $44 to $381). 

The system might have seemed suspect if scores remained the same over time (Le., the 

same IHAs were always rated high or low), but this is not the case with the ACA. We divided the 

IHAs into decites according to their overall ACA ratings in two periods: 1986-89 and 1990-93. A 

major change was defined as occurring when an individuallHA moved up or down by two or more 

decites between these periods. The composite ratings for 52 percent of the IHAs--high or low--did 

not change much between these two periods, but 23 percent accomplished a major increase in 

performance, while 25 percent experienced major declines. 

Average characteristics of the IHAs in each 1990-93 decile grouping are shown in Table 

5.10. Few clear patterns are evident. The only two characteristics that show sizeable and 

consistent variation with ACA scores are TARS and the rate of turnover of IHA directors: for both, 

the these indicators increase as ACA scores get worse (ACA decile numbers get higher). 

Regression analysis confirms the importance of the second of these variables (we already 

know the first is correlated with ACA scores). The ACA score was established as the dependent 

variable, with independent variables including: IHA size, IHA age, the percent of low income 

households in the service area, executive director turnover, dummy variables for the regions, and 

three variables borrowed from the analysis in Chapter 2: distance to a large urban area, the ratio 

of total service area population to AlAN population, and the number of AlAN for-profit and self 

employed workers per 1,000 population (Annex 50). 
Assessment of American Indian Housing Needs and Programs: Final Report 168 

Table 5.10 
 

CHARACTERISTICS OF IHAs BY ACA RANKINGS 
 

Decile Ranklnfl! b:l Avg. ACA Score, 1990-93 

AlIIHAs 2 3 4 5 6 7 8 9 10 

BASIC IHA CHA~CTERISTICS 

No.oflHAs 176 17 18 17 18 18 17 18 17 18 18 

Total Units in Mgt. 74,072 13,561 5,181 5,959 5,745 5,823 11,099 10,280 6,940 7,655 1,829 

Avg. Units per IHA 421 798 288 351 319 324 653 571 408 425 102 

Percent Rental 35 26 28 45 30 30 39 29 58 37 49 

Age of IHA (yrs.) 21.9 17.5 19.9 18.1 24.5 23.8 22.7 22.7 25.5 24.1 20.0 

Avg. Employeesl100 Units 4.3 4.6 2.7 4.6 4.0 4.2 3.8 3.8 4.9 3.7 7.3 

Directors Past 10 Years 4.0 3.1 3.3 3.4 3.3 4.4 3.4 2.9 4.1 6.9 5.2 

RENTAL PROGRAM FINANCIAL 

Avg. Expenses per Unlt·Mo. 217 203 179 193 221 194 187 345 183 279 211 

Pet. Tenant Contrlb. 27 28 28 23 25 25 29 35 26 22 24 

Avg.TARSJUnit 208 18 63 82 119 113 172 270 382 468 369 

MUTUAl. HELP PROGRAM FINANCIAL 

Avg. Expenses per Unlt·Mo., Mutual Help 91 85 81 95 81 72 112 95 90 109 100 

Avg. Pet. Tenant Contrll., Mutual Help 59 66 54 74 58 68 23 67 59 55 52 

Avg. TARSJUnlt, Mutual Help 366 45 145 161 225 165 302 502 741 824 572 

AREA CHARACTERISTICS 

Avg. Dist. to 50K Place 103 91 92 90 113 75 73 169 87 167 68 

Pet. HHs below 80% Median Inc. 67 54 63 70 65 66 68 65 70 68 77 

This regression explained 26 percent of the variation in the dependent variable. The only 

independent variable that made a difference and was significant was executive director tumover: 

the larger the number of executive directors an IHA had over the past decade, the lower its ACA 

rating. 

As we interpret it, this means that IHA performance is mostly driven by institutional and 

personal factors. Interviews with HUD personnel confirmed that the system has had a number 

of professional executive directors that exhibit strong managerial and leadership skills, that have 

performed well in different tribal environments. The strength of the individual may well be the 

most important factor. 

However, it seems likely that the tribal environment also makes a difference (one 

hypothesis is that the good managers avoid tribal environments they think are likely to be 
Assessment of American Indian Housing Needs and Programs: Final Report 169 

problematic}. We refer again to the findings of Cornell and Kalt (1990) to the effect that American 

Indian tribes vary substantially in their stability and evidenced capacity to pursue economic 

development, and this variation is influenced, among other things, by the conSistency between 

govemance structure and traditional ways and values. Factors in the institutional setting (such 

as the effectiveness of decision making in the tribal council, the presence or lack of a fair judicial 

system, the method of appointing or electing IHA boards, and the tribal election process) may well 

have an important impact on the ability of IHAs to operate successfully. 

Thus it is probably not IHA director turnover itself that is the primary determinant of program 

managerial performance but, rather, the character of tribal governance that lies behind it--a mix of 

factors that are not yet well understood. It would seem that this issue should be given high priority 

for further research as HUD continues to move to decentralize program administration. 

REFERENCES 

Abt Associates, Inc. 1994. Revised Methods of Providing Federal Funds for Public Housing 

Agencies: Final Report. Cambridge, MA: Abt Associates, Inc. 

Comell, Stephen and Joseph P. Kalt. 1990. "Assessing the Causes and Consequences of 

Economic Development on American Indian Reservations: An Introduction to the Harvard 

Project on American Indian Development: Cambridge, MA: Harvard University. 

Housing Assistance Council. 1988. Indian Housing in the United States: A History. Washington, 

D. C.: Housing Assistance Council. 

______~ 1992. A Report on the Bureau of Indian Affairs' Consolidated Housing 

Inventory. Washington, D.C.: Housing Assistance Council. 

Kingsley, G. Thomas, Maris Mikelsons, and Car1a Herbig. 1995. Housing Problems and Needs 

ofAmerican Indians and Alaska Natives. Project Report prepared for the Office of Policy 

Development and Research, U.S. Department of Housing and Urban Development, No. 

6349A. Washington, D.C.: The Urban Institute. 

ONAP (Office of Native American Programs). 1994. Native American Programs Annual Report, 

1993. Washington, D.C.: U.S. Department of Housing and Urban Development. January. 
Assessment of American Indian Housing Needs and Programs: Final Report 170 

Annex SA 
 

Multiple Regression Analysis 
 

Dependent Variables: UNITSALL Total units in management 

Independent Variables: 

HHBLW80 HHs below 80% median income 
 

TOTAC93 Total ACA Rating, 1993 
 

AGEIHA Age of IHA (years) 
 

PCTLRUTS Pct. low-rent units 
 

REGION1 Region 1 dummy (= 1 if region is 1, 0 otherwise) 
 

REGION2 Region 2 dummy (= 1 if region is 2, 0 otherwise) 
 

REGION3 Region 3 dummy (= 1 if region is 3, 0 otherwise) 
 

REGION4 Region 4 dummy (= 1 if region is 4, 0 otherwise) 
 

REGION5 Region 5 dummy (= 1 if region is 5, 0 otherwise) 
 

REGION6 Region 6 dummy (= 1 if region is 6, 0 otherwise) 
 

REGION7 Region 7 dummy (= 1 if region is 7, 0 otherwise) 
 

REGION8 Region 8 dummy (= 1 if region is 8, 0 otherwise) 
 

Variation 

R-Square: 0.89 

Root Mean Square Error: 257.15 

Analysis of Variance 

Model Degrees of Freedom: 12 

Mean Dep. Variable: 450.59 

F Value: 88.384 

Probability> F: 0.0001 

Variable: Parameter Est.: Std. Error: T for Ho: Prob.> ITI: 

INTERCEPT -55.39 152.40 -0.36 0.7169 
 

HHBLW80 0.23 0.01 27.25 0.0001 
 

TOTAC93 0.80 1.17 0.68 0.4957 
 

AGEIHA 15.33 4.18 3.67 0.0004 
 

PCTLRUTS -1.06 1.09 -0.98 0.3303 
 

REGION1 -132.17 130.39 -1.01 0.3126 
 

REGION2 -134.59 123.56 -1.09 0.2781 
 

REGION3 180.41 124.57 1.45 0.1500 
 

REGION4 -146.76 161.32 -0.91 0.3646 
 

REGION5 97.84 123.21 0.79 0.4286 
 

REGION6 -3.89 119.76 -0.03 0.9741 
 

REGION7 -110.82 109.30 -1.01 0.3125 
 

REGION8 -136.42 119.45 -1.14 0.2555 
 
Assessment of American Indian Housing Needs and Programs: Final Report 171 

Annex 58 
 

Multiple Regression Analysis 
 

Dependent Variables: PCTLRUTS Pct. Low-Rent Units 

Independent Variables: 

UNITSALL Total Units in Mgt. 

TOTAC93 Total ACA Rating, 1993 

PCTLINC Pct. AlAN HH's below 80% median inc., 1990 

MDIS50 Distance. to 50K Place 

AGEIHA Age of IHA (years) 

REGION2 Region 2 dummy (= 1 if region is 2,0 otherwise) 

REGION3 Region 3 dummy (= 1 if region is 3,0 otherwise) 

REGION4 Region 4 dummy (= 1 if region is 4,0 otherwise) 

REGION5 Region 5 dummy (= 1 if region is 5, 0 otherwise) 

REGION6 Region 6 dummy (= 1 if region is 6, 0 otherwise) 

REGION7 Region 7 dummy (= 1 if region is 7,0 otherwise) 

REGION8 Region 8 dummy (= 1 if region is 8, 0 otherwise) 

REGION9 Region 9 dummy (= 1 if region is 9, 0 otherwise) 

Variation 

R-Square: 0.52 

Root Mean Square Error: 20.66 

Analysis of Variance 

Model Degrees of Freedom: 13 

Mean Dep. Variable: 48.99 

F Value: 10.989 

Probability> F: 0.0001 

Variable: Parameter Est.: Std. Error: T for Ho: Prob.> ITI: 

INTERCEPT 118.56 15.20 7.80 0.0001 

UNITSALL 0.00 0.00 0.23 0.8192 

TOTAC93 -0.07 0.10 -0.75 0.4537 

PCTLINC 0.08 0.14 0.59 0.5565 

MDIS50 -0.Q1 0.03 -0.56 0.5740 

AGEIHA -1.75 0.31 -5.71 0.0001 

REGION2 -36.10 7.68 -4.70 0.0001 

REGION3 -53.88 8.79 -6.13 0.0001 

REGION4 -42.44 11.39 -3.73 0.0003 

REGION5 -15.64 6.07 -2.58 0.0111 

REGION6 -31.38 6.66 -4.71 0.0001 

REGION7 -45.60 6.01 -7.59 0.0001 

REGION8 -31.98 6.79 -4.71 0.0001 

REGION9 -65.10 11.73 -5.55 0.0001 
Assessment of American Indian Housing Needs and Programs: Final Report 172 

Annex SC 
 

Multiple Regression Analysis 
 

Dependent Variables: TonRUN TARS/Unit ($) 

Independent Variables: 

UNITSALL Total Units in Mgt. 

LRUTSALL Low Rent Units in Mgt. 

FTEMP100 FT Emp/100 Units 

EXDIRS No. Ex. Dirs. Last 10 Years 

TOTAC93 Total ACA Ratin9, 1993 

ADMN ACA Administration Rating, 1993 

LRPCnC Pet. Tenant Contribution., Low Rent 

owpcnc Pet. Tenant Contribution., Mutual Help 

LRINC Avg. HH Income, Low Rent 

OWINC Avg. HH Income, Mutual Help 

HHLDS AlAN HH's, 1990 Census 

MDIS50 Distance. to 50K Place 

DEC89 ACA Decile, 1986-89 

DEC93 ACA Decile, 1990-93 

PCTAIAN Pet. AlAN HH's in assisted housing 

PCTLINC Pet. AlAN HH's below 80% median inc., 1990 

Variation 

R-Square: 0.47 

Root Mean Square Error: 321.15 

Analysis of Variance 

Model Degrees of Freedom: 16 

Mean Dep. Variable: 

F Value: 

267.54 

4.070 

Probability> F: 0.0001 

Variable: Parameter Est.: Std. Error: T for Ho: Prob.> ITI: 

INTERCEPT 46.55 440.66 0.11 0.9162 

UNITSALL 0.20 0.18 1.12 0.2657 

LRUTSALL 0.43 0.29 1.48 0.1438 

FTEMP100 0.56 22.07 0.03 0.9799 

EXDIRS 37.81 15.23 2.48 0.0154 

TOTAC93 -6.72 4.72 -1.42 0.1589 

ADMN 3.73 2.18 1.71 0.0910 

LRPCTTC -1.40 1.56 -0.90 0.3732 

owpcnc 

LRINC 

0.37 

0.01 

0.79 

0.02 

0.47 

0.37 

0.6413 

0.7124 

OWINC -0.02 0.01 -1.59 0.1167 

HHLDS -0.04 0.03 -1.61 0.1121 

MDIS50 0.66 0.38 1.73 0.0875 

DEC89 60.32 16.57 3.64 0.0005 

DEC93 6.52 24.86 0.26 0.7938 

PCTAIAN 0.16 0.74 0.21 0.8335 

PCTLINC -0.44 3.67 -0.12 0.9050 
Assessment of American Indian Housing Needs and Programs: Final Report 173 

Annex 50 
 

Multiple Regression Analysis 
 

Dependent Variables: TOTAC93 

Independent Variables: 

REGION1 

REGION2 

REGION3 

REGION4 

REGION5 

REGION6 

REGION7 

REGION8 

UNITSALL 

AGEIHA 

EXDIRS 

PCTLINC 

MDIS50 

PROF 

SHARE 

Variation 

R-Square: 0.26 

Root Mean Square Error: 17.62 

Analysis of Variance 

Model Degrees of Freedom: 15 

Mean Dep. Variable: 65.10 

F Value: 3.206 

Probability> F: 0.0002 

Variable: Parameter Est.: 

INTERCEPT 84.34 
 

REGION1 -13.06 
 

REGION2 -5.31 
 

REGION3 2.13 
 

REGION4 11.61 
 

REGION5 4.02 
 

REGION6 -4.75 
 

REGION7 -9.24 
 

REGION8 -12.79 
 

UNITSALL 0.00 
 

AGEIHA -0.36 
 

EXDIRS -2.53 
 

PCTLINC -146.15 
 

MDIS50 -0.02 
 

PROF 0.03 
 

SHARE 0.24 
 

Total ACA Rating, 1993 
 

Region 1 dummy (= 1 if region is 1, 0 otherwise) 
 

Region 2 dummy (= 1 if region is 2, 0 otherwise) 
 

Region 3 dummy (= 1 if region is 3, 0 otherwise) 
 

Region 4 dummy (= 1 if region is 4, 0 otherwise) 
 

Region 5 dummy (= 1 if region is 5, 0 otherwise) 
 

Region 6 dummy (= 1 if region is 6, 0 otherwise) 
 

Region 7 dummy (= 1 if region is 7, 0 otherwise) 
 

Region 8 dummy (= 1 if region is 8, 0 otherwise) 
 

Total units in management 
 

Age of IHA (years) 
 

No. Executive Directors in last 10 years 
 

Pct. AlAN HH's below 80"10 median inc., 1990 
 

Distance to nearest place of 50,000 population 
 

AlAN seH/profit employed per 1,000 pop., 1990 
 

Total population/AlAN population, 1990 
 

Std. Error: T for Ho: Prob.> ITI: 

10.99 7.67 0.0001 

8.86 -1.48 0.1426 

10.25 -0.52 0.6051 

10.73 0.20 0.8430 

13.00 0.89 0.3734 

8.58 0.47 0.6401 

9.56 -0.50 0.6199 

9.24 -1.00 0.3190 

9.50 -1.35 0.1804 

0.01 0.48 0.6344 

0.2V -1.34 0.1826 

0.59 -4.29 0.0001 

274.74 -0.53 0.5956 

0.02 -0.86 0.3929 

0.03 1.13 0.2598 

0.33 0.73 0.4668 
Chapter 6 

ALTERNATIVE APPROACHES AND 

SUMMARY ASSESSMENT 

While HUD's Rental and Mutual Help programs dominate the flow of housing assistance 

into Tribal Areas, several other programs (described in Chapter 4) offer alternative and 

complementary approaches, if at a smaller scale. The first section of this chapter examines the 

evidence we have been able to gather about the performance of these programs. 

The second section focuses on a new topic. In the course of the site-visits and through 

discussions with HUD officials and advisors, we heard about a number of innovative practices 

tribes had adopted to improve housing conditions in their areas. We review these to set the 

context of what may be possible in forming local housing strategies, outside of the context of 

traditional program definitions. 

Finally, the chapter weaves together findings from the program assessments as a whole 

to offer overall conclusions about Federal housing assistance now being provided to American 

Indians and Alaska Natives in Tribal Areas. 

ALTERNATIVE AND COMPLEMENTARY APPROACHES 

The Indian housing programs at HUD have remained primarily production programs, while 

HUD spending trends nationally have moved much faster in the direction of other approaches 

discussed in this chapter: tenant-based assistance, block-grants, and financing assistance. What 

role have these approaches played in Indian country to date? Before responding to that question, 

we examine the other pervasive production program operating in Tribal Areas: BIA's HIP program. 
Assessment of American Indian Housing Needs and Programs: Final Report 175 

Other Production Programs: The BIA's Housing Improvement Program 

As noted earlier Bureau of Indian Affairs Housing Improvement Program (HIP) serves only 

the very lowest income homeowners with grants, primarily for rehabilitation. Our telephone survey 

indicated that almost all tribes (77 percent) have used or are using HIP funds. In almost all 

cases, this program is administered locally by the tribal staff rather than the IHA. 

Traditionally, HIP had been regarded as attractive in Indian country because it provides 

a direct grant to a family with very few restrictions. As noted in Chapter 4, HIP funds are used 

primarily for rehabilitation, although down payment assistance and new construction are eligible 

activities. The family has great flexibility to determine location, the type of housing, and the work 

needed. Individual desires for housing design and style can easily be accommodated through 

the HIP program. The major benefit to the Indian family, however, is that its housing needs are 

served with a grant which does not need to be repaid (unless the home is sold). 

Although inquiries were made to the BIA, it was not possible to obtain information on 

production under this program over time. One of our advisors recalled hearing that as many as 

70,000 HIP grants had been made through the early 1990s, but this number is unconfirmed. 

Again, these grants cover small scale renovation and improvements for the most part. Even 

though the number of units affected may be sizeable, the total flow of resources has been only 

a small fraction of that provided by the HUD programs discussed in the last chapter. 

The program has had serious control problems. The BIA's Office of Inspector General 

(U.S. Department of the Interior, 1992) reported that in selected areas HIP had: (1) provided 

housing assistance to individuals who were ineligible for assistance and to applicants for whom 

eligibility had not been determined; (2) provided improvements that did not result in decent, safe, 

and sanitory housing or that were unnecessary or extravagant; and (3) inadequately controlled 

procurements, disbursements, and construction materials and supplies. Furthermore, in an earlier 

report, the General Accounting Office (1987) concluded that the BIA was not monitoring and 

enforcing the HIP model contract with tribes. More recently, an Indian task force has worked with 

the BIA to address these issues. 

While the HIP program was a sizeable contributor to Tribal Area housing improvements 

in earlier years, it current allocation of funds is so small (around $20 million per year) that it can 
 

. only be expected to playa minor role in relation to the need. In our on-site survey, tribal leaders 
 

were mixed as to their feelings about BIA HIP: Slightly more than a third (36 percent) felt the 
 

service they received was poor; about 28 percent thought it was good to excellent. 
Assessment of American Indian Housing Needs and Programs: Final Report 176 

Tenant-Based Assistance--Section 8 Certificates and Vouchers 

To date, the Section 8 Program has had only a marginal impact on the delivery of housing 

to Indians in Tribal Areas. In 1994, only about 3,500 certificates and vouchers were in use by 

IHAs. In our telephone survey, only 11 percent of alilHAs said they were presently using tenantbased assistance--82 percent they had never used it and had no plans to use it. The use of 

Section 8 to date appears to stem from FONAP efforts; 53 percent of the IHAs that are aware of 

the Section 8 program became so through their field office. 

When asked about obstacles to expanded use of Section 8 in the telephone interviews, 

74 percent of the responses related to the lack of private rental units in Tribal Areas (18 percent 

noted the lack of trained staff to administer the program). These patterns were generally 

corroborated in on-site interviews, which also endorsed the lack of available rental units as the 

primary barrier. Seven of these IHAs (19 percent) were actually administering tenant based 

assistance. Of these, 90 percent said that the administrative fee is not adequate, and half said 

the Section 8 Fair Market Rents (FMR) for their service areas were insufficient.59 

A HUD (1992) report on this topic, had drawn similar conclusions about perceived barriers 

to the use of Section 8 in Tribal Areas. However, it also noted that this form of assistance faced 

resistance because of the overwhelming preference for homeownership among tribal members, 

and the feeling on the part of some, that their acceptance of Section 8 assistance might somehow 

diminish their funding for construction programs, and that some AlAN households experience 

discrimination in their search for housing. 

Nonetheless, the central conclusion of the HUD study was "that while the limited 

availability of privately owned, affordable rental housing in many American Indian reservations will 

necessarily limit the use of vouchers, there are a number of IHAs which appear likely to be able 

to use vouchers effectively ... HUD Field Office staff estimate that up to 80 of the 183 IHAs 

could make some use of this form of rental assistance." 

In the analysis of conditions in Tribal Areas in Chapter 2, this study certainly corroborates 

that conclusion. We found 159 Tribal Areas that were within 50 miles of a large urban area, and 

another 24 that were more remote but "large and open" as we defined those terms. Together 

these contain 143,300 AlAN households, out of which 26,700 are low-income households whose 

only housing problem is affordability. 

59 "Fair Market Rents" are periodically estimated by HUD for small areas across the country to provide equitable 

standards related to changing market conditions in each area. There FMRs provide ceiling amounts in formula 

calculations to assure that HUD subsidies will not be excessive in relation to local market conditions. 
Assessment of American Indian Housing Needs and Programs: Final Report 177 

The HUD study stated, "It is clear ... that some IHAs have overcome the administrative 

and social-cultural obstacles to make use of Section 8 vouchers. It would be useful to promote 

awareness of these models ... in the process of providing education and outreach to IHAs." 

Block Grants--ICDBG and HOME 

The two block grant programs for housing are HUD's Indian CDBG and HOME programs, 

both of which have special set-asides for Indian areas. Both programs are made available only 

to Federally recognized (not state recognized) tribes. ICDBG was funded at $40 million last year, 

relatively small as a percentage of total Indian housing funding, but is heavily relied on due to its 

inherent flexibility. The HOME program is new (FY1991) and was funded for Indians at only 

$12.5 million in its first year. 

HOME. At the local level, HOME program activities have been administered directly by 

the tribal government, rather than the IHA. Interest in the program appears substantial in the 

Indian community due to the flexibility of uses of this program and to a major outreach effort by 

HUD, through training sessions and other efforts designed to increase awareness about it. Of 

all tribal staff responding to our on-site interview on this topic, 9 percent said they were already 

managing HOME activities, and another 41 percent said they plan to use HOME funds in the 

future. 

HUD (ONAP) awards the funding it has available to tribes on a competitive basis. Tribes 

respond to a NOFA (which lists specific criteria) and HUD ranks the application according to how 

well the tribe has prepared its plan to meet its needs. 

ONAP (1994) reports that 29 applications were received for the $15 million of FY1992 

funds available. Of the total amount, 62 percent will go for rehabilitation, 27 percent for new 

construction, 10 percent for acquiSition, and 1 percent for tenant-based assistance. The 

production money is expected to yield 191 new units and 260 rehabilitated units. 

The regulatory flexibility in this program has resulted in projected lower per unit costs than 

under the Rental and Mutual Help programs. As noted in Chapter 5, the budgeted per unit cost 

for new programs is $51,600, well below the average for the Rental and Mutual Help programs. 

However, most of the HOME construction has not been completed, so the proof is not in. 

Indian CDBG. ICDBG is currently a much larger source of funds for tribes than HOME, 

with 40 percent of IHAs reporting via the telephone survey that their tribes receive ICDBG funds. 

ICDBG usage changes over time. In the combined 1991-92 grant, housing accounted for only 

18 percent of spending while community facilities development comprised 70 percent of the 
Assessment of American Indian Housing Needs and Programs: Final Report 178 

spending. In 1993, a 40 percent share for housing was anticipated. A total of over 1,300 ICDBG 

projects in 32 states have been funded since 1980. 

ICDBG is also administered directly by the tribal government in almost all cases. All tribal 

staff we interviewed said that they were familiar with the Indian CDBG program. About half of 

those that responded said they coordinated their ICDBG activities with the IHA. Only four IHAs 

responded that they were subrecipients of ICDBG funds (one each in the Eastern, South Central, 

California-Nevada, and Pacific-Northwest regions). 

There are no doubt several reasons why tribes have not used IHAs more often to 

administer these grant funds, even though they generally have a sound administrative 

infrastructure in place for such activities. One is that, in the past, these block-grants were 

administered directly to tribes through HUD offices other than ONAP, so there was a completely 

different administrative structure that dealt only with tribes and no HUD institutional link was 

established to the IHAs. Another may be that since ICDBG plays an important role in providing 

employment in many tribal areas, the tribe may prefer to keep the administrative funds provided 

by the programs as well as the creation of jobs at the tribal level. 

If they could influence ICDBG funding, IHAs say they would use it to augment construction 

budget areas in which they now feel they are limited by HUD. Specifically, they would spend it 

on land acquisition and infrastructure. In California, ICDBG has been an important source of land 

acquisition funds for IHAs since most Rancherias have very little contiguous trust land. However, 

tribal priorities on how to spend the ICDBG money vary from year to year, limiting an IHA's ability 

to plan for the availability of ICDBG funds for housing-related functions. 

Financing Assistance: Sections 248 and 184 

The availability of private mortgage financing that most Americans take for granted has 

been largely withheld from Tribal Areas (mostly because lenders have perceived additional risks 

due to the inability to foreclose on trust land and other legal complexities). The FHA Section 248 

mortgage insurance program was established in 1987 in the hope of offsetting these risks, but 

the program has not been frequently used to date. Among IHA directors responding to the 

question on this program in the on-site interview, 78 percent they had never tried to take 

advantage of Section 248 assistance and had no plans to do so in the future. 

As noted in Chapter 4, a new loan guarantee program has been established (Section 184) 

to provide a complement to the Section 248 insurance approach, but it has only recently become 

operational and it is too early to judge its effects. At the time of our survey, just over 60 percent 

of the IHA directors said they were even aware of the new HUD Loan Guarantee Program, 

however, not one of the tribal staff interviewed was aware of it. 
Assessment of American Indian Housing Needs and Programs: Final Report 179 

There have been a number problems with the FHA 248 program. First, the program was 

not well marketed in the early years and many Indian communities have only recently became 

aware of it. Second, for a time, Ginnie Mae had refused to buy Section 248 loans (these 

problems have since been resolved). Finally, there are legal and cultural barriers between wouldbe lenders and the tribes. A method must be established, under Section 248, for disposition in 

case of a default, and this became a sticking pOint for many tribes who did not want HUD to have 

the right of first refusal on the unit in the event of default: i.e., the potential that the property 

could pass into the hands of a non-Native American. Also some tribes appear reluctant to 

establish clear eviction and/or foreclosure policies as is required under the program. 

Nonetheless, both the 248 and 184 programs have worked in specific instances and, in 1984, 

HUD embarked as a campaign to market them more effectively. 

The analysis in Part I of this report showed that there were many moderate and higher 

income AlAN renters living in Tribal Areas. A potential market for private mortgage lending, 

therefore, does exist. But it is clear that Federal policy has not yet been effective in eliminating 

the barriers that have prevented expanded private lending in the past. We see this as an 

important policy challenge for the future--it will be discussed in more depth in Chapter 9 of this 

report. 

Financing Assistance: Farmers Home Administration 

As discussed in Chapter 4, the Farmers Home Administration (FmHA)60 does offer loans 

to Indian families in Tribal Areas, but their records do not permit a separate tabulation of loans 

on this basis. We cannot, therefore, report reliably on the volume of FmHA activity that occurs 

in Indian country. However, all indications are that it is quite small. The overwhelming majority 

(80 percent) of IHAs reported that they had little or no understanding of FmHA programs. Over 

70 percent of IHAs reported that they had no contact with FmHA staff. Most efforts made by 

FmHA have been targeted to larger Tribal Areas. However, in accord with their intended target 

group of very low income rural reCipients, their contacts have also focused on areas with very low 

incomes. 

Tribal staff were somewhat familiar with FmHA programs. Half of them interviewed in onsite surveys claim to have been contacted recently by FmHA. Less than half of the tribal leaders 

asked about the FmHA programs, however, knew about them at all. 

While of negligible impact so far, there is the potential that FmHA impact in Indian country 

could expand. Section 709 of the 1990 National Affordable Housing Act (NAHA) added a new 

60 As noted in Chapter 4, the Farmers Home Administration has been renamed the Rural Housing and Community 

Development Service, but we will still refer to it as FmHA in this text. 
Assessment of American Indian Housing Needs and Programs: Final Report 180 

section intended to target more of FmHA's housing assistance funds to "underserved areas." The 

provision required FmHA to designate 100 counties having extremely high concentrations of 

poverty and substandard housing that have been underserved in the past for this purpose. A 

number of these incorporate Tribal Areas, and the Housing Assistance Council has mounted a 

program to try to make this provision work effectively in Indian country (see discussion later in 

this chapter). 

Other Programs 

Very little additional housing assistance exists in AlAN Tribal Areas. Almost 72 percent 

of IHAs reported that their tribes operated their own housing programs in addition to those of their 

IHAs. This is a positive sign in that it indicates a large number of tribes have had at least some 

exposure to the administration of housing assistance. However, almost all of the programs they 

administer are federally funded (e.g., HIP, ICDBG and HOME); only 12 percent of IHAs reported 

that tribes use any of their own funds for housing assistance. 

Only one third of the tribal staff interviewed had any familiarity with the housing programs 

of the Department of Veterans Affairs (VA); only 30 percent were aware of any state housing 

assistance that might be available to tribal members; only 19 percent had ever had discussions 

with private lenders about expanding mortgage lending in their areas. 

INNOVATIVE APPROACHES 

Using HOME and other funding mechanisms, some tribes are experimenting with new 

housing assistance approaches that would avoid some of the problems of the current categorical 

HUD programs. Activities range from an adaptation of the Mutual Help concept (providing a 

sliding scale for homeownership payments based on ability to pay with payments going into a 

revolving fund to assist more homebuyers) to a variety of alternatives for financing additional 

housing in Tribal Areas. At least three principles are being applied, all in a manner that would 

increase the number of families that can be assisted for any given amount of Federal funding 

provided: 

1. 	 Leverage -- instead of covering the full bill, HUD or other Federal subsidies could 

be used as a base, with additional funds attracted from other sources (including 

private loans and loans from state housing finance authorities as well as tribal 

funding and family down-payments); 
Assessment of American Indian Housing Needs and Programs: Final Report 181 

2. 	 Using lower cost building plans and techniques (including self-help and incremental 

approaches where subsidy funds can help build a modest "starter home" that 

families can improve and expand as their income increases); 

3. 	 Offering a variety of program formulas to more efficiently serve households with 

differing needs and incomes; for example, providing downpayment assistance only 

for those with incomes in the ranges just below the median, a continuum of 

homeownership options below that (households with incomes at the top end of this 

range would be required to pay a larger share of the costs than those at the lower 

end--shares paid by the family would change over time as their income changes), 

and more use of tenant-based assistance where a private rental housing stock is 

available. 

Even after the substantial deregulation that has occurred over the past few years, statutes 

defining HUD's Rental and Mutual Help programs still preclude using funds for creative leveraging 

schemes, help with downpayments, alternative assistance formulas, and tenant-based assistance. 

Continuing to push the bulk of Federal housing assistance funds through these two limited 

program options tends to dampen local incentives to search for a more effective range of 

alternatives. Some specific examples of program innovations are as follows: 

1. The Mississippi Choctaw Housing Authority, in conjunction with the tribe, this 

IHA produces houses in record time. It starts the surveys for land and archeological work as far 

in advance as possible. The tribe has a comprehensive land use plan and the IHA works with 

the tribe's real estate office which approves leases and preapproves sites. One 20 unit project 

took six months from reservation to completion of construction. Force account labor is used to 

build the homes. A housing authority can reduce costs for construction if it can plan in advance 

and have preapproved sites ready to go when funds become available. Mississippi Choctaw is 

a checkerboard reservation with a number of communities scattered several miles from each 

other. The length of construction time depends on the number of units being built and the 

distance between the project sites. For example, if a project is being constructed at a distance 

of 100 miles from the IHA office, the force account construction crew may need to spend several 

nights on-site which adds to the cost due to required travel time and housing for the crew. 

Subcontractors are sought from the local area, but if there are no local ones (often the case in 

rural areas) there is an added cost for the subcontractor to commute to the site. 

The tribe has tumed to the IHA to administer two HOME grants to build single family, 

homeownership units for tribal members. It will create a r~volving fund from the homebuyer 

payments which are similar to Mutual Help but with a minimum and maximum payment based on 

a sliding scale according to the family's ability to pay. The minimum payment is higher than 

Mutual Help; there is an annual recertification of income to determine the sliding scale payment, 
Assessment of American Indian Housing Needs and Programs: Final Report 182 

and the family gets title to the house in 25 years. The program uses a lease-purchase contract 

rather than a mortgage because tribal codes make mortgage foreclosure very difficult; eviction 

procedures for rentals or lease-purchase contracts, however, are less problematic. The sliding 

scale was adopted because families' incomes typically vary with frequent job turnover. This 

program will allow tribal members to remain in their home even if their income increases 

substantially--they will just have to make a larger monthly payment as long as their income stays 

at the higher level. In addition, homeowners are responsible for all utilities and maintenance cost. 

Interestingly, the MiSSissippi Choctaw IHA has not changed the basic deSign of the units 

utilized for Rental, Mutual Help or the HOME programs. Thus, the costs per unit are essentially 

the same under each program. Cost differences are generally due to the amount of site work 

required, for example, the least expensive units are on existing paved roads with existing water 

and sewer hookups; the second least expensive are units on a paved road with water but that 

need septiC tanks; and the most expensive units are in subdivisions where the IHA has to pay 

for the costs of paving streets and putting in water and sewer systems. These elements, coupled 

with the distance from the IHA to the construction site, create cost differences between projects. 

2. In order to reduce costs, the Cheyenne River Housing Authority, SD, developed 

an assembly site for housing construction. Cheyenne River is a reservation of about three million 

acres with several villages. Travel times are a significant issue in management and in the viability 

of the village economies. And, environmental conditions are extreme with high winds and 

temperature ranges from minus 70 degrees F. to over 100 degrees F. 

At the time of the on-site survey (summer 1994), 30 houses were being constructed in an 

area to the rear of the IHA's administrative building. Laborers were being brought in from the 

outlying villages. They stayed in tents and trailers near the assembly line during the week and 

retumed home on weekends (this saves on travel time and costs). The IHA does not use force 

account labor but the tribe has a strong Tribal Employment Rights Office (TERO) ordinance giving 

job preference to tribal members. 

The assembly site is surrounded by a fence which provides security and has resulted in 

less vandalism and materials "shrinkage." The proximity of the houses to the administrative 

offices and their concentration in one line has meant that quality control inspections are done on 

a daily basis. The design of these units has been modified to reflect a need for larger 

dining/living room and kitchen areas and higher R values in the walls, floors and ceilings. Even 

though the units are 20 percent larger and more energy efficient than previously developed units, 

the cost has dropped by $15,000 (15 percent) to about $80,000. After completion, the houses 

are trucked to the sites. The tribe's HIP program has used the assembly site as well, as have 

other builders. As with the example from Mississippi Choctaw, if you are able to speed up the 
Assessment of American Indian Housing Needs and Programs: Final Report 183 

construction time by using local labor and other innovations (e.g., an on-site manufacturing plant), 

you reduce costs of construction and provide the added benefit of creating local jobs. 

3. The Southern Puget Sound Housing Authority, WA, has created a nonprofit 

subsidiary, Sound Development Association (SDA), to provide mortgage assistance to enrolled 

tribal members both on and off trust land. Their four program offerings are: 

a. 	 Mutual Help Transition Program. This program is for current Mutual help 

participants moving from the reservation into privately financed housing. SDA 

loans the homebuyer money to buy an existing or newly constructed home. The 

amount of the loan depends on the homebuyer's household income. IHAs 

contribute a one-time grant for down payment assistance and closing costs which 

is forgiven over a ten year period. 

b. 	 Reservation Project-Based Program. This program is for tribal members buying 

new homes on trust land. Participants generally come from the IHA waiting list 

and will buy their house with a combination of an IHA grant and a loan from SDA. 

After the homes are built and financed, the IHA has no further involvement in such 

things as payment collections or maintenance. 

c. 	 Finance Leveraging for Indian Housing Authorities. This program is for IHAs using 

federal dollars to leverage private dollars in developing housing on and off trust 

land. SDA makes loans to the IHA for planned unit developments or scattered site 

single or multi-family units. IHAs manage the rental properties and are responsible 

for remitting loan payments to SDA. The units developed under this program are 

rentals whose revenue can create a solid operation budget for the IHA. 

d. 	 30 Year Fixed Rate Mortgage. SDA processes applications for 30 year fixed rate 

mortgages for tribal homebuyers buying existing or newly constructed homes either 

on or off trust land. The amount borrowed depends on household income. 

These programs are vel}' new with only six loans closed to date, and all of these loans 

are on fee land. SDA has yet to close a loan on restricted land although several are in the 

pipeline. In the case of a home on trust land, the tribe holds title to the land, and the land is 

leased by the purchasing family. While it could vary by the tribe and its locally adopted policy, 

houses are anticipated to be sold only to other tribal members. Individual loans have not created 

enough volume to pay for the cost of operating a mortgage company. Thus, SDA is looking at 

developing projects that will increase the volume of sales of home mortgages. Their plan for 

working with IHAs is still being shaped. SDA is providing technical assistance to IHAs that want 
Assessment of American Indian Housing Needs and Programs: Final Report 184 

to use their development funds as collateral for loans that would allow them to increase the size 

of a housing development. 

4. The Zuni Tribe, NM, used Indian COSG funds in a partnership arrangement to 

combine meeting housing needs with job training. The tribe worked with the University of New 

Mexico to train staff in the construction trades, and design and inspection services, then, using 

force account labor, rehabbed units in the historic area of Zuni Pueblo with a basic grant to 

homeowners ot-about $25,000 per unit. Zuni won a performance recognition award from ONAP 

for this effort. The tribe is now continuing to rehab units using HOME funds. 

5. At Pascua Yaqui, AZ, the Tribe has received HOME grant funds to construct 35 

homeownership units using force account and self-help labor with payments going into a revolving 

loan fund. New construction is allowed both on and off reservation at four scattered sites, and 

an adobe brick-making machine is being used to assist in the sweat equity effort. 

6. Housing Assistance CounciVNorthwest Area Foundation Demonstration. Two 

provisions in the 1990 National Affordable Housing Act (NAHA) have led to a demonstration of 

serving Indians in rural "underserved" areas. Section 708 of NAHA provides assurance to an 

Indian applicant seeking to mortgage tribal trust or allotted land that the land would never end up 

in the ownership of a non-tribal member or entity (Housing Assistance Council, 1993). Further, 

as noted earlier in this chapter, Section 709 targets more of FmHA's housing assistance funds 

in "underserved areas" and requires FmHA to deSignate 100 counties for this investment. 

In 1991, the Housing Assistance Council (HAC), a national nonprofit organization serving 

the rural poor, started a demonstration project to assist tribes in developing knowledge and 

capacity in order to make .FmHA financing a viable alternative for Native American households 

living on tribal trust or allotted lands. HAC's belief was that the two provisions in NAHA did not 

bridge the gap in basic knowledge about FmHA housing programs nor did they provide the 

capacity needed to develop project applications. HAC sought funds to provide training and 

technical assistance to "underserved" tribes to develop their capacity to package FmHA housing 

loans and grants. 

With technical assistance from HAC and financial support from the Northwest Area 

Foundation, four tribes have received technical assistance and training throughout the 

demonstration period (1991-1994) and are continuing to expand their activities to develop housing 

with funding from FmHA. The results from the first year and one half were slow but steady 

growth, with many rejections along the way: 143 applications were submitted through the end of 

1992, nearly 60 percent of which were for Section 504 home repair loans and grants. Rejections 

exceeded approvals by a 2:1 ratio. Sometimes this related to incomplete applications: 

specifically, inadequate provision of information on income, employment verification, or credit 
Assessment of American Indian Housing Needs and Programs: Final Report 185 

history. Several new issues concerning processing and eligibility had to be resolved along the 

way.61 

In addition, as part of the demonstration, the Housing Assistance Council was able to set 

up a revolving loan fund to assist HAC's tribal contractors with some of the required up-front 

costs. Another problem was that FmHA thought that even with the repairs that could be made 

with the maximum allowed (generally $5,000 for grants), the house would still not be free of 

serious hazards. Tribal coordinators argued that it was better to make some repairs and FmHA 

has allowed more flexibility in establishing health and safety standards (Housing Assistance 

Council, 1993, pps. 15-16). 

By the end of 1994, the closing of two Section 502 loans on the Cheyenne River Sioux 

Reservation was marked as an "historic" occasion as the event not only tested the knowledge and 

perseverance of the tribal loan packager, but also resulted from changes in FmHA policy with 

regard to appraisals on remote and tribal trust lands, and allowing the use of tribal rather than 

federal courts in the event of a foreclosure proceeding. Now, more loan and grant approvals are 

being made than rejected. Capacity building has occurred not only with the tribal coordinators 

but also within FmHA, which is now better able to deal with unusual circumstances and serve at 

least a small fraction of the Native American population. 

Legislation to institutionalize the "Building Indian Housing in Underserved Areas" within 

FmHA and extend it to up to 15 tribes, however, failed to pass Congress in 1994 when the 

housing authorization bill was tabled. 

7. The Minnesota Housing Finance Agency has been assisting the American Indian 

population since 1976 with its Minnesota Tribal Indian Housing Program. The program is funded 

through the state legislature. Three tribal housing corporations have been established by 

Minnesota tribal governments: (1) the Minnesota Chippewa Tribe Housing Corporation, (2) the 

Red Lake Housing Finance Corporation, and (3) the Minnesota Dakota Indian Housing 

Authority.62 

61For example, it is not uncommon for family members to move in with elderly or disabled relatives to help out 

temporarily. In this case it was unclear whose income should be counted. On this issue, FmHA decided that if the 

helping relatives were not permanent residents, their income would not be counted. Also, credit reports are costly for 

low-income households, especially if there is no guarantee that their application will be approved. Where two or more 

unrelated individuals are living in a home, FmHA was requiring that each individual pay the credit fee. FmHA has now 

decided that only the borrower or co-borrower need to pay the fee. 

62 National Commission on American Indian, Alaska Native and Native Hawaiian Housing, 1992, pp. 38-40. 
Assessment of American Indian Housing Needs and Programs: Final Report 186 

The corporations each have developed programs to address the unique housing needs 

of their particular area. These programs provide an array of housing options for the 11 Minnesota 

reservations in both rural and urban areas. The programs include rental assistance and mortgage 

financing for new construction, purchase, and/or rehabilitation of existing homes. Interest rates 

for program borrowers range from 4.5 to 8 percent, depending on the program. Because the law 

allows for considerable autonomy on the part of the tribal housing corporations, each program has 

its own house price limits, income guidelines, interest rates, selection process, service area, and 

application process. 

Each tribal housing corporation has set up a revolving fund used to finance other 

mortgage loans, including interim construction financing and rehabilitation loans, as well as 

administrative costs. They have also developed strong servicing procedures normally employed 

by any reputable mortgage servicer to follow through on borrower delinquency issues. The goal 

is to eliminate the need for the foreclosure process. The Minnesota HFA also provides intensive 

homeownership counseling which has led to the success of this program. The Minnesota tribal 

housing corporations have become self-sufficient agencies providing a variety of housing 

opportunities to their respective communities. 

ASSES~MENT AND IMPLICA TlONS 

1. 	 HUD programs have made a substantial contribution to improving housing 

conditions in tribal areas. HUD-financed housing is serving the types of 

households for which it was intended, although its distribution evidences some 

inequities geographically. 

HUD has provided financial assistance to tribes for a relatively short period of time 

compared to its programs in the nation's cities, but the production under its Rental and Mutual 

Help programs has greatly improved living conditions for thousand of families in Tribal Areas. 

HUD-financed programs have built homes that now house about one-fourth of the American 

Indian and Alaska native households living in Tribal Areas: 37-42 percent of those with low 

incomes. The availability of this housing may well have prevented the demise of some native 

communities altogether. 

Virtually all of the households occupying HUD-financed units have low incomes and nearly 

70 percent have very low incomes (below 50 percent of median). Almost all program recipients 

are AlAN households, although there is some minimal variation within the Rental Program. Only 

six percent of all IHA units in management in 1993 were vacant. 
Assessment of American Indian Housing Needs and Programs: Final Report 187 

Chapter 5 pointed out that the allocation of IHA housing across tribal areas is generally 

in proportion to the distribution of low-income households, however, some serious inequities do 

exist. Some tribal areas have received a much higher proportion in relation to need than have 

others. 

2. 	 HUD-assisted housing in Tribal Areas does have defects, but its condition is far 

better than that of the private housing stock in these areas, and it does not seem 

to be seriously at odds with Indian preferences. 

As detailed in Chapter 5, the share of HUD-assisted units in Tribal Areas that are 

overcrowded and/or with facility/condition problems is 24 percent overall (18 percent in Rental 

units and 28 percent in Mutual Help). This compares with 45 percent for unassisted units. Both 

residents and tribal staff seem to recognize these realities as survey data show appreciation for 

the benefits these units provide--comparatively few are highly critical. Criticism of the HUDassisted housing stock focuses on features like the lack of adequate storage space, Rental units 

being too close to each other, and an emerging concentration of crime and drug problems in 

Rental developments. The lack of sensitivity to cultural design features is recognized, but it does 

not seem to be a high priority issue compared to aspects that reflect the basic adequacy of 

structure and services. 

3. 	 In the past, cumbersome regulations and administrative procedures frustrated 

program efficiency. Since the late 1980s, however, HUD has taken steps to deal 

with most of the problems that have been within its power to address. 

Throughout the most of their history, HUD Indian housing programs existed in a 

cumbersome regulatory environment, including the often inappropriate application of rules and 

processes from the national public housing program in Indian Areas. Since the late 1980s, 

however, HUD has acted to address many of the problems that had existed by creating more 

flexible regulations separate from those of public housing, and reorganizing to create a separate 

Office of Native American Programs, and adopting a more customer-service oriented philosophy. 

Regulations have been substantially streamlined and requirements for detailed HUD reviews 

markedly reduced. In this period, HUD has also initiated management improvements that have 

led to reductions in development costs per square foot and in the time it takes to develop new 

projects. HUD's implementation of a reasonably objective and systematic system for recurrently 

monitoring IHA performance (the ACA) is also recognized as a valuable contribution. 
Assessment of American Indian Housing Needs and Programs: Final Report 188 

4. 	 There is much variation in IHA managerial capacity and performance. Differences 

in the adequacy and stability of institutional settings in various Tribal Areas seem 

important in explaining this variation. 

This study was not expected to conduct a detailed management audit of IHA periormance, 

but the more general indicators available do shed light on how well they have done their job. 

Overall, neither the speed nor cost of new housing development seems excessively high, given 

the type of housing being produced and the special problems of construction and infrastructure 

provision that exist in Tribal Areas (due primarily to the remoteness of many of them). Similarly, 

operating costs in the Rental program, on average, compare reasonably well with the more 

effective range of periormance in public housing (although additional efficiencies could no doubt 

be gained). 

A major problem does remain in that beneficiaries in some areas are substantially 

delinquent in their rent and homeowner payment obligations. TARS (tenant accounts receivable) 

have grown to represent very large amounts on a per-unit basis in these areas. It is recognized 

that forceful collection methods are likely to be in conflict with tribal culture in many locations, but 

this still represents a problem to be addressed. Also, we judge that operating cost levels in 

Mutual Help bear more scrutiny--these costs range widely per-unit-month and expectations as to 

what should be accomplished per dollar are less clear than they are in the Rental program. 

Probably the most important finding of this component of the work, however, is the broad 

variation in overall periormance that exists among the IHAs. A large number seem to function 

quite effectively, but others clearly have great difficulty in periorming the basic tasks of housing 

development and management. 

Statistical analysis showed that variations in I HA size, location, or service-area income had 

little influence in explaining these differences. The only available indicator that stood out as 

significant was the rate of turnover among IHA directors. The lowest quartile of periormers 

(according to ACA scores) had on average, six directors over the past ten years--about twice the 

average for the other groups. Director turnover and IHA periormance problems may well be 

influenced by tribal governance patterns. The lowest I HA periormers also had the highest 

percentage of IHA board members who were appOinted rather than elected by the tribe, and the 

highest turnover in board members. There is good reason to expect that the stability and 

effectiveness of tribal governance has an important effect on a tribe's ability to secure and retain 

a good director and create an environment in which effective IHA management can occur. 
Assessment of American Indian Housing Needs and Programs: Final Report 189 

5. 	 Nonetheless, despite the recent streamlining of regulations and mostly because of 

categorical constraints inherent in their authorizing legislation, the Rental and 

Mutual Help Programs provide neither the incentives nor the flexibility needed for 

tribal and IHA officials to apply federal funds creatively to address the housing 

needs of Indian country efficiently and effectively. 

The most important empirical finding of this study is not that Federal housing assistance 

serves so many, but that it still serves such a small share of those with desperate housing 

problems; from 63 to 68 percent of all low-income AlAN households in Tribal Areas, almost all 

of whom have housing problems, receive no benefits whatsoever. Federal housing assistance 

in Indian country approximates an "all or nothing" game. While a significant fraction of the 

households in need are benefiting from substantial subsidies, even larger numbers in similar 

circumstance receive nothing. 

And there are policies that can address these issues more effectively. At the lower end 

of the income scale, it is clear that many more households could be served by supporting them 

in developing very basic decent units (with no or limited infrastructure) on a self-help basis (at 

much less cost per family served). A startling finding from this study (noted in Chapter 5) is that 

even though a self-help component in Mutual Help has been authorized for some time, not one 

IHA is using it. We asked one HUD official why. His answer, having profound policy implications 

was, "because the standard Mutual Help program exists." 

In other words, with substantial funding continuing to be delivered through just one rigidly 

defined program mechanism, IHAs and households had no incentives to try alternatives. The 

reality this study has exposed is one of diversity; not only between Tribal Areas, but within them. 

Families in every Tribal Area have a wide range of needs and incomes. Those at the lower end 

should be able to get "something," being obligated to pay only a very modest amount for it. 

But there are gaps at the higher end as well. Families just below the low-income threshold 

might be able to purchase a house if they were provided with only a limited amount of downpayment assistance--but HUD Rental and Mutual Help funding cannot be used in that way. 

Similarly, if a state government or private investor were willing to put up substantial funding for 

new housing construction assuming the tribe would put up a partial match, the tribe is statutorily 

prevented from using the main stream of Federal assistance it receives (HUD Rental/Mutual Help 

funding) for that purpose. 

In between the high and lower ends of the low-income range, programs like that being 

implemented by Mississippi Choctaw seem attractive--they offer a range of packages that can 

vary by household need and income. Every family pays a share of the cost that is reasonable 
Assessment of American Indian Housing Needs and Programs: Final Report 190 

given its own resources. And the family's contribution can vary over time if its circumstances 

change, without it being forced to move out of its home. 

Therefore, mainly due to statutory constraints, IHAs cannot easily pursue broader housing 

strategies. A number of IHAs and tribal leaders say they would like to pursue more creative 

financial strategies such as leveraging HUD funds, using HUD funds to credit enhancement, and 

developing revolving loan funds. Others seek more access to tenant-based assistance, ability 

to provide downpayment assistance to would-be homeowners, or the freedom to provide some 

housing assistance to a broader range of income groups to maximize their resources. Many of 

these activities are precluded from the available uses by HUD's current Indian housing programs. 

While there is still a major need for new construction, the flexibility to pursue a variety of housing 

strategies with program funds would probably result in lower delivery costs and increase the 

number of beneficiaries. 

6. 	 Federal assistance in and of itself will never be a sufficient or appropriate way to 

deal with the full range of housing problems and opportunities in Indian country. 

Further priority needs to be given to economic development in Tribal Areas with 

related policy thrust to encourage more private investment in Indian housing. 

Incomes remain extremely low in Tribal Areas on average. Regardless of the amount of 

Federal housing assistance provided, some of these communities may well not survive unless 

they find some way to enhance their local economies. Evidence from the studies by Cornell and 

Kalt cited earlier show that some tribes are making considerable progress in this regard; i.e., there 

are models for economic development success in Indian country. ONAP, through its responsibility 

for ICDBG, should be able to exert more influence (as well as provide needed technical 

assistance) to encourage other tribes to broaden their own economic opportunity. 

Successful economic development will, of course, reduce the need for Tribal Area 

dependence on housing subsidies. But even today, our data have demonstrated that there are 

large numbers of households in Tribal Areas with incomes above the cutoff for Federal housing 

assistance that are still not well housed. The barriers that now prevent private mortgage lending 

in Indian country, noted earlier in this Chapter, clearly remain formidable. 

The lack of financial institutions in many Indian areas has clearly constrained the 

development of a private market economy, and the more remote the location, the more serious 

this problem is likely to be. In many Tribal Areas, American Indians and Alaska Natives still use 

a cash/barter economy; they do not have bank accounts, use neither credit cards nor ATM 

machines, and have no credit references. 
Assessment of American Indian Housing Needs and Programs: Final Report 191 

There is also a lack of understanding on the part of financial institutions--both private and 

public--regarding Indian land, tribal court systems, local culture, and tribal governments. On the 

other side, there is a lack of tribal government understanding of the private market real estate 

industry, fee simple title, title insurance, equity build up, and housing market requirements. Local 

land barriers also inhibit development, including customary land use such as formal and informal 

assignments of land to various families or clans to specific tribal trust land areas. And, basic 

infrastructure which is taken for granted in urban areas of America is still being developed in tribal 

areas. A complete approach to Tribal Area housing policy must include sensible initiatives aimed 

at addressing these issues. 

7. 	 Even if most remaining program restraints were eliminated, local barriers would still 

make housing development in Tribal Areas more difficult and costly than it is in 

typical urban markets. These include local constraints on the ability to develop 

land, internal land allocation problems, and a lack of capital to finance and maintain 

infrastructure development in many tribal areas. 

Over half the IHA directors and tribal leaders interviewed reported that local land control 

and use problems internal to tribal governance, in addition to the basic status of trust land, 

frustrate the development process. Internal land use restrictions stem from several sources 

including: units of self-governing districts within reservation boundaries that limit movement within 

the reservation; formally assigned land; historic or customary land use areas which are 

considered to belong to a family or clan even if not formally assigned; and proscription of certain 

pieces of land from being used for housing development because they are being reserved for 

agricultural, grazing or other uses. Existing HUD programs, with the exception of Indian CDBG 

and HOME, do not provide significant funds for land development or acquisition. 

The lack of infrastructure and capital investment funding is a barrier to housing 

development not only in Alaska, but also in the lower 48 states. Most tribes and IHAs cited lack 

of funding for roads and other infrastructure as a major gap in Federal program funding. The lack 

of basic financial services, especially in remote areas inhibits the development of a private market 

economy that in turn inhibits private sector housing development. 

REFERENCES 

Housing Assistance Council. 1993. Demonstration of Building Indian Housing in Under served 

Areas: An Evaluation and Recommendations. Washington, D. C.: Housing Assistance 

Council. 
Assessment of American Indian Housing Needs and Programs: Final Report 192 

National Commission on American Indian, Alaska Native and Native Hawaiian Housing. 1992. 

Building the Future: A Blueprint for Change. Washington, D.C.: National Commission on 

American Indian, Alaska Native and Native Hawaiian Housing. June. 

ONAP (Office of Native American Programs). 1994. Native American Programs Annual Report, 

1993. Washington, D.C.: U.S. Department of Housing and Urban Development. January. 

U. S. Department of Housing and Urban Development (HUD), Office of Policy Development and 

Research. 1992. Feasibility of Expanded Use of Section 8 Vouchers by Indian Housing 

Authorities. Washington, D. C.: U. S. Department of Housing and Urban Development 

U.S. Department of the Interior, Office of the Inspector General. 	 1992. "Audit Report: Selected 

Housing Program Operations of the Albuquerque Area Office, SIA." Report No. 92-1-1042. 

Washington, D.C.: U.S. Department of the Interior. July. 

U.S. General Accounting Office. 	 1987. "Internal Controls: Indian Housing Controls Improved but 

Need Strengthening." Report to the Secretary of the Interior, GAO/RCED-87-148. 

Washington, D.C.: U.S. General Accounting Office. August. 
PART III 
 

POLICY DIRECTIONS 
 

Chapter 7 

THE POLICY SETTING 

Part I of this report has demonstrated that the housing problems of American Indians and 

Alaska Natives remain enormous. It has also demonstrated, however, that the nature of those 

problems (and the social and economic circumstances that surround them) differ markedly in 

different comrnunities. These differences are pronounced even among Tribal areas, and they 

point to the need for a wide range of housing strategies designed so that they "fit" the individual 

circumstances at hand. 

Part II has assessed existing Federal housing assistance programs and the manner in 

which they have been responding to perceived problems and needs. This assessment recognizes 

the important contributions HUD programs have made to the improvement of housing conditions 

in Tribal Areas, and finds few serious problems with the way those programs are being 

administered under their current statutory framework. It concludes, however, that the statutory 

framework itself is overly restrictive. 

A two-part approach to policy falls naturally from these findings and conclusions. First, 

there is a need to substantially reform the nation's current approach to providing housing 

assistance for low-income families in Indian communities--to deliver assistance more equitably 

and efficiently. How that may be addressed is the subject of Chapter 8. Second, the analysis 

makes it clear that Federal assistance in and of itself will never be a sufficient or appropriate way 

to deal with the full range of housing problems and opportunities in Indian country. Alone, it can 

never create a viable and self-sustaining system for delivering adequate housing services. 

The ultimate solution to the dire housing circumstances in Indian country today will still 

require Federal assistance, but it will also rest on spurring private sector housing activity. Indeed, 

it appears that current market circumstances would warrant expanded private housing investment 

for the AlAN population even now, but various constraints are holding back what, in the rest of 
Assessment of American Indian Housing Needs and Programs: Final Report 194 

the country, would be seen as a natural market response to expressed housing needs. Market 

potential and policies that might be implemented to take advantage of that potential are 

addressed in Chapter 9. 

This Chapter provides a context for the policy analysis and program recommendations 

which follow in Chapters 8 and 9. It does three things. First, it reviews the trust/fiduciary 

obligations that establish the relationship between the Federal government and Indian tribes. 

Second, it examines two important trends in policy thought that affect the environment in which 

those relationships are now being more clearly defined: self-determination and reinventing 

government. Finally, it offers a way of looking at the question of the adequacy of Federal funding 

for Indian housing assistance for the purposes of this report. 

TRUST/FIDUCIARY OBLIGA TlONS 

Development of a comprehensive, effective, and long-term Federal housing policy must 

take cognizance of historic, ongoing, and anticipated future changes in pertinent institutions and 

processes within which policy is to be implemented. We discuss here the sovereign-to-sovereign 

relationship between the U.S. Government and recognized tribes. 

Although closely related, the concepts of sovereignty, self-government, self-determination, 

and autonomy are not synonymous. Understanding those concepts, at a level beyond the 

introduction provided in Chapter 1, is important to analysis of Indian policy generally and to 

development of viable Indian housing policy in particular. 

Indian tribes are recognized under treaty and constitutional decisions as constituting 

sovereign entities. Sovereignty implies the "power of a nation to determine its own course of 

action with respect to other nations" (Deloria, 1979). Self-government implies that the tribe's 

governmental structure is controlled by the tribe, i.e., that tribal members act through tribal 

government to make and to implement decisions perceived as being in the best interest of tribal 

members. 

While sovereignty and self-government are necessary for self-determination to occur, they 

are not, in and of themselves, sufficient conditions. Tribes must also have the opportunity to 

determine their own destiny, but Indian tribes exist within a largely market oriented economic 

system and a federal pOlitical system, both of which may either enhance or restrict 

self-determining activities by tribes. Tribes can effectively exercise self-determination only if they 

have both the political, social, and economic institutions within which to make decisions. 
Assessment of American Indian Housing Needs and Programs: Final Report 195 

Considerable confusion and disagreement persist regarding the Federal government's 

responsibilities toward American Indians and Alaska Natives. These owe in considerable 

measure to ambiguity implicit in the several statutes, treaties, and public policy pronouncements 

which frame the Federal government's relationships with American Indians and Alaska Natives. 

Intergovernmental agreements between agencies of the United States Federal government 

and tribal governments predate the Constitution, with both the Continental Congress and the first 

American Congress under the Articles of Confederation establishing agreements with tribal 

governments by treaty. The Federal government's obligations to Indian governments in those 

prior agreements were explicitly recognized in the Constitution, and in countless treaty 

agreements since then.63 

Agreements have variously referred to the Federal government's relationship with tribal 

governments as one of "trustee," "guardian," and "fiduciary." Whether explicit or implied, those 

agreements have specified "responsibilities," "promises," and "obligations" which the Federal 

Government is expected to fulfill. 

Despite ambiguity in the meanings of trust, fiduciary, and speCial relationship, the 

dimensions of the Federal government's policy toward American Indians and Alaska Natives have 

been delimited primarily by the Executive and Legislative branches of the U.S. Government. 

Federal responsibilities have been further delimited by a series of court decisions: 

That the Federal government's legal responsibilities as trustee and guardian extend to 

Indians both as individuals and as members of tribes was probably established most definitively 

in Sf. Paul Intertribal v. Reynolds: "In light of the broad scope of the trust doctrine, it is not 

surprising that it can extend to Indians individually, as well as collectively .... "64 This has also 

been confirmed in other cases. For example, in Eric v. Secretary of United States Department 

of Housing and Urban Development, the court concluded that: "The trust doctrine is not limited 

to situations in which the government is managing property owned by an Indian tribe as 

defendants contend." The decision also referenced a U.S. Supreme Court case which "applied 

the trust doctrine so as to require stricter administrative standards in the management of an 

'off-reservation gratuity.",65 

83See, for example, U.S. Senate. Special Committee on Investigations. 1989. "Executive Summary," A New 

Federalism for American Indians, pp. 16-17. 

64St. Paul Intertribal Housing Bd. v. Reynolds, 564, Federal Supplement, D. Minnesota (1983), p. 1414. 

"Eric v. Secretary of United States Department of Housing and Urban Development, 464, Federal Supplement 

(1978), p. 49. Also, see Morton v. Ruiz, 415, U.S. 199,236,94 S.Ct. 1055,39 L.Ed.2d 270 (1974). 
Assessment of American Indian Housing Needs and Programs: Final Report 196 

That the Federal government's trust responsibilities are independent of who administers 

Federal assistance programs was concluded by the court in Eric v. Secretary: "The trust doctrine 

is not limited to situations in which the government is managing property owned by an Indian 

tribe....lf the government cannot shed its trust obligation by delegating its responsibility to the 

tribe, it is unlikely it could do so by delegation to a state."ss 

That the Federal government's trust responsibilities include housing services was a 

determination by the court in St. Paul Intertribal v. Reynolds: "Provision for housing is well within 

the spirit of the trust doctrine as defined above."s7 

THEMES IN THE BROADER POLICY ENVIRONMENT 

The way relationships between tribes and the Federal government will be made 

operational in the future will undoubtedly be influenced by two broad trends in policy thought that 

have considerable bipartisan support: the movements related to self-determination and reinventing 

government. 

The Self-Oetermination/Self-Government Movement 

In recent years, the watchword in federal assistance programs for Indians has been 

"self-determination "--helping native Americans and their tribal governments manage their 

own affairs with a minimum of direct federal involvement. In essence, the ultimate goal 

of these programs is tribal autonomy. (Government Information Services, 1992). 

The movement toward self-determination and self-governance for Indian tribes dates from 

the mid-1960s.s8 Several Congressional Acts represent particularly important steps in the 

development of the nation's Indian self-governance policy: 

The Indian Self-Determination and Educational Assistance Act of 1975 (P.L. 93-638) 

established the right of Indian tribes to take over and operate for themselves programs previously 

66Residents of Alaska native villages brought action against HUD, alleging breach of trust responsibilities in 

administering the Bartlett Act, a statute providing a method for distributing funds to the State of Alaska to assist in 

providing housing primarily for Alaska Natives. Eric v. Secretary of United States Department of Housing and Urban 

Development, 464, Federal Supplement, D. Alaska (1978), p. 49. 

67 st. Paul Intertribal Housing Board v. Reynolds, p. 1414. For an excellent survey of the legal foundations of 

U.S. Indian housing policy, especially as implemented by HUD and IHAs, see Ulmer, 1990. 

68See, for example, U.S. Commission on Human Rights, 1981. 
Assessment of American Indian Housing Needs and Programs: Final Report 197 

operated by the Bureau of Indian Affairs (BIA) and the Indian Health Service (IHS). The Act 

permitted tribes to enter into "638" contracts with BIA and IHS whereby the contracting agency 

would pay directly to the contracting tribe those funds which the agency would otherwise have 

expended to operate the program. 

The Indian Tribal Government Tax Status Act of 1982 (P.L. 97-473) established the right 

of Indian tribes to issue tax-exempt bonds. The Indian Gaming Regulatory Act of 1988 (25 USC 

pp.2702-2721) established the right of tribes to compact with states. 

That the self-governance and self-determination movement enjoys wide support and 

encouragement is amply attested to. For example, the U.S. Senate Special Committee on 

Investigations called for the "empowerment of tribal self-governance through formal, voluntary 

agreements" resting on "mutual acceptance of four indispensable conditions," including that: 

"Federal assets and annual appropriations must be transferred in toto to the tribes." (U. S. 

Senate, 1989). The first "Principle for Reorganization" which the Joint Tribai/BIAIDOI Advisory 

Task Force on Bureau of Indian Affairs Reorganization (1992) proposed for the Bureau of Indian 

Affairs was "decentralization with movement of maximum funding and decision making to the 

Tribe." 

The BIAIIHS Self Governance Demonstration. The Tribal Self-Governance 

Demonstration Project of 1988 (P.L. 100-472) established the right of tribes to enter into compacts 

with the Department of the Interior and with IHS, thereby enabling them to receive as a single 

combined grant all the funds which the compacting agency would otherwise have expended in 

providing its programs and services to tribal members. 

The Self-Governance Demonstration Project was recently audited by the Inspector General 

of the U.S. Department of the Interior (1995). The audit report concluded that the 10 participating 

tribes audited "generally accomplished the objectives" of the project. According to the audit 

report, the new self-governance authority given tribes under the project resulted in their creating 

new programs as well as increasing services provided under pre-existing programs to the mutual 

benefit of tribes and individual Indians. The self-governance tribes developed program priorities 

according to tribal needs rather than following BIA's program objectives. 

Although it was never enacted, a draft Indian Housing Demonstration Project Act, was 

introduced in the House of Representatives in 1991, that would essentially to replicate the 

BIAlIHS Demonstration project in the housing field. Under this proposal, the Secretaries of the 

Interior and of HUD would have jointly administered a demonstration program to test the 

effectiveness of enabling five to ten tribes to receive all Federal housing program assistance as 

a lump sum and determine their own housing needs. 
Assessment of American Indian Housing Needs and Programs: Final Report 198 

Under this proposal, participating tribes would have been required to submit a plan 

describing how they would maintain projects, give priority to low-income Indian families, and 

develop alternative financing strategies. In addition to transferring Federal assistance to 

participating tribes, the proposal would have also transferred to tribes "all of the rights, titles, and 

interests of the United States and any IHA of the tribe" in housing units and projects on the trust 

lands. For all practical purposes, the proposal would have terminated any independent authority 

of an IHA (Walker, 1992). 

In 1993, legislation was introduced in Congress to make the Self-Governance project a 

permanent part of Federal Indian policy, its sponsor arguing: "It is the right direction at the right 

time." Despite the sponsor's inability to have the Housing Demonstration Project enacted during 

the previous session of Congress, he said he thought it only a matter of time before "we will 

expand Self-Governance to other departments of the Federal Government" (Richardson, 

1994). 

In sum, although its development has been sporadic, Federal policy toward Indians has 

generally been trending toward greater self-governance for the last two to three decades, 

culminating in the current 638 contracting program and the Self-Governance Demonstration 

project. But the tribal self-governance movement has also been evident, albeit on a more modest 

scale, in the areas of Federal housing programs and services. The two most notable changes 

in housing policy toward Indians in recent years have been the consolidation of HUD's housing 

activities within the Office of Native American Programs (ONAP), and the streamlining and 

simplifying of regulatory requirements for those programs to afford tribes greater administrative 

flexibility (as discussed in Chapter 5). 

Part of the rationale for HUD's reorganizing and restructuring its Indian housing programs 

was undoubtedly a desire for administrative efficiency. However, those changes also represent 

a deliberate attempt to further the cause of Indian self-determination. The stated "primary goal" 

of HUD's proposed rule amending the Indian Housing Consolidated regulations is "to provide 

greater discretion and responsibility to IHAs in carrying out their housing programs, thereby 

returning them to local control" (HUD, 1994). 

Above all, the Native American community itself continues to call for changes in Federal 

programs which would permit greater local autonomy in meeting housing needs. Many of the 

recommendations of the National Commission on American Indian, Alaska Native, and Native 

Hawaiian Housing (1993) involve long-term solutions to Native housing needs which also further 

tribal self-governance: 

The Commission has found that another risk of total reliance on Federal housing programs 

is the constraint on Native communities to structure their housing developments more to 
Assessment of American Indian Housing Needs and Programs: Final Report 199 

suit federal program requirements than to meet their own needs. Furthermore, such 

reliance on the federal government runs counter to Native communities' goals of self 

determination and economic self-sufficiency. 

The Canadian Self-Government Experience. Canada's transfer of program 

responsibilities to Indian tribes paralleled, and in many ways anticipated, the U.S. experience in 

recent years. Therefore, a brief overview of Canada's major initiatives du ring the last decade may 

provide insight regarding the feasibility of comparable U.S. initiatives (Indian and Northern Affairs 

Canada, 1993): 

In 1986, the Canadian Government introduced new alternative funding arrangements 

(AFAs) for Indian bands. AFAs provide bands with increased authority to manage funds received 

from the Govemment. Also in 1986, Community Self-Government legislation was enacted, 

enabling the Sechelt Band of British Columbia to become the first self-goveming Indian 

community in Canada. 

In 1988, the Government introduced guidelines to conduct up to 15 separate 

community-based self-govemment negotiations; fourteen framework agreements have been 

signed and substantive negotiations are under way on others. The Kamloops Amendments 

enacted in 1988 clearly established the power of band councils to tax reserve lands. 

In 1992, Aboriginal people became full participants in the Canada Round of constitutional 

discussions. Leaders of Canada's four major Aboriginal groups conducted unprecedented 

consultations among their people, gaining recognition of their inherent right to self-government 

by non-Native leaders across Canada. 

In December 1992, Canada's House of Commons' Standing Committee on Aboriginal 

Affairs released its Fourth Report entitled: A Time for Action: Aboriginal and Northern Housing 

(1992). The report's recommendations included: 

• 	 that the government deliver all of its funding for Aboriginal housing through one 

department or agency; 

• 	 that the Govemment of Canada transfer, in consultation with AbOriginal people, 

control of housing along with sufficient resources to Aboriginal people in order to 

ensure that there is greater community control over the development and delivery 

of housing programs; 
Assessment of American Indian Housing Needs and Programs: Final Report 200 

• 	 that the Governrnent of Canada provide the necessary funding to rneet the 

housing needs of all Aboriginal and northern people living on-reservation, 

off-reserves, and in the North; 

• 	 that the Government of Canada recognize that Aboriginal people have particular 

cultural and practical housing needs which are not being addressed due to the 

rigidity of current federal housing programs; 

• 	 that the Government of Canada recognize that the only way to provide the 

flexibility that Aboriginal people need to ensure the delivery of the kind of housing 

best suited to their particular needs is through self-government for Aboriginal 

people; 

• 	 that prograrn guidelines ensure that the maximum possible flexibility is provided 

to Aboriginal organizations participating in those programs; 

• 	 that the Government provide greater opportunities for homeownership on-reserve, 

off-reserve, and in the North through the development and expansion of 

homeownership programs, and the encouragement of innovative solutions aimed 

at addressing impediments faced by Aboriginal people to homeownership; and 

• 	 that the Government address immediately the housing related infrastructure needs 

of Aboriginal and northern people. 

The concept of self-determination in the U.S. is similar to the idea of self-government in 

Canada. However, transfer of Government programs and policies to Indian bands has proceeded 

more rapidly than in the U.S. By the end of 1993, it is estimated that Indian people had been 

given control of some 80 percent of the Indian and Inuit Affairs program budget. 

The Reinventing Government Movement 

The principles for reinventing government would seem to be equally applicable, and wholly 

complementary, to devising a workable self-determination strategy to guide Federal housing policy 

for Native Americans and Alaska Natives. The Report of the National Performance Review for 

installing reinventing government approaches at the Federal level (Gore, 1993) identified the 

following principles: 

We will invent a government that puts people first, by: Cutting unnecessary spending; 

Serving its customers; Empowering its customers; Helping communities solve their own 

problems; and Fostering excellence. Here's how. We will: Create a clear sense of 
Assessment of American Indian Housing Needs and Programs: Final Report 201 

mission; Steer more, row less; Delegate authority and responsibility; Replace regulations 

with incentives; Develop budgets based on outcomes; Expose federal operations to 

competition; Search for market, not administrative, solutions; and Measure our success 

by customer satisfaction. 

If "serving," "empowering," "helping" and to "delegate authority and responsibility" are 

advocated for customers and communities with which the Federal government interacts, they 

would seem especially apropos in its relationships with Indian tribes and other sovereign 

governmentS. 

In Reinventing Government, Osborne and Gaebler (1992) embrace decentralized authority 

and participatory management, arguing that: "If a department or program director does not have 

the opportunity to do things wrong, authority is lacking to do them right." However, the authors 

also recognize the critical link between empowerment and accountability: "The success of 

empowerment is...directly dependent on the success of other concepts ... including accountability 

for results." 

CONSIDERING THE ADEQUACY OF 
 

FEDERAL FUNDING FOR INDIAN HOUSING 
 

The first recommendation of the National Commission on American Indian, Alaska Native, 

and Native Hawaiian Housing (1993) addresses the inadequacy of Federal funding: "A clear 

consensus exists: greater funding is needed to address the critical housing needs in Native 

communities in the United States." 

The findings of this study certainly corroborates that conclusion. Housing problems of 

American Indians and Alaska Natives remain far more severe than those of non-Indians, 

particularly in Tribal Areas. In 1990, for example, the proportion of AlAN households overcrowded 

or lacking either plumbing or kitchen facilities was five times the share for all U.S. households (28 

percent vs. 5.4 percent). In total, more than four in ten housing units in Tribal Areas occupied 

by American Indians or Alaska Natives are over-crowded and/or have severe condition/facilities 

problems; the comparable share for AlAN occupied units in other areas of the country averages 

only about one in ten. Moreover, needs appear to be grO\~ing, e.g., the number of low-income 

AlAN households with the most severe housing problems probably increased by over 7 percent 

from 1990 to early 1994. Federal housing assistance is not keeping up. 

There is little debate about the justification for continued Federal assistance for Indian 

housing. The initiative being exhibited by many tribes in assuming central responsibility for their 
Assessment of American Indian Housing Needs and Programs: Final Report 202 

own futures is evidence that they do not want dependency to be the central feature of their 

development. On the other hand, it is clear that the consequences of withdrawing Federal 

housing assistance at this point would be disastrous. The circumstances in many Tribal Areas 

will not support housing development that relies solely on market forces. In addition, the section 

on trust and fiduciary obligations at the beginning of this chapter makes it evident that the 

provision of assistance to American Indians and Alaska Natives for housing is consistent with 

fundamental legal responsibilities of the Federal government. 

A relevant question, however, is what level of increase in Federal assistance would be 

appropriate to address these needs. Clearly, that question cannot be answered by taking 

numbers on the total number of Low-Income AlAN households with housing problems and 

multiplying it by the cost of a typical new Rental or Mutual Help unit. Approaching the problem 

in this way would be quite inefficient. Most of these households do not need a new unit produced 

by government. Depending on the area, many households in need could be more efficiently 

through assisted repair and rehabilitation of existing units, through tenant-based assistance, and, 

in a nontrivial number of cases, through limited help with down payments for the purchase of 

private units. 

Despite exhibiting among the highest incidences of poverty and housing problems of any 

population group in the United States, a sizeable proportion appears to have sufficiently high 

incomes to pose an equally sizeable potential demand for homeownership, e.g., one out of four 

AlAN renter households has an income 95 percent of the area median or higher. While the 

operation of non profits and private firms in providing housing services in Indian country cannot 

be the whole story, it can be a more important part of the story than it has been in the past. 

While the Federal government has an obligation to provide assistance, few would disagree 

that it is reasonable to expect that assistance to be delivered efficiently. This is particularly so 

in light of the formidable pressures that now exist to economize in Federal outlays overall. But 

it is also fully consistent with the basic themes of self-determination and reinventing government 

discussed earlier in this chapter. Also consistent with these themes is the notion that the best 

way to achieve efficient program delivery will rest on creative mixes of program strategies 

developed locally in response to local needs and circumstances. Accordingly, this report makes 

no effort to estimate or recommend any total level of subsidy assistance to be provided. 

Recommendations in the remainder of this report concentrate on means by which such assistance 

could be more effectively applied. 

In summary, there is much evidence to suggest that American Indians and Alaskan 

Natives do not want lives that are characterized by "dependency." But continued assistance from 

the Federal government to Tribal Areas is not only a legal obligation in most cases (under treaties 

between sovereigns); all indications are that it has widespread support. This is borne out by the 
Assessment of American Indian Housing Needs and Programs: Final Report 203 

recognition that withdrawal of Federal assistance would imply a devastating blow to the cultural 

richness of our nation as well as breach a moral obligation in response to past injustices. The 

enormous unmet housing needs in Tribal Areas documented in this report justify expanding 

Federal housing assistance to these Areas, but it is reasonable for Congress to expect that such 

assistance be delivered in a more efficient form than it has been in the past. The challenge is 

to provide support in a manner that leverages and expands the power of Native Americans to 

control and enhance their own destinies. 

REFERENCES 

Canada. House of Commons. Standing Committee on Aboriginal Affairs. 1992. "A Time for 

Action: Aboriginal and Northern Housing." 

Deloria, Vine Jr. 1979. "Self-Determination and the Concept of Sovereignty," in Economic 

Development in American Indian Reservations, ed. Roxanne Dunbar Ortiz and Larry 

Emerson, Albuquerque: University of New Mexico American Indian Studies Center. 

Gore, AI. 1993. From Red Tape to Results: Creating Government that Works Better and Costs 

Less, Report of the National Performance Review. Washington, D.C.: U.S. Government 

Printing Office. September. 

Government Information Services. 1992. "Native American Programs." 1992. Guide to Federal 

Funding for Governments and Nonprofits. 

Indian and Northern Affairs Canada. 1993. "Indian Affairs and Northern Development: Major 

Initiatives in the Last Decade." Information. Information sheet no. 57. October. 

Joint Tribai/BIAIDOI Advisory Task Force. 1992. "Report on Bureau of Indian Affairs 

Reorganization to the Secretary of the Interior and Appropriations Committees," 

(December). 

National Commission on American Indian, Alaska Native, and Native Hawaiian Housing. 1993. 

Supplemental Report and Native American Housing Improvements Legislative Initiative. 

Washington, D.C.: National Commission on American Indian, Alaska Native, and Native 

Hawaiian Housing. September. 

Osborne, David and Ted Gaebler. 1992. Reinventing Government. Massachusetts: 

Addison-Wesley Publishing Company, Inc. 
Assessment of American Indian Housing Needs and Programs: Final Report 204 

Richardson, The Honorable Bill. 1994. "The Tribal Self-Govemance Act of 1993." Sovereign 

Nations, Vol. 3. January. 

U.S. Commission 	 on Human Rights. 1981. Indian Tribes: A Continuing Quest. Washington, 

D.C.: U.S. Govemment Printing Office. 

U.S. Department of Housing and Urban Development (HUD). 	 1994. "Indian Housing Program: 

Proposed Amendments," Federal Register, Vol. 59, No. 146 (August 1). 

U.S. 	 Department of Interior, Office of the Inspector General. 1995. "Self-Govemance 

Demonstration Project, Department of the Interior Audit Report No. 95-1-699," 

Washington, D.C. March. 

U.S. Senate, Special 	 Committee on Investigations. 1990. "Executive Summary: A New 

Federalism for American Indians,". 

U.S. Senate. 	 Special Committee on Investigations. 1989. A New Federalism for American 

Indians. Washington, D.C. 

Ulmer, Mark K. 1990. "The Legal Origin and Nature of Indian Housing Authorities and the HUD 

Indian Housing Programs." American Indian Law Review. Volume 13, Number 2. 

Walker, Jana. 1992. "Testimony on H.R. 4027, The Indian Housing Demonstration Project Act 

of 1991." May 29. 
Chapter 8 

REFORMING FEDERAL HOUSING 

ASSISTANCE 

As documented in Chapter 3, the housing needs of American Indians and Alaska Natives 

are great by virtually any standard--affordability, crowding, or adequacy. The salient conclusion 

drawn from Chapters 4 to 6 is that, while substantially improving the living conditions for 

thousands of families, to date, assisted housing programs have been able to address only a 

fraction of Indians' housing needs. 

A key implication deriving from this finding is that, absent substantially increased funding, 

Federally assisted housing programs must be delivered more efficiently, particularly by increasing 

flexibility in their use. How Federal housing assistance programs may be usefully restructured 

is the topic of this chapter. 

BROAD ALTERNA TlVES FOR FEDERAL HOUSING ASSISTANCE 

The analyses of needs and programs undertaken in preceding chapters of this report lead 

to three principal implications for future policy: First, increased federal funding assistance would 

seem warranted, given the size and seriousness of housing problems documented to exist in 

much of Indian country. Second, the extent by which housing needs exceed available resources 

implies the need for increased efficiency in the use of housing programs, both by producing more 

housing services with existing resources and by leveraging) additional resources from alternative 

sources. Third, increased efficiency will require greater flexibility in the design and operation of 

housing programs, especially to permit localities to tailor housing programs to their particular 

housing need priorities. Additional, related policy issues involve long- vs. short-term tradeoffs, 

tribal vs. individual decision-making, public vs.private sector mix of housing activities, and the 
Assessment of American Indian Housing Needs and Programs: Final Report 206 

appropriate roles for IHAs and tribes. It is fundamentally clear that the issue of tribal selfdetermination cannot be avoided in assessing options for Federal housing assistance. 

Federal housing policies and programs can have significant long-run effects on tribal 

self-determination by influencing the willingness and ability of tribes and tribal members alike to 

exercise choices in the public and private sectors. The existing Section 248 and new Section 184 

programs are examples of Federal programs designed explicitly to increase the range of choices 

available to Indian households by increasing access to private sector lending by those aspiring 

to become homeowners. However, Federal policies and programs may also limit the range of 

choices (and, therefore, the opportunity for exercising self-determination) by tribes and tribal 

members. 

Self-determination involves choosing, but choices are not limited to the use of public 

resources. Indian tribes as well as their individual members make most decisions in the private 

market place. Even in the housing sector, where a tribal area is sometimes depicted as 

something of a socialist society with government housing predominating, most Indian households 

in fact live in private housing, albeit provided in "markets" far different from those in which nonNatives typically partiCipate. 

Basic Alternatives 

The issue of tribal self-determination has both economic and political dimensions. The 

opportunity to choose among alternative possible courses of action the one which maximizes 

one's well-being is essential for economic growth. Evidence is persuasive that those tribes which 

have moved most aggressively toward greater self determination and increased assertion of tribal 

decision making power are those which have been the most successful at achieving economic 

growth. Cornell and Kalt conclude: "To the extent that federal policy reinforces the legal, political, 

and institutional foundations of tribal sovereignty, it increases the chances that tribes can find their 

own pathways out of poverty" (Cornell and Kalt, 1989). 

Federal regulations are also ostensibly intended to promote broad national goals of 

efficiency and equity. Therefore, their elimination does not necessarily guarantee increased social 

well-being. Nor is it certain that the substituted local requirements will produce efficient and 

equitable outcomes. Widely differing policy approaches are at least conceptually possible. 

At one extreme, virtually complete responsibility for Indian housing would reside in the 

hands of the Federal Government. Decisions ranging from how Federal assistance is distributed 

among tribes to how programs are structured to address tribal housing needs would be made by 

Federal agencies. Under one scenario, a single Federal agency would assume principal 

responsibility for administering all Federal housing and housing-related programs designed 
Assessment of American Indian Housing Needs and Programs: Final Report 207 

specifically to meet the needs of Native Americans. An alternative scenario would make Indian 

housing programs off-shoots of programs targeted at the general public, e.g., set-asides for 

CDBG, public housing, and so forth. Under both scenarios, however, Federal rules and 

guidelines would circumscribe local choice, with program design and administration being largely 

Federally determined. 

Such a policy stance would reverse the trend toward decentralization, self governance, 

and self determination which has been continuing apace for several years. Moreover, political, 

ethical, and legal as well as economic factors--all seem to militate against such a policy. 

Yet another scenario within the Federally operated program approach would be to create 

yet more categorical programs. In Chapter 6, it was argued that pushing the bulk of Federal 

assistance funding through just two program options (Rental and Mutual Help) did not respond 

sensitively to the broad range of family needs and resources that exist in most Tribal Areas.69 

It would be possible to create more categorical approaches to address a larger variety of 

circumstances. This, however, would fly in the face of lessons learned about the problems with 

such programs over the past several decades; i.e., each program would probably develop its own 

constituency at the national level and rigidities would emerge that prevent expanding and 

contracting different options even when conditions clearly warrant doing so. Rigidities of this kind 

do not tend to develop where the program mix is determined locally under the transparent form 

of decision making that should accompany true tribal self-determination. 

At the opposite extreme, virtually complete responsibility for housing and hOUSing-related 

activities would reside with tribal governments. Such a policy stance would essentially replicate 

and extend themes of the Self Governance Demonstration under which some 30 tribes currently 

receive as a block grant the total Federal assistance previously provided by BIA and IHS, but 

transferring housing responsibilities to all tribes within a relatively short period of time. 

Two factors in particular militate against such a Federal policy. On the one hand, the 

Federal government typically attempts to achieve a variety of national objectives through its 

assistance programs, including those arising under treaties. Hence, Federally imposed 

restrictions on Federal assistance to tribes (and other local recipients) are generally viewed as 

I 

eorhe need for a broader approach to meeting Indian housing needs than is provided for in eXisting categorical 

housing programs is evident in the Congressional testimony of a tribal leader critiquing existing Federal Indian housing 

policy: "The present program has several other major deficiencies: First, it provides housing for low-income families. 

Yet on reservations, where there is no housing stock at all, we need a comprehensive housing approach that meets 

the needs of all our people. Without decent housing for teachers, our education suffers. Without decent housing for 

our young college-educated tribal members, we cannot get them to return to the reservation to help our tribe. Without 

decent housing we cannot attract the skilled people we need to promote economic development." (Pesata, 1992). 
Assessment of American Indian Housing Needs and Programs: Final Report 208 

necessary to ensure that funded programs at least not frustrate, and hopefully promote, national 

objectives as well as fulfilling treaty obligations. 

Many tribes are perceived as currently having insufficient capacity to assume major 

responsibility for designing and administering their own housing programs. At best, according to 

this view, complete transference of policy and program responsibilities to tribes must remain a 

long-term objective. 

The most feasible Federal policy stance probably lies somewhere between the two 

extremes. One such intermediate approach is to continue the current incremental transfer of 

administrative responsibilities to localities, e.g., HUD's permitting greater local discretion in 

program design and administration such as by replacing rule books with guidelines. The major 

limitation of this approach is that Federal statutes limit what HUD and other administrative 

agencies can do in terms of further deregulating Native American housing programs. 

An alternative intermediary approach would also continue transferring housing program 

responsibilities to localities, but in discrete, substantive steps rather than incrementally. The 

ultimate objective is for localities to assume virtually complete responsibility for the deSign, 

implementation, and operation of housing and housing-related activities, as described above. 

However, the focus here is on the transition from the current situation to the desired; namely, 

effectuation of the procedural, legal, and institutional changes necessary to successfully transfer 

program responsibilities from Federal agencies to tribes. 

The Block Grant Approach 

Disagreement persists about the relative merits of providing Federal assistance to recipient 

governments through categOrical programs versus block grants. One variant of the argument is 

that categorical programs better enable the Federal government to ensure that resources are 

used to accomplish national policy objectives, while block grants better enable recipient 

governmental units to meet local needs. But local governments are not sovereign entities, 

deriving their powers indirectly from the sovereign states in which they are located. 

The principal advantage of providing Federal housing assistance to Tribal Areas in block 

grant form is the increased flexibility permitted in their use. Block grants, depending on how they 

are structured, could also provide a more stable flow of funding which the recipient can plan for, 

thereby contributing to efficiency. Block grants can also be used as a leveraging factor by 

permitting borrowing against future allocations. 

In sum,the most obvious way in which the U.S. Department of Housing and Urban 

Development along with other Federal agencies can move toward according Indian tribes greater 
Assessment of American Indian Housing Needs and Programs: Final Report 209 

discretionary authority is by allocating resources with fewer strings attached, e.g., through greater 

use of block grants. Indeed, a pilot block grant program for housing--the HOME program--already 

exists, the experience with which is proving instructive. 

Federal Indian policy of the 1970s and 1980s was designed to foster increased tribal 

self-determination, especially by permitting tribes to gain greater control over education, health, 

and social welfare programs. As noted in Chapter 7, Congress took an additional step toward 

tribal self-determination in 1988 by authorizing the Interior Department to provide block grants to 

10 tribal governments, bypassing the BIA completely, and permitting tribes to administer programs 

formerly administered by BIA. The Secretary of the Department of Health and Human Services 

was subsequently authorized by Congress to establish a comparable self-governance 

arrangement between tribes and the Office of Indian Health Service?O 

Consideration of combining existing housing programs into a block program for Indian 

tribes raises a number of questions, including: 

• 	 How many, and which, tribes currently have both the willingness and the ability to 

operate housing block grant programs satisfactorily? 

• 	 How many additional tribes either would be induced by the mere presence of a 

block grant program to develop the requisite willingness and ability to operate the 

program satisfactorily or could have those qualities developed through federal 

technical assistance, training, and other support? 

• 	 What form would programs take for those tribes not yet receiving block 

grants--continuation of current categorical programs? Phased consolidation of 

those programs eventually leading to block grants? 

• 	 What would be the nature and extent of accountability required of Indian housing 

block grant recipients? How would accountability be ensured? 

The history of Federal Indian policy reveals several dramatic shifts. When misdirected, 

such shifts have had equally dramatic adverse effects on Indian welfare, effects which can take 

decades to overcome. The implication is that future policy changes ought to proceed with 

caution, implemented deliberately step-by-step. This is the approach of the Self-Governance 

Demonstration project and, by implication, the approach recommended for Federal Indian housing 

assistance as well. 

7O"fhe voluntary self-governing project has been expanded, including 30 tribes by 1992, and extended until 1996. 

See Levitan and Miller, 1993. 
Assessment of American Indian Housing Needs and Programs: Final Report 210 

POLICY DIRECTIONS 

Based on these considerations, in light of the findings and conclusions of Parts I and II 

of this study, we offer the following recommended directions for policy. 

Consolidating Existing Programs into a Block Grant Framework 

HUD's recent streamlining and deregulation ofits Rental and Mutual Help programs seem 

to be important steps in the right direction, but as noted, the statutory frameworks for these 

programs still preclude sufficient flexibility. The block grant approach offered under the HOME 

program is already spurring experimentation in at least a few areas with a potentially more 

efficient, tribally determined array of program options. Although, it would seem most reasonable 

for HUD to consolidate all of its existing funding into a block grant framework that operates 

generally in the same way. Given the diversity of housing problems and opportunities in Tribal 

Areas documented earlier, it should be clear that different strategies will be required in different 

Areas--sometimes varying from each other in subtle ways based on tribal culture and political 

realities as well as economic and physical conditions. The strategy for any individual Area ought 

to be designed by local stakeholders who have both the knowledge of local conditions needed 

to select the best mix of activities and strong locally based incentives to implement them 

effectively. This approach would make Indian housing policy fit better with overall U.S. Indian 

policy in which "self-determination" is now the dominant theme. 

Existing categorical housing programs administered by HUD (the Rental and Mutual Help 

programs), while meeting many housing needs, have also resulted in inefficiencies and inequities. 

As with many Federal programs, tribes frequently apply for, accept, and use available categorical 

funds, even though permissible uses are not areas of greatest local need. likewise, in this 

limiting framework, tribes are motivated to attempt to use available categorical programs to meet 

needs other than for intended uses, thereby producing further inefficiencies. 

Consolidating existing categorical program assistance into block grant-type assistance 

could provide localities the needed increased flexibility.71 However, such a shift in Federal policy 

would have to be implemented cautiously and with considerable forethought. Obstacles to 

implementation of a Federal housing block grant program are both political and institutional. They 

are interrelated as well. Obstacles include conflicting objectives, non-coordinated 

decision-making, and limited institutional capacity within both Federal and tribal governments. 

710ne half of the IHA directors interviewed for this study said they would prefer that Indian housing funds be 

administered as block grants instead of as in existing programs. 
Assessment of American Indian Housing Needs and Programs: Final Report 211 

The pattern of dependency on public housing assistance which characterizes many Tribal 

Areas was presumably not an intended outcome of Federal housing programs. Nor was the 

virtual absence of a private housing sector a deliberate Federal policy outcome. Nonetheless, 

failure on the part of the Federal Government to help establish the institutional setting necessary 

for private markets to develop contributed to the climate of dependency. 

Inappropriate Federal policy, in tum, owes to myriad factors, not the least of which is 

failure to accommodate the wide diversity among indigenous political, social, and economic 

systems in Indian Country.72 Because each tribe's heritage, resources, and capabilities differ 

so greatly one from another, a single policy strategy obviously cannot apply to all tribes, despite 

the several empirically based commonalities documented in this study. For example, an issue 

among some tribes is the extent to which an expanded market economic system is compatible 

with their culture (see discussion in Smith, 1990). 

Housing needs differ substantially among Native American Areas. As cited previously, 

existing Federal programs tend to underserve American Indians and Alaska Natives living in 

counties surrounding Tribal Areas. Despite the fact that some 38 percent of the AlAN population 

living in AlAN counties live in the surrounding counties compared with 62 percent living in the 

Tribal Areas themselves, only about one-fifth of the responding IHA directors said they built any 

Rental or Mutual Help housing in the surrounding counties. Consolidating Federal programs and 

reducing restrictions on their use could permit greater local flexibility to provide needed housing 

assistance to households in a wider range of circumstances and even over broader geographic 

areas. 

Attaching Fewer Federal Strings, but Rigorously Enforcing those that are Attached 

The Rental and Mutual Help programs have suffered from overly complex regulations 

requiring too much HUD oversight. In a new block grant, substantially fewer strings should be 

attached, but it is essential that some requirements remain to 'focus resources on basic national 

objectives. Probably most important in this regard is requiring that the bulk of the funding be 

devoted to addressing the housing problems of low-income households most in need, and that 

some quantitative constraints be imposed to direct local decisions away from spending very large 

amounts on a small number of families while the majority of those in need remain unassisted, or 

in dispersing funds too widely to adequately meet anyone's housing needs. 

Of equal importance, program funding should be contingent on the local preparation of a 

simple, publicly discussed, integrated housing strategy whiph shows how local tribal leaders 

intend to allocate Federal and other resources. The purpose would be to make local leaders 

725ee, for example, Prince, 1994. 
Assessment of American Indian Housing Needs and Programs: Final Report 212 

more clearly accountable to their own members. (HUD would not be expected to approve the 

strategy, just to ensure that one had been prepared.) Finally, with fewer rules to monitor, HUD 

should be able to do a better job of rigorously auditing performance in relation to those 

requirements that remain. Serious penalties should be imposed for failure to comply with those 

requirements, and some form ofbonuses should be considered to provide incentives for improved 

performance. 

The basic strings to be attached. Although the objective is to permit the grant recipient 

maximum flexibility to use grant funds, some Federal requirements are deemed necessary in 

furtherance of U.S. national goals and others to provide an accountability benchmark. 

Consistent with the national priority for assisting low- and moderate-income households, 

grant recipients ought to be required to allocate a disproportionately large share to assisting 

households with incomes below 80 percent of the area's median income. Some type of maximum 

cost per assisted family would also have to be established to encourage wider coverage of the 

population in need. Grant reCipients would also be obliged to administer Federally funded 

programs in compliance with the Indian Civil Rights Act, Americans with Disabilities Act, 

environmental protection requirements, and other Federal laws and executive orders. 

Grant recipients would be initially required to conduct a housing and community 

development needs assessment and to develop a five-year plan for addressing those needs. 

Recipients would be expected to report annually to HUD on program outcomes in terms of 

impacts on previously identified needs. In joint consultation, HUD and the tribe would annually 

assess the previous year's performance by both parties. Where performance is deemed less than 

satisfactory, appropriate remedial action would be developed, agreed to, and implemented. 

In some cases, remedial action may entail HUD's provision of additional technical 

assistance to the grantee. In other cases, improved performance may be best achieved by 

modifying or replacing the local housing delivery programs. The ultimate sanction, to be resorted 

to only after repeated failure of the grantee to meet minimum accountability standards despite 

extensive HUD assistance, is the withholding of future grants. 

Receipt of Federal housing assistance for Native Americans should be made 

contingent upon localities' development of comprehensive housing and community 

development plans. Comprehensive housing and community planning is essential to effective 

use of resources. Hence, by making its assistance contingent upon local planning, the Federal 

Govemment could encourage coordination, cooperation, and integration among local housing 

entities, including between tribal officials and the IHA. (In fact, some officials interviewed for this 

study were indignant that HUD requires planning by non-Indian program participants, but not by 

tribal or IHA participants.) Although the sovereign status of tribes may weaken the Federal 
Assessment of American Indian Housing Needs and Programs: Final Report 213 

Government's authority to require planning by tribes as opposed to non-tribal governments, the 

importance of planning to local capacity development should justify it as a requirement. 

A Phased Transfer, Linked to Capacity Building 

Other researchers of Indian problems and institutions have recently concluded: (1) when 

tribal governments are given a freer hand in implementing their own development, they generally 

perform more effectively than under approaches imposed from the outside; but (2) tribes vary 

dramatically in the effectiveness of their governance structures. Similarly, this study has 

documented substantial diversity in local capacity, and this may be an important constraint on 

policy and program transfer. Granting full authority and responsibility for housing development 

to all tribes and IHAs immediately would be dangerous. Many are capable of handling it all now, 

including entrepreneurial innovations, but the institutional capacity ofa sizeable number is notyet 

adequately developed. 

A phased strategy for implementing the block grant approach seems warranted, in which 

expansions of authority would go hand in hand with expansions in capacity. The initial round of 

strategiC planning, as called for above, might be used to help select the most appropriate path 

for each Area. Strategies would have to include a section on proposed institutional arrangements 

for implementation, and HUD would provide resources for technical assistance to help local 

leaders identify the various programmatiC options open to them and to assist them in preparing 

their plans. 

On the basis of these submissions: (1) a large number of Tribal Areas would be given full 

authority to implement the full block grant approach immediately; (2) others would be given more 

flexibility, but be subject to closer monitoring for a fixed period as they improve their 

implementation capacity; and (3) yet others might have to wait for a time until they establish 

adequate basic capacity to begin to perform under the new arrangements. Federal agencies 

would have to provide an adequate level of resources for technical assistance to tribes and IHAs 

in the second and third categories. Existing providers of technical assistance would target their 

efforts on the neediest tribal administrative systems. 

Housing and community development grants ought to be consolidated and program 

responsibilities transferred only for localities which can demonstrate sufficient capacity 

to assume the increased policy and program responsibilities. Widely perceived as severely 

restricting tribal ability to implement a block grant-type housing program is the limited capacity 

among some tribal governments to implement and manage inQigenous housing programs. Local 

capacity problems, in turn, are commonly attributed to insufficient construction and management 

scale/stability/wherewithal to support adequate staff and facilities or to conflict among tribal and 
Assessment of American Indian Housing Needs and Programs: Final Report 214 

IHA officials and staffs. Answers to three questions seem particularly pertinent in formulating an 

effective Indian housing policy: 

• 	 What is the nature and extent of existing local capacity to formulate housing policy 

and to implement housing programs? 

• 	 What are the principal reasons for existing capacity limitations? 

• 	 Which Federal poliCies and program activities have greatest potential for removing 

or circumventing local capacity limitations? 

Some tribal housing agencies compare favorably with the best run public housing 

authorities (PHAs); they could undoubtedly assume responsibility for virtually all phases of 

housing policy, given sufficient opportunity and resources to do so. Other tribes and IHAs will 

require modest technical assistance and training to enable them to assume increased 

responsibility for local housing policies and programs. Still other agencies will require substantial 

time and, probably, good fortune in addition to any assistance they may receive from the Federal 

Government. 

That current capacity is so limited among many Indian localities ought not be surprising, 

given the limited resources available. But it is potential rather than current capacity on which we 

ought to focus, and here there is reason for optimism. Although it is frequently difficult to 

disentangle cause from effect, resource availability and program capacity seem to occur together 

disproportionately in Indian Country. Where resources have become available--whether as a 

result of deliberate tribal, state or Federal action, because of private sector development, or 

simply fortuitously--Iocal housing program capacity has tended to respond commensurately. For 

example, tribes in Minnesota have made effective use of that state's financial housing aSSistance, 

and some tribes are making effective use of gaming revenues to meet housing and urban 

development needs. 

The implication is that local policy and program capacity is most likely to develop in 

response to localities being given greater flexibility in the use of Federal resources. The rub will 

be in determining where and when the potential for local capacity development is sufficiently high 

to transfer increased housing responsibilities to the tribe. Transferal of housing policy and 

program responsibilities to localities would require both their certification as having sufficient 

capacity to accept those responsibilities and the tribes' willingness to accept the additional 

responsibilities. 

Requisite to devising strategies for aSSisting localities to assume increased policy and 

program roles are reliable indicators to identify localities' current capacity strengths and 
Assessment of American Indian Housing Needs and Programs: Final Report 215 

weaknesses. Reliable indicators are also necessary for determining when local agencies have 

developed sufficient capacity for assuming additional policy and program responsibilities. 

ACA ratings, audit findings, and assessments by HUD regional office personnel are among 

available indicators which could be used to assess IHA capacity. For example, analysis 

conducted in Chapter 5 revealed statistically significant relationships between ACA ratings and 

IHA director turnover. Other suitable measures could be added as appropriate. 

Capacity to assume increased responsibilities for housing policy formulation and 

program operation varies considerably from one Native American Area to another: 

Therefore, local capacity building should occur in tandem with phased transfer of policy 

and program responsibilities. It is obviously desirable that shifting from the current system of 

categorical programs to a block grant-type program facilitate a concomitant expansion of local 

capacity. At a minimum, the shift ought not adversely affect existing local capacity. Development 

of local policy and program capacity would be better fostered under a step-by-step, phased 

implementation of a block grant-type program than by a once-and-for-a" program replacement. 

Phased implementation of a block-grant program would facilitate the integration of tribal policy 

goals with IHA program expertise. 

Community Development Block Grants are currently being made directly to Indian tribes, 

rather than to IHAs. One approach that might warrant further study, would be to establish two 

separate block grants initially. One would go directly to the tribes and consolidate the current 

CDBG, HOME, and other Federal housing and community development program assistance to 

tribes. The other would go to the IHAs, consolidating the current Rental and Mutual Help 

programs, along with other minor forms of Federal categorical housing assistance to IHAs. The 

objective would be to maintain viable housing roles for both the tribal housing office and the IHA 

while giving increased flexibility to both and simultaneously facilitating their cooperation. 

Eventually, the separate block grants to tribes and IHAs would be combined, but with 

accompanying incentives to ensure that institutional capacity is not lost. The total dollar amounts 

of Federal assistance received by individual IHAs and tribes would be pre-determined solely on 

the basis of the distribution formula. Therefore, grant consolidation would affect only the form, 

and not the amount, of assistance each area receives. 

Husbanding Existing Institutional Capacity-Roles for the IHAs 

In many Tribal Areas, sound working relationships h~ve been established between tribes 

and their IHAs. It is likely that under the new approach, IHAs would naturally work with the tribes 

in preparing the strategy and the IHAs would be assigned as the lead implementing agency, 

taking on both more challenging and exciting responsibilities as they branch out from the more 
Assessment of American Indian Housing Needs and Programs: Final Report 216 

limited task of administering current HUD programs and become more entrepreneurial, for 

example, in seeking private sector financing. In some Areas, however, tribal governments might 

be tempted to reject the IHA role too easily. While this study has noted that IHA performance is 

uneven, the IHAs have generally developed a level of professional competence not easily 

replaced in the tribal structure. Ultimately, tribal governments should be able to select the 

institutional arrangements that suit them best, but constraints should be placed on their ability to 

eliminate existing performance capacity and professionalism unreasonably. 

IHA institutional capacity, expertise, and professionalism ought to be safeguarded, 

enhanced, and integrated with other entities to implement comprehensive tribal housing 

policy. Many Tribal Areas face insufficient scale of production and management, inadequate 

financial support, and limited staff expertise--all are thought to constrain local housing activities. 

And all are frequently interrelated. It is argued, for example, that lack of financial resources 

prevents hiring of sufficient personnel to undertake housing activities on a large scale, and small 

scale, in turn, limits ability to hire staff. 

IHAs are frequently perceived by others as well as by themselves as being de facto 

agents of HUD. This perception owes in part to IHAs being originally established by tribes as a 

requirement for participation in HUD programs. The perception also persists in part because of 

IHAs being funded almost exclusively to administer HUD programs. Among the manifestations 

of this perception is that IHA housing units are typically referred to as "HUD housing." 

Restrictions on use of existing categorical programs limit the capacity of IHAs and tribal 

housiny offices to seek out creative and effective means for addressing local housing needs. 

Under current statutes, HUD funds may not be used by a housing authority to administer a 

non-HUD program, even if such a program would address local problems more effectively than 

would the HUD program. 

Whether or not IHAs' past dedication to HUD programs was an efficient use of resources 

is moot. The question is whether or not so constraining IHAs activities in the future is the 

preferred alternative. Two key research findings tend to suggest that it may not be: First, 

substantial and increasing tribal housing needs, e.g., for homeownership, do not appear to be 

adequately addressed by existing Federal programs, including HUD programs administered by 

IHAs. Second, IHAs appear to constitute the most viable vehicle for expanding housing 

opportunities in much of Indian country. 

Lack of information and technical expertise, as well as lack of financial resources, appear 

to represent notable constraints upon some I HAs' and tribal housing offices' ability to offer a 

broader range of housing programs than they do. In some cases, this reflects the absence of 

significant demand for information and expertise regarding additional housing programs and 
Assessment of American Indian Housing Needs and Programs: Final Report 217 

activities. In other cases, local housing entities are precluded from developing the necessary 

information and expertise because they are either unwilling or unable to do so, despite demand 

for housing services above and beyond those already available, because of inadequate funding, 

or because of inertia. 

Widely perceived as the greatest constraint on the capacity of IHAs to meet the housing 

needs of Native Americans effectively is a fractious political relationship between IHAs and tribal 

officials. Our research did in fact reveal some situations in which local capacity to develop and 

operate housing programs appeared to be severely hamstrung by political infighting. As noted 

in Chapter 5, however, we also found many situations in which local housing entities functioned 

effectively within the local political structure. Indeed, political constraints on IHAs and tribal 

housing offices cover the whole gamut, generally mirroring the relationships between local officials 

and housing offices in non-Indian areas.73 

Tribal leaders and IHA executive directors in each of the 36 survey sites were asked to 

assess the extent of involvement by the tribal council in various IHA activities. Although tribal 

leaders perceived slightly less involvement by the tribal council than did IHA directors, both 

categories of respondents saw similar patterns--greatest involvement in project site selection and 

in overall planning, and least involvement in tenant selection/assignment and selection of 

architects/contractors. Forty-two percent of the tribal leaders and 48 percent of I HA executive 

directors viewed tribal councils as either somewhat or very involved in the IHA's overall planning. 

Fifty-four percent of tribal leaders and 64 percent of IHA directors said tribal councils were 

somewhat or very involved in project site selection. 

Although the appropriate tribal council involvement in IHA activities undoubtedly varies 

from locality to locality, from activity to activity, and from time to time, the majority of tribal leaders 

appear to believe ample coordination and involvement currently exist. Approximately two-thirds 

of the tribal leaders surveyed answered "yes" to the question: "Do you feel that you meet with 

IHA staff frequently enough, both formally and informally, for the purpose of coordinating 

activities?" 

Potential Key Role for IHAs. Restrictions on IHA operations seem to owe as much to 

administrative inertia as to perceived legal and financial obstacles. No obvious legal restrictions 

prevent IHAs from operating as developers of non-government housing, for example, and earning 

developer's fees as a source of revenue. Indeed, IHAs have powers to "lease, manage, and 

sublease land, borrow and lend money, pledge assets as security, buy and sell personal property, 

731t seems worthy of note that only 42 percent of the interviewers who completed a narrative summary from their 

site visits for this study deemed the IHA-tribal relationship worthy of comment, and of those who did, nearly three-fourths 

remarked that the relationship was good. 
Assessment of American Indian Housing Needs and Programs: Final Report 218 

buy land, cooperate with other housing authorities or tribes to finance housing, and issue 

obligations" (NAIHC, 1993). 

Rather, the reason IHAs have restricted their activities primarily to administration of HUD's 

Rental and Mutual Help programs appears to be traceable to their origins. Although created by 

tribal ordinances, IHAs have often been seen (by others and themselves) essentially as creatures 

of HUD. The basic terms of the originating ordinances were written by HUD, and any funds 

allocated to IHAs may only be used to support low-income HUD programs. 

IHAs mirror Public Housing Authorities (PHAs) in many ways, including miSSion, 

administrative structure, and program implementation. IHA staffs look primarily to serving the 

needs of a restricted group of households (those having incomes below 80 percent of area 

median) in a restricted geographic area (trust lands).74 Regulations for IHA-administered HUD 

programs historically were similar to those administered by PHAs, namely, permitting only limited 

adaptability to local needs and conditions. In recent years, HUD has significantly reduced the 

regulatory requirements on IHAs in administering Indian housing programs. 

Given their heavy workloads and limited staff resources, IHAs are understandably reluctant 

to assume responsibilities beyond the administration of HUD's low-income programs, even when 

they would seem to be well-positioned to provide important additional housing services. For 

example, administrative assistance has been sorely needed to increase the use of FmHA lending 

activities in Tribal Areas, and IHAs would seem the entities best qualified to assist in packaging 

FmHA loan applications. IHAs generally have not undertaken this activity, frequently saying they 

have insufficient resources to do so and lamenting that HUD-funded staff cannot be used to 

administer non-HUD programs, including other Federal housing programs. 

Some changes in IHA focus could be achieved by statutory change, e.g., authorizing HUD 

housing program funds to be allocated in block form, thereby enabling IHAs to undertake a wider 

range of housing activities. Others would require increased resource support, whether in larger 

administrative budgets or in increased technical assistance and training, to increase IHA 

administrative capacity sufficiently to undertake a wider scope of Indian housing programs. 

Other changes in IHA activities in support of Indian housing will clearly require a change 

in the prevailing (PHA) ethos. In many instances, the IHA's narrow traditional focus on the needs 

of low-income Indian households living on trust lands stems from the tribe's perceptions and 

expectations of the IHA when viewed as an Indian PHA. 

741HAs located in Oklahoma and Alaska typically define their service areas more broadly; and sixteen IHAs which 

serve reservations, primarily in the Northwest, have defined their service areas to encompass sizeable off-reservation 

areas as well as the reservation itself. 
Assessment of American Indian Housing Needs and Programs: Final Report 219 

Decentralizing and simplifying HUD programs through regulatory reform is giving IHAs 

greater autonomy. But to further broaden the focus of IHAs and to change their image from 

agents of generic HUD low-income housing programs to tribal agencies dedicated to enhanced 

housing opportunities for all Indian families, will require statutory change. One way to broaden 

IHAs' focus and image would be by blending HUD housing program dollars with funding from 

other sources--both public and private--to support IHA activities. 

To be sure, HUD's recent deregulatory initiatives have gone a long way toward effecting 

change in IHA missions. As one ONAP official expressed it: "Everything currently left in the 

regulations is what is in the statutes. Lots of stuff remains in the regulations because lots of stuff 

remains in the statutes." However, as an example of the added flexibility permitted by HUD's 

streamlining of administrative requirements, IHAs can now choose any method of procurement 

instead of being required to use one of four prescribed methods. Indeed, HUD's attempts to 

decentralize administration of its Indian housing programs parallels the Self Governance 

Demonstration noted earlier being conducted by BIA and IHS. Not surprisingly, so do the 

problems encountered. 

Whereas many tribes are ready, willing, and able to assume increased responsibility for 

administering their own programs, others are not. Critically needed are far more extensive 

programs of training, technical assistance, and information dissemination than currently exist. 

Such programs need to be targeted to tribes, IHAs, lenders, Indian households, and HUD staff. 

IHA activities ought to promote the integration of housing activities with pertinent 

social services in Tribal Areas. It has long been recognized that housing conditions are closely 

related with the physical and emotional health of families (Glazer, 1980). More recently, housing 

conditions have been linked with family wealth creation, economic mobility, economic security, 

and overall economic self-sufficiency. Indeed, poor housing conditions have been shown to 

thwart economic achievement, by contributing to: "...Iack of security, and the general troubles 

associated with the spatial concentration of poverty, including social isolation, greater risks of 

crime victimization and physical danger, absence of economically mobile role models and support 

for community institutions, and lack of visible opportunities.,,75 

That insufficient attention has been paid to the relationship between housing and social 

services is attested to in the responses by both IHA directors and tribal housing staff personnel 

interviewed for this study. Over 80 percent of the former and some 63 percent of the latter 

responded "yes" to the question: "Is there a need for existing [housing) programs to be more 

closely coordinated with other social services, such as education and health care?" 

75See, for example, Schlay, 1993. 
Assessment of American Indian Housing Needs and Programs: Final Report 220 

This study has documented a perceived increase in the concentration of social problems 

in IHA Rental projects. Because of this concentration and the role the IHA has in housing 

management, it is in an unusually important institutional position to "connect" with the lives of its 

tenants. There is a growing literature on the ability of housing managers to facilitate the delivery 

of adequate social services in their housing complexes. This literature should be a basis for 

technical assistance and training as well. 

Husbanding Existing Institutional Capacity--Roles for HUD and Other Federal Agencies 

Under the new approach, the Federal role changes substantially, moving away from direct 

program implementation and toward: (1) facilitating local performance capacity (through, technical 

assistance, demonstrations, and information sharing functions); and (2) more careful monitoring 

and sanctioning of results. In fact, with its recent deregulation initiatives, HUD is already moving 

in these directions. This study has evidenced no major coordination problems among Federal 

agencies in administering housing assistance in Indian country (certainly, in part, because the 

non-HUD programs are comparatively so small). We judge that significant performance problems 

might arise, however, if there was any major shift of operating responsibilities away from HUD. 

HUD has built considerable capacity to understand and address AlAN housing problems and 

needs, and it might be difficult to rebuild this capacity elsewhere. 

Capacity-building roles for the Federal Government include technical assistance, 

staff training, and information dissemination. Staff training, technical assistance, and 

information dissemination are areas in which the Federal government could fruitfully contribute 

to capacity-building among local housing institutions within Indian country. Recent and on-going 

training and technical assistance programs funded by the Federal government have yielded 

significant benefits. However, a far greater level of effort is needed to equip IHAs to assume 

increased policy and program responsibilities, particularly those who have evidenced limited 

managerial capacity to date. 

HUD could play an especially useful role by encouraging tribal communities to explore 

creative ways of overcoming perceived problems with existing housing programs, and then 

disseminating information about successes among other communities. For example, among the 

creative ways a few IHAs have attempted to overcome the inefficiencies and inequities inherent 

in the fixed 30 percent of income requirement of the Low Rent program is to base rent payments 

on a sliding scale.76 

76The Mississippi Choctaw IHA's experiment with a sliding rent scale represents the sort of program innovation 

which both promotes local capacity building and tests a conceptual construct. For an excellent rationale for use of 

a sliding rent scale, see Stone, 1993. Also see discussion of "affordability" measures in Chapter 3. 
Assessment of American Indian Housing Needs and Programs: Final Report 221 

Increased coordination is needed among Federal agencies responsible for Indian 

housing and housing-related programs to ensure maximum efficiency in the furtherance 

ofIndian Policy. The ebb and flow of Federal funding has made it difficult for Federal agencies, 

IHAs, and tribes alike to make long-range plans. So, too, have the Federal Government's 

slowness to respond to change, and the division of housing programs among Federal agencies 

(Suzuki, 1991). 

Federal agencies specialize in provision of housing and housing-related services to Native 

Americans, thereby presumably yielding production efficiencies. For example, after HUD became 

involved in producing new Indian housing, BIA concentrated more on maintaining and upgrading 

existing units. While no insurmountable coordination problems appear to exist, divided 

responsibilities among Federal agencies has sometimes resulted in overlapping functions and 

conflicting policies (U. S. Senate, 1989). As indicated before, differences of opinion exist 

regarding the seriousness of such coordination problems. 

Activities by regulatory agencies, Federal departments, GSEs, and others are sometimes 

conflicting as well as complementary, and often produce differential effects within individual Tribal 

Areas. Federally-wielded sticks--e.g., enforcement of CRA provisions and anti-discrimination 

laws--appear to be increasing Native Americans' access to housing services in some areas. 

Federally-provided carrots--e.g., HUD's guaranteed loan program and Fannie Mae underwriting 

guidelines--appear to have the potential for increasing Native Americans' access to housing 

services in other areas. Efforts by Federal agencies to bridge the gap in understanding between 

Native American communities and private sector housing providers--e.g., Federally-sponsored 

informational workshops and sensitivity training programs--appear to be producing salutary effects 

in still other areas. 

Given limited Federal resources and differing local housing sector obstacles, it is 

imperative that activities at the national level be clearly coordinated and tailored to the specific 

needs of localities. For example, one locality might benefit most from Federal assistance in 

improving foreclosure and eviction processes and from Federally-sponsored informational 

workshops; another locality might benefit most from intensified CRA enforcement and FHLB 

targeting of Affordable Housing Program subsidies. 

On the one hand, the intergovernmental relationship between sovereigns--Le., between 

the U.S. Federal Government and recognized Indian tribes--would appear to dictate minimal 

restrictions on recipient governments. On the other hand, the Federal Government attempts to 

advance various national objectives, including income redistribution, by specifying how funds are 

to be used by program recipients. Conflicting interests of grantor and grantees must be 

reconciled; but disagreement often centers as much on means as on ends. 
Assessment of American Indian Housing Needs and Programs: Final Report 222 

One fifth of the tribal housing staff interviewed for this study said that HUD, SIA, and IHS 

have been "not successful" in coordinating activities in general, whereas two-thirds said those 

agencies have been "somewhat successful," and only 12 percent said the agencies have been 

"very successful." The distribution of responses was similar regarding how well HUD, SIA, and 

IHS have worked together efficiently. One of the elite interviewees characterized the relationship 

among those three agencies as "lacking communication and coordination, and severely 

fragmented in authority." She attributed lack of coordination in part to "every agency having its 

own cycle." 

Consolidating programs within a single agency would presumably facilitate integration of 

housing, economic development, health, and other Federal programs into a more coherent overall 

Indian policy, but could lose the advantages of having Federal housing assistance provided by 

a specialized housing agency (HUD), health care assistance provided by an agency specializing 

in health care (IHS), and a third agency (SIA) specializing in land use. 

As block grant-type programs are phased in, the advantages of divided Federal 

responsibilities will probably diminish. However, because the phase-in period is likely to be 

lengthy, the advantages of continued division of Federal responsibilities for Indian programs 

among HUD, IHS, and SIA would seem substantial. Moreover, many of the benefits of 

consolidation can be achieved through increased interagency cooperation which is continuing 

apace. 

An Equitable Approach to Allocating Funds 

Systems that give Federal officials substantial discretion in allocating government funds 

seem often to produce inequities. This is what has occurred in the way HUO has allocated Indian 

housing program resources in the past. In the proposed block grant approach, funds should be 

allocated to Tribal Areas solely by formula in proportion to their comparative need, based on 

objective indicators. Recent studies have shown that formula approaches like this, based on 

Census data, have worked well in the national COBG program. The Census is the only reliable 

national data source for these purposes, and analysis in this study suggests that it could be used 

to produce sensible allocations for most Tribal Areas. In those cases where Census area 

definitions may not reasonably reflect tribal settlement patterns (most often the smaller Tribal 

Areas), special surveys (with tight controls) could be conducted to replace Census figures. 

The system for providing Federal housing program assistance to Tribal Areas 

should be reassessed to provide greater certainty and flexibility, and to better reflect cost 

differences among localities. Perhaps the most important way in which local program capacity 

can be expanded is through Federal funding. Although attention typically centers on the total 
Assessment of American Indian Housing Needs and Programs: Final Report 223 

dollar amounts dispersed to Native Americans under Federal housing assistance programs, the 

manner in which funds are distributed warrants greater scrutiny. 

That is not to say that the Federal Government's system of financial support for Native 

American housing programs has not been faulted in the past. Three facets of HUD's funding of 

Indian housing programs have received criticism: (1) uncertainty of funding which raises costs and 

heightens uncertainty in local programs; (2) limited local flexibility provided by Federal funding 

guidelines which prevents the efficient use of funds; and (3) inadequate allowance for fixed costs 

in the funding formula which discriminates against smaller jurisdictions as well as limiting local 

program flexibility. 

Proposal of a new, detailed funding system is not only beyond the scope of this report, 

but would be presumptuous as well. As with any agreement among sovereigns, specifics must 

be negotiated to the mutual satisfaction of all interested parties. However, based upon findings 

from our research, key features of a more optimal funding system are discernible, regardless of 

whether Federal housing assistance to Native Americans takes the form of modifying the existing 

system of categorical programs or moving toward a block grant-type program. In fact, transition 

from the current system of categorical programs to a block grant-type program would seem to be 

best effected through a phased, step-by-step implementation of a new funding allocation strategy. 

We suggest two principles for reform. First, the current system of funding categorical 

programs could be usefully replaced with a formula-based block grant-type program; such a 

program would provide localities a reasonably stable funding source, minimize intertribal 

competition, and afford localities maximum flexibility to match programs to housing needs. 

Second, a funding allocation formula could be devised which would better accommodate cost 

differences among localities, including the mix of fixed and variable costs, than do current funding 

systems. 

The Self-Government Demonstration (SGD) would seem to constitute a prototype block 

grant-type program specific to Native Americans; valuable lessons from that experience may be 

in what to avoid in implementing a system of consolidated block grants. In particular, the funding 

formula ought to be determined so that tribes neither gain nor lose Federal funding relative to 

other tribes solely by virtue of receiving their funds as a block grant rather than as categorical 

assistance. 

Consolidating previous categorical BIA and IHS funds into a single block grant would have 

institutionalized the existing de facto allocation formula. Each participating tribe was to receive 

as a block grant the same total Federal funds previously received under various categorical grant 

programs and including pro-rata shares of BIA's and IHS' costs of administering those programs. 

Basing each tribe's consolidated grant on previous Federal funding was not as straightforward 
Assessment of American Indian Housing Needs and Programs: Final Report 224 

as anticipated, however. Intense negotiations between representatives of the Federal 

Govemment and the participating tribes resulted in tribes receiving substantially more (in some 

cases by factors of four or five) than they would have received under the categorical programs. 

Despite a supplementary budget allocation, the SGD tribes apparently gained at the expense of 

non-participating tribes, despite the SGD program's provision that non-participating tribes be held 

harmless. 

Basing housing block grants on historical pattems of Federal assistance has the ostensible 

advantage of minimizing controversy, but clearly failed to do so under the SGD program. 

Moreover, as argued above, there is no a priori reason for believing historical pattems were 

necessarily optimal, and even less reason to expect them to be optimal in the future. 

Expanding Indian Access to Housing Assistance Outside of Tribal Areas 

While not as severe as those in Tribal Areas, the housing problems of AlAN households 

living in other areas (metropolitan and nonmetropolitan) are more serious than those of the 

general population. Administrative realism, however, argues against setting up new special 

program initiatives to address their problems. Rather, emphasis should be on expanding their 

access to assistance within the framework ofFederal housing programs that already exist in those 

areas. This suggests the need for HUD to establish special outreach efforts for Indians in all of 

its programs. 

The housing needs of Indians living in urban areas seem to center on three major issues: 

• 	 the need for better service provision through Federally-assisted housing programs; 

• 	 the need for decent and affordable rental units that would accommodate extended 

families; and 

• 	 the need for homeownership opportunities. 

Access to Federal Programs could be improved through better outreach and 

education provided by Indian community centers. Our survey data indicate that Indians are 

often reluctant to ask for assistance from govemment agencies. Indian community centers could 

act as liaisons between PHAs and the Indian community to disseminate information about 

assisted-housing opportunities, process applications, conduct orientation sessions, and assist in 

finding and maintaining assisted housing. In addition, certain regulations, such as occupancy 

rules, could be made more flexible to accommodate the experience of families coming from Indian 

country. 

Access to decent and affordable larger rental units could be improved through more 

flexible Indian block grants. Census and survey data suggest that many Indians prefer to live 
Assessment of American Indian Housing Needs and Programs: Final Report 225 

in extended family situations, but that they are unable to find affordable and decent housing units 

to accommodate them. Block grant funds (under the Community Development Block Grant or 

HOME programs) could be extended to urban Indian CDCs to develop and manage housing units 

suitable for the Indian community. These funds could be channeled through state or local 

governments to established Indian housing organizations or could be used to improve the 

capacity of existing Indian organizations to develop housing expertise. 

Access to homeownership opportunities could be improved with homebuying 

assistance to eligible Indian households. Our interviews suggest that many Indian households 

are not participating in homebuying opportunities, despite the fact that they are financially able. 

Some, like other minorities, do not have adequate savings for a downpayment or acceptable 

credit history. Others lack information regarding the responsibilities of homeownership. Still 

others are reluctant to approach traditional financial institutions, such as banks and mortgage 

companies. 

Homebuying assistance could be provided through Indian community centers and could 

include government or privately funded grants or low-interest loans for down payments and 

closing costs. In addition, community centers could also provide homebuying counseling to assist 

potential homeowners with the homebuying process. However, it would seem extremely 

important that traditional private financial institutions playa key role in providing homeownership 

opportunities for American Indians and Alaska Natives, as they do for other Americans, in order 

to prevent the further "ghettoizing" of the housing experience of urban Indians. 

CONCLUDING COMMENTS 

Based upon assessments of housing needs facing American Indians and Alaska Natives 

and of Federal programs for addressing those needs, it has been concluded that both efficiency 

and equity would be increased substantially by permitting greater local flexibility in the use of 

Federal program assistance. Greater local flexibility, in turn, implies transferring decision-making 

responsibilities to tribes and their housing authorities, thereby also contributing to the goals of 

self-determination and self-governance. As one of those interviewed for this study expressed it: 

"The time is right." 

Combining HUD's existing categorical programs for aSSisting Indian housing into a block 

grant-type program could increase local flexibility, provide a more stable funding stream, and 

enable increased leverage of housing funds from other sources--all contributing to increased 

efficiency as well as increased equity. Recent experiences with the Self Governance 

Demonstration, the Indian CDBG and HOME programs, and HUD's deregulation of its Rental and 
Assessment of American Indian Housing Needs and Programs: Final Report 226 

Mutual Help programs provide good reason for believing a housing block grant program could be 

implemented successfully. 

However, transferring decision-making responsibilities and program flexibility to tribes and 

IHAs by implementing a block grant-type approach to Federal housing assistance will succeed 

in many, and probably most, cases only if the transfer occurs incrementally and deliberatively. 

The transfer must recognize different IHA-tribal configurations and proceed hand-in-hand with 

development of local institutional capacity. The implied needs, among others, are for increased 

technical assistance, training, planning, and accountability. 

Clearly, the task is an urgent one. It is addressing what this study has documented as 

the most severe housing deficiencies remaining in America. 

REFERENCES 

Comell, Stephen and Joseph P. Kalt. 1990. "Pathways from Poverty: Economic 

Development and Institution-Building on American Indian Reservations." American Indian 

Culture and Research Journal, Vol. 14. 

Cornell, Stephen and Joseph P. Kalt. 1991. "Where's the Glue? Institutional Bases of American 

Indian Economic Development." Project Report Series, Harvard Project on American 

Indian Economic Development. Cambridge: John F. Kennedy School, Harvard University. 

Glazer, Nathan. 1980. "The Effects of Poor Housing." in Housing Urban America, eds. John 

Pynoos, Robert Schafer and Chester Hartman. New York: Aldine Publishing Co. 

Housing Assistance Council. 1993. "Demonstration of 'Building Indian Housing in Underserved 

Areas': An Evaluation and Recommendations," HAC Report, Washington, D.C.: Housing 

Assistance Council, December. 

Housing Assistance Council. 1988. Indian Housing in the U.S.: A History. Washington, D.C.: 

The Housing Assistance Council. February. 

Levitan, Sar A. and Elizabeth I. Miller. 1993. The Equivocal Prospects for Indian Reservations. 

Washington, D.C.: The George Washington University Center for Social Issues. May. 
Assessment of American Indian Housing Needs and Programs: Final Report 227 

National American Indian Housing Council. 1993. "Feasibility Study: A Predevelopment Loan 

Fund on Native American Trust Lands," Washington, D.C.: National American Indian 

Housing Council, April. 

Pesata, Levi. 1992. "Testimony on the Indian Housing Demonstration Act." Washington, D.C.: 

U.S. House of Representatives, Committee on Interior and Insular Affairs, May 29. 

Prince, Steve J: 1994. "Moving Beyond Pretext: Indigenous Economic Systems and Appropriate 

Economic Policy." A paper prepared for the Western Economics Association Conference. 

Vancouver, June 30. 

Schlay, Anne B. 1993. "Family Self-Sufficiency and Housing." Housing Policy Debate, Vol. 4. 

Smith, Tim. 1990. "Financing Economic and Business Development on Indian Reservations: 

Fulfilling the Promise of Self- Determination." Northwest Report. April. pp. 20-34. 

Stone, Michael E. 1993. Shelter Poverty: New Ideas on Housing Affordability. Philadelphia: 

Temple University Press. 

Suzuki, Peter T. 1991. "Housing on the Nebraska Indian Reservations: Federal Policies and 

Practices." Habitat International. Vol. 15. 

U.S. Department of Interior. 	 1995. "Self-Governance Demonstration Project, Department of the 

Interior Audit Report No. 95-1-699," Washington, D.C. March. 

U.S. Senate. 	 Special Committee on Investigations. 1989. A New Federalism for American 

Indians. Washington, D.C. 
Chapter 9 

EXPANDING THE MORTGAGE LENDING 

IN INDIAN AREAS 

As discussed in Chapter 8, there is reason to expect that restructuring the way in which 

Federal housing assistance is provided to American Indians and Alaska Natives can substantially 

enhance its ability to address the serious and extensive needs documented in earlier chapters 

of this report. It is also clear, however, that Federally assisted housing cannot and should not 

be expected to meet al/ housing needs in Tribal Areas, regardless of the program delivery 

mechanism used. This chapter focuses on the importance of and potential for augmenting 

Federal assistance with private housing market activity within Tribal Areas, with special attention 

to the need to develop the housing finance sector. 

The chapter starts with a brief discussion of the economic benefits of private housing 

development in general. It then reviews the major barriers that have prevented an inflow of 

private financing for housing in Indian country to date (amplified by the results of a small sample 

survey of lenders located near Tribal Areas). Next, a number of recent initiatives to promote 

expanded mortgage lending to AlAN households are examined and crude estimates are offered 

on the size of the potential market. Finally, implications for policy are discussed. 

THE ECONOMIC BENEFITS OF PRIVATELY FINANCED HOUSING 

Without adequate incomes, Native American families will be unable to have their housing 

needs met within the private housing market, and left to compete for the limited supply of publicly 

assisted housing.77 Not surprisingly, low and unstable incomes were rated as "major" barriers 

77Not surprisingly, low and unstable incomes were rated as "major" barriers to homeownership by approximately 

85 percent of both IHA directors and tribal staff surveyed for this study. 
Assessment of American Indian Housing Needs and Programs: Final Report 229 

to homeownership by approximately 85 percent of both IHA directors and tribal staff surveyed for 

this study. But this study has also shown that there are many moderate and higher income 

households living in Tribal Areas who should be able to afford homes without subsidies, but have 

been unable to achieve their housing objectives. If private housing delivery systems could 

broaden housing opportunities in this regard, it should benefit not only those households, but the 

broader Tribal Area economy as well. 

Accumulated income-earning assets are both the manifestation of past economic 

accumulation and a source of future economic well-being. However, a paucity of income-earning 

wealth--particularly household wealth--characterizes nearly all of Indian country. Although some 

areas have significant stocks of natural resources, many factors--economic, cultural, political, and 

regulatory, among others--frequently limit the economic viability of those resources as a source 

of economic development generally, and as a source of effective private housing demand in 

particular. 

Privately owned housing is a likely source of economic growth for Indian and non-Indian 

economies alike: First, equity in houses is a major source of wealth for most U.S. households, 

second only to human capital. Over one-half of all owner-occupied units in the U.S. are mortgage 

free, thereby providing a significant source of savings, and thus investment capital, for 

households. In most economies, housing investment comprises from one-tenth to one-half of 

gross fixed capital formation, and from three to eight percent of Gross Domestic Product (GOP). 

Moreover, housing investment tends to increase as a share of GOP as economies develop.78 

Second, housing investment historically has leveraged substantial additional investment. 

One estimate is that each $1 of demand for real estate products ultimately results in $3.70 of total 

production for the U.S. economy (National Association of Realtors, 1988). Again, there is no 

apparent reason for believing housing investment would contribute less to economic development 

in Tribal Areas than elsewhere. 

Third, housing investment may displace the production of relatively few tradeable goods 

and services. Few Indian economies are currently making maximum use of available resources, 

typically exhibiting substantial unemployment and underemployment of their meager resources, 

most notably labor. Hence, ample opportunity appears to exist for expansion of the private 

housing sector in Tribal Areas without having to divert scarce resources from alternative uses. 

Fourth, employment of idle resources in housing production could not only directly 

increase the supply of private housing but increase the potential future supply as well. if useful 

78See, for example, Annez and Wheaton, 1984; Burns and Grebler, 1986; and Mayo, Malpezzi, and Gross, 1986. 
Assessment of American Indian Housing Needs and Programs: Final Report 230 

construction skills are acquired by the newly employed workers or other productive activities 

stimulated. 

In sum, investment in housing represents a major method by which most U.S. households 

save, by building equity in their homes. Accumulated home equity, in turn, provides a source for 

amassing further wealth by financing education, health care, or mObility, as well as providing a 

source for increased housing market demand. All this is to say that housing construction 

represents a vital form of capital investment both individually and collectively--in many cases, 

yielding a high potential economic rate of return. 

BARRIERS TO PRIVATE MORTGAGE LENDING IN INDIAN AREAS 

Identifying the Barriers 

The availability of financing is normally the most basic requirement needed for the 

expansion of homebuilding in any area. In the surveys conducted for this study, respondents 

identified the lack of private housing finance as one of the primary factors preventing the 

expansion of homeownership in Tribal Areas. What are the barriers that have prevented the U.S. 

housing finance industry from serving Indian country in the past? The literature in this field, 

typically identifies at least four: legal obstacles, the lack of institutional infrastructure, the lack of 

information, and discrimination (see, for example, NAIHe, 1993). 

Legal Obstacles. The overarching legal obstacle perceived by mortgage lenders is 

usually the difficulty in recovering the outstanding loan amount in case of default. The lender may 

specify guidelines for repayment as a condition of the loan, but the lender's ability to enforce 

repayment requirements ultimately depends on the lender's ability to use the courts. The trust 

status of tribal land--its inalienability--prevents its use for loan collateral by individuals. The wide 

diversity in tribes' legal institutions and procedures frequently presents a significant source of 

uncertainty to conventional lenders in encumbrancing structures as well. Such uncertainty poses 

a potentially sizeable obstacle to lenders' willingness to make mortgage loans for home purchases 

on trust lands. 

Decrying the obstacle to mortgage lending on trust lands represented by the inability of 

lenders to collateralize the land is something of a mantra among lenders, regulators, and others. 

In practice, the obstacle may be less imposing than popularly thought. Witness, for example, the 

lengthy experience of many conventional mortgage lenders for homes purchased on lease-hold 

land in Baltimore and other historic east coast cities, on public utility-owned land, and in foreign 

countries. Witness, too, the several areas within Indian country in which active mortgage lending 
Assessment of American Indian Housing Needs and Programs: Final Report 231 

is occurring, including for homes purchased on trust lands. Witness, finally, the widespread 

attempts throughout Indian country to develop tribal ordinances, judicial institutions, and legal 

processes which will facilitate securing of on-reservation housing transactions (as will be 

discussed below). 

Lack of Institutional Infrastructure. Institutional intermediaries must be in place, not 

only to overcome legal and practical obstacles but to provide the myriad services necessary for 

any economic transaction to occur, i.e., to bridge the gap between demanders and suppliers of 

goods and services. The need for such institutions is particularly acute when significant obstacles 

exist on either the demand or the supply side of the market, or on both sides as seems to 

characterize the housing sector in Tribal Areas. 

Such institutions are typically either scarce or ineffectual in much of Indian country. In onsite surveys, some 83 percent of tribal staff and 70 percent of IHA directors said that the 

"unavailability of mortgage lenders operating on or near reservations" is a "major" barrier to 

owning homes. 

Lack of Information and Attitudinal Barriers. Lack of information is clearly a serious 

obstacle to the operation of an effective private housing market in Tribal Areas. Incomplete and 

erroneous information characterizes both demand and supply sides of virtually all components 

of housing markets in Tribal Areas. 

Negotiating the home purchase process can be a daunting experience for anyone, but 

tends to be doubly so for Native Americans. Among non-Indians, advice and information are 

typically available to a prospective home buyer from friends, family, and co-workers who have 

gone through the home-buying and home-financing processes. Within the Indian community, 

such information sources are less likely to be available. 

Underlying the paucity of information and interaction within the private housing sector in 

Tribal Areas is a legacy of suspicion, misperception, and distrust. On the demand side, many 

Native Americans are suspicious and distrustful regarding any contractual agreements with 

non-Native American entities, public or private. Also, well-defined and enforced property rights, 

a pre-condition for a private market, are frequently absent in AlAN areas so many Indians have 

little experience with them. On the supply side, cultural differences and prejudicial attitudes 

frequently characterize builders, lenders, and other providers of housing and hOUSing-related 

goods and services in Tribal Areas. 

In some cases, there are deeper underlying attitudinal barriers. As discussed in Chapter 

7, for example, it is argued by some that weak demand for private housing in Tribal Areas is in 
Assessment of American Indian Housing Needs and Programs: Final Report 232 

part a legacy of Federal policies which have produced a mindset among some Native Americans 

that housing ought to be freely provided by government.79 

Discrimination. No nationwide estimates are currently available regarding the nature and 

extent of discrimination against Native Americans in the sale, rental, and financing of housing. 

Nonetheless, there is evidence to indicate that Native Americans frequently encounter 

discriminatory treatment in their attempts to obtain housing in the private sector. In the late 

1980s, the Montana Human Rights Commission (1989) undertook to measure the nature and 

extent of racial discrimination against Indians in three Montana communities. The project results 

indicated that discrimination occurred in 57 percent of the tests conducted, a substantially higher 

incidence of discrimination than experienced by other minorities in testing performed in other parts 

of the country.so 

IHA executive directors surveyed in this study were asked: "To what extent is racial or 

ethnic discrimination a barrier to obtaining housing?" Some 42 percent said discrimination is 

"very much a barrier" and another 32 percent said "somewhat of a barrier." Tribal housing office 

staff were asked a similar question: "Is racial or ethnic discrimination a significant barrier to 

obtaining housing financing for members of your tribe?" Half of the respondents said "yes." In 

sum, discrimination is at least perceived by many Native Americans as constituting a significant 

barrier to obtaining suitable housing. 

Fair housing laws are arguably enforced less vigorously in AlAN Areas than elsewhere. 

One reason is that local private fair housing groups playa key role in fair housing enforcement, 

but such groups are disproportionately located in urban areas which do not encompass Tribal 

Areas. 

In summary, obstacles to development of Federal Indian housing policy are many and 

daunting. It is important to note, however, that the constraints appear to differ in degree rather 

than in kind from the sorts of obstacles which typically constrain non-Indian housing markets. 

Moreover, innovative programs and recent creative policy initiatives (to be discussed below) are 

sufficiently numerous in Indian country to indicate that policy constraints are not insurmountable. 

791n fact, nearly one-fourth of the Tribal leaders responding to the survey conducted for this study said that ·many" 

tribal members feel entitled to free housing from the Federal Government. Another 40 percent said that a 'ew· 

members feel entitled to free housing. 

aorhe fair housing "tests" consisted of observed differential treatment accorded Indian and non-Indian housing 

seekers by housing providers. An individual test consisted of successive visits to the same rental agent by an Indian 

and a non-Indian matched as closely as possible in terms of economic wherewithal, housing needs, and other pertinent 

household characteristics. Systematic differences in treatment could then be attributable solely to discrimination. 
Assessment of American Indian Housing Needs and Programs: Final Report 233 

The Lender Survey (Confirming and Understanding the Barriers) 

Because of the importance of expanded mortgage lending in Tribal Areas, a small scale 

lender survey was conducted as part of this study. Its primary purposes were to assess the 

extent of current lending activity and learn more about both the opportunities and the barriers 

likely to affect the growth of such activity in the future. 

Survey Sample and Methodology. A private mortgage lending institution was randomly 

selected in each of the 36 AlAN areas in which in-person interviews were previously conducted 

with IHA directors, tribal leaders, and tribal housing office personnel. For each of those areas, 

the sampling frame was the most populous county encompassing the sampled AlAN Area. 

The population of lending institutions for each of the 36 identified counties were lists of 

branch SAl F-insured institutions and FDIC-insured institutions. The two lists of lending institutions 

were combined for each of the 36 counties, and numbered consecutively. Two branch institutions 

were selected from the combined list (one to be used as a replacement if the primary institution 

was unable to be surveyed), using a random numbers table. One or more private lending 

institutions which make mortgage loans as a matter of course were identified for each of the 36 

counties. The number of institutions listed for the 36 counties ranged from 1 to 510 with a mean 

of 112. 

Telephone numbers for each of the selected lending institutions were obtained from 

directory assistance. When the institutions were contacted by telephone, the interviewer was 

instructed to ask for the residential mortgage loan officer. If pOSSible, the interview was 

conducted at that time. However, in nearly all cases, additional calls were necessary to set up 

a mutually acceptable interview time. The interviews were conducted from mid-December 1994, 

until late February 1995. 

Although the survey was to be completed by a branch loan officer of the selected lending 

institution, the interviewer was instructed to seek out another knowledgeable official if either the 

loan officer deferred to someone else or was unable to answer the questions. Preference was 

given to CRA officers for replacement interviews. Consequently, over two-thirds of the completed 

interviews were conducted with loan officers, and nearly one-fourth with CRA officers.81 

81Three replacement institutions were necessary. One bank selected in the primary sample apparently no longer 

exists. No telephone listing could be obtained for another institution. A third selected bank was mistakenly listed as 

being located in the survey county. Despite one lender's expressed willingness to participate in the survey, an interview 

was never able to be completed. Therefore, telephone interview forms were completed for only 35 of the 36 sample 

areas. 
Assessment of American Indian Housing Needs and Programs: Final Report 234 

The lender survey was designed to obtain two types of information. First, we attempted 

to determine the current capacity, experience, and potential for the existing system of private 

lending institutions to meet the mortgage lending needs of Indian homebuyers. Of primary 

interest were the perceptions and practices of loan officers at the sampled branch bank. 

Second, we attempted to obtain information about other private lending institutions 

operating within the sampled area. In addition to asking about lending activities by competing 

institutions, the surveyed individuals were asked whether independent mortgage lending 

institutions were operating within their service areas and, if so, how many. 

Volume of Lending. All of the sampled financial institutions reported making mortgage 

loans during the two-year period preceding the survey. The median number of mortgage loans 

made during that period was 55. All but one institution reported that a full range of financial 

services in addition to mortgage loans was made available to Native Americans. Some 69 

percent (24 of 35) said they had made mortgage loans to Indians during the previous two-year 

period; 11 percent said they had made no such loans; and 20 percent said they did not know 

whether any mortgage loans had been made to Indian borrowers. 

For those few respondents who were willing to estimate the number of mortgage loans 

made to Indians (12 of 35), the median number of mortgage loans made on trust land was 1.0 

and the median number made off trust land was 1.5. Among those reporting having made 

mortgage loans to Indians, some four-fifths said that loans had been made for home purchases; 

slightly over three-fifths made loans for refinancing; slightly under three-fifths made home 

improvement loans; one-third made home equity loans; and about one-sixth made small business 

loans. 

Forty six percent of the surveyed financial institutions reported that they keep all mortgage 

loans in portfolio. Seventeen percent said they sell all their mortgages, and 37 percent do 

both--retaining some in portfolio and selling some. Lenders appear to retain mortgages in 

portfolio for a variety of reasons, including long-standing practice. However, most appeared to 

believe that mortgage loans to Indians could not be sold because they were thought to be 

nonconforming, most frequently because the mortgage loans were for homes located on trust 

land. 

Whether mortgages were sold or kept in portfolio appeared to be unrelated to the lender's 

awareness of either of HUD's 248 or 184 programs or of Fannie Mae or Freddie Mac mortgage 

purchase programs targeted at Native American homebuyers. When subdivided by whether they 

retained all mortgages in portfolio, sold all mortgages, or both retained and sold mortgages, 

roughly the same proportion (one-third) of all groups were aware of HUD's 248 or 184 programs. 
Assessment of American Indian Housing Needs and Programs: Final Report 235 

Other Lenders and Barriers. The lender survey was designed primarily to obtain 

information regarding the perspectives and experiences of representative private lending 

institutions in Tribal Areas. However, the survey also attempted to gauge the overall nature and 

extent of mortgage lending activities in each of the sample areas. Respondents estimated a 

mean of 3.4 and a median of 3.0 lenders operating in their service areas. Over three-fifths of the 

surveyed lenders said they were aware of other lenders (including other branches of their own 

banks) which had made mortgage loans to Native Americans within the previous two-year period. 

Respondents were asked what they thought had prevented their lending institutions from 

making more mortgage loans to Native Americans during the previous two years than they had 

made. The relative frequencies are provided in Table 9.1; more than one reason was frequently 

volunteered: 

Program Awareness andSecondary Market Influence. Among the most striking results 

of the lender survey is how few of the respondents were aware of Federal initiatives to reduce 

mortgage lending risk, to decrease lending difficulty, or to increase profitability of mortgage 

lending to Native Americans, particularly on trust lands. For example, only about one in seven 

respondents was familiar with HUD's 248 mortgage insurance program, and only one claimed to 

have used it. The proportion knowing about HUD's new 184 program was only Slightly larger, 23 

percent, although five of the six respondents who reported knowing about the program said they 

were likely to use it. 

Table 9.1 
 

BARRIERS THAT LIMIT LENDING IN TRIBAL AREAS: 
 

RELATIVE FREQUENCY (Percentages) 
 

Land problems 

Can't use reservation land as collateral 54 

Difficulty foreclosing on trust land 31 

Limited demand for mortgages: 

Lack of applicants 46 

Lack of Information 23 

Indians cIon't want to ownlborrow 11 

Failure of borrowers to qualify: 

Don't meet income requirements 20 

Don't meet cIownpayment requirements 14 

Don't meet credit requirements 11 

Other obstacles 60 

Source: Lender survey 
Assessment of American Indian Housing Needs and Programs: Final Report 236 

Eighteen percent of the survey respondents said they were "aware of any programs or 

activities (in addition to the 248 and 184 programs) by Fannie Mae, banking regulators, HUD, or 

other government agencies which have been intended to make it easier or more profitable to 

make mortgage loans to Native American homebuyers." 

Respondents were asked: "How important are the underwriting requirements established 

by Fannie Mae and Freddie Mac in determining whether you can make home loans available to 

Native Americans (Alaska villages/Oklahoma trust lands)?" Of those responding, 38 percent said 

"Very important," 24 percent said "Somewhat important," 24 percent said "Not very important," 

and 14 percent said "Not at all important." 

As might be expected, awareness of HUD's mortgage insurance programs and other 

government programs and activities in support of mortgage lending to Native Americans differed 

somewhat between loan officers and CRA officers. Whereas only one-eighth of the loan officers 

knew about HUD's 184 program, over one half (4 of 7) of the surveyed CRA officers knew about 

the program. Somewhat surprisingly, however, whereas over one fifth (5 of 24) of the loan 

officers were aware of other government programs and activities in support of Native American 

housing, none of the seven CRA officers were aware of such programs or activities. 

Conclusions. In sum, the lender survey indicates that in virtually all Tribal Areas, one or 

more private lending institutions originate some mortgages for Indian homebuyers, although the 

volumes remain extremely small. The reasons for low lending volume include lack of knowledge 

and initiative by tribes and their members, as well as continued caution on the part of lenders. 

Separate interviews, however, indicate that major lenders and secondary market institutions at 

the national level are now exhibiting considerable interest in finding ways to serve AlAN 

households in all locations more effectively. Recent initiatives along these lines are discussed 

in the section below. 

RECENT INITIATIVES TO STIMULA TE MORTGAGE LENDING 

Public Support for Private Lending for Indian Housing 

As explained in Chapter 6, several public programs currently work to provide support for 

mortgage lending in Indian country, some of them explicitly designed to reduce the risk or to 

increase the profitability of private lending to Native American home buyers. In particular, FHA's 

Section 248 mortgage insurance program and ONAP's Section 184 loan guarantee program 

provide implicit public subsidies to Indian borrowers while reducing the default risk to private 

lenders. 
Assessment of American Indian Housing Needs and Programs: Final Report 237 

The Farmers Home Administration's recently intensified outreach efforts in Indian country 

are being complemented with innovative demonstration projects such as the Housing Assistance 

Council's Building Indian Housing in Underserved Areas Project. Regionally, several Federal 

Home Loan Banks are also making special efforts to increase member financial institutions' use 

of the Affordable Housing Program to subsidize home purchases on trust lands. 

Some state housing authorities are making special efforts to increase the flow of financial 

capital into Indian country; programs operated by the Minnesota Housing Finance Agency (MHFA) 

and the New Mexico Finance Authority (NMFA) are especially noteworthy. Under MHFA's Indian 

Housing Program, some 1,100 subsidized mortgage loans have been made to Indian homebuyers 

in Minnesota over the last two decades. NMFA's approach has been primarily to assist tribes 

with reducing legal and institutional barriers to mortgage lending on trust lands. 

Recent Regulatory Initiatives 

We are currently witnessing a flutter of activity throughout the country to open up private 

financial markets to prospective Indian borrowers. Financial regulatory agencies within the past 

year have undertaken several initiatives designed to increase mortgage lending by private 

financial institutions in Tribal Areas. Illustrative initiatives include: 

(1) The Board of Governors of the Federal Reserve System denied a merger 

application by First Interstate Bank System of Montana because one of the holding company's 

subsidiary banks had unreasonably excluded the Northern Cheyenne Indian Reservation from its 

delineated service area; this was the first time the Federal Reserve Board had denied a merger 

request based exclusively on Community Reinvestment Act compliance issues (Profit Wise 

Profiles, 1994). 

(2) The Office of the Comptroller of the Currency's (OCC) Western District Office is 

attempting to increase private lending in Indian country by financial institutions it regulates through 

a three-pronged initiative: (a) "Lead, cajole, push" lenders to get lenders to make additional home 

mortgage loans to Indian borrowers "within the boundaries of safety and soundness." (b) Help 

get tribes to reach out to lending institutions, including learning about CRA requirements and 

overcoming "cultural aversion" to dealing with financial institutions. (c) Bring lenders and tribes 

together in areas where it is easiest "to make inroads," e.g., the Navajo Nation because of its 

R~sidential Master Lease Act.82 

82The Master Area Land Lease Act designates specific tracts of land on the Navajo Reservation as Master Land 

Lease Areas, each having a separate entity having oversight of leasing activities for that area. Area land can be used 

as collateral for either commercial or housing development, but the Navajo has the right of first refusal if property is 

defaulted upon. The Navajo's Deed of Trust Act eliminates some of the obstacles to foreclosure when the lender is 

the government. (Telephone interview with Julia Brown, Community Affairs/Compliance Officer, Office of the Comptroller 
Assessment of American Indian Housing Needs and Programs: Final Report 238 

(3) The Minneapolis, Kansas City, and San Francisco Federal Reserve Banks are 

sponsoring a series of seminars targeted at lenders, tribes, and bank examiners. Presenters at 

the seminars on "Credit and Finance in Indian Country" discuss legal and cultural issues that 

"reflect the Fed's concern that banks may be avoiding making loans in Indian country" 

(Community Investment Reporter, 1994). 

(4) The U.S. Department of Justice (DOJ) is actively attempting to reduce discrimination 

in U.S. lending markets, including discrimination against Indians. For example, DOJ recently 

successfully settled a suit against Blackpipe State Bank in Martin, South Dakota. DOJ charged 

that the bank refused to make secured loans when the collateral was located on a reservation 

and that the bank placed credit requirements on Indians which were not required of non-Indians. 

The bank entered into a consent decree in which it agreed to implement a broad range of 

reforms, including affirmative action in several areas. 

Private Housing Finance Initiatives 

National and regional mortgage market participants are also actively attempting to facilitate 

an increased flow of credit into the home financing markets in Indian country. Following are three 

examples: (a) The Federal Home Loan Bank of Seattle recently published Bringing Private 

Resources to Native Lands: A guide to Housing Finance for Native Americans, Alaska Natives 

and Native Hawaiians. (b) The Federal National Mortgage Association (Fannie Mae) is currently 

completing an underwriting guide for loans made on Indian reservations which lenders can sell 

to Fannie Mae. (c) Attorneys of the Federal Home Loan Mortgage Corporation (FHLMC) are at 

an "exploratory stage" in studying the legal process involving foreclosure on trust lands. 

Both Fannie Mae and Freddie Mac have actively explored with HUD or with BIA methods 

to increase their activity in Tribal Areas, including the development of model legal agreements for 

lending on tribally owned lands held in trust by the Federal government. Mortgage lending 

projects sponsored by those entities are actively underway in several tribal areas, and Fannie 

Mae has established a "Native American Housing Specialist" position. 

Among the recent initiatives undertaken by conventional lending institutions to increase 

lending in Indian country are participation in information workshops and seminars dealing with 

tribal laws and cultural issues. Norwest Mortgage Company created a Fair Lending Department 

within the last year. Norwest officials surveyed for this study did not see "any insurmountable 

problems" in extending conventional mortgage opportunities to Native Americans. They perceived 

of the Currency, Western District, August 3, 1994}. 
Assessment of American Indian Housing Needs and Programs: Final Report 239 

the greatest need as "education of potential homeowners as well as of housing authorities" 

regarding mortgage financing.83 

The more successful homeownership finance programs in Indian country tend to be those 

in which mortgage finance is modestly subsidized by the tribe, the state, the Federal government, 

the lender, or some combination thereof. We offer selected examples: 

Firstar Bank in Minocqua, Wisconsin, has made seven mortgage loans (three refinances) 

to :ndians to purchase homes on the Lac du Flambeau reservation over the last few years. The 

tribe contributes the land, and the well and septic system are provided by the Indian Health 

Service. The loans are insured under FHA's Section 248 program, and sold on the secondary 

mortgage market. 

Associated Bank in Green Bay, Wisconsin, has made some 70 to 75 mortgage loans to 

Indians for home purchases on the Oneida reservation since 1987. The tribe provides up to 20 

percent of the purchase price (to a maximum of $15,000, including downpayment and closing 

costs). The bank lends the remaining 80 percent collateralized by a conventional mortgage which 

is not insured under Section 248 and which is held in portfolio. 

Three tribal housing corporations in Minnesota have been making housing-related loans 

on 11 reservations for nearly 20 years under the aforementioned Minnesota Housing Finance 

Authority's Tribal Indian Housing Program which blends state mortgage revenue bond money with 

State appropriations. Loan subsidies include assistance with down payments, closing costs, and 

monthly payments. The 1,100 loans made to date have included mortgage financing for new 

construction, and financing for purchase and/or rehabilitation of existing homes. 

In sum, the climate seems right for progress to be made in expanding private mortgage 

lending to American Indians and Alaska Natives. 

THE MARKET FOR PRIVATE FINANCING 

That many tribal areas are currently underserved by the private sector is evident in the low 

percent of households with a mortgage and the high percent of higher-income households living 

in substandard or overcrowded housing. At issue is the 'extent of this underservice; i.e., the 

unmet demand. 

83Patrick Guillion, Director, and Diana DiPronio, Manager, Fair Lending Department, Norwest Corporation, Des 

Moines, Iowa, Telephone Interview, (August 8, 1994). 
Assessment of American Indian Housing Needs and Programs: Final Report 240 

This section develops data and an approach for roughly estimating the level of demand 

for private financing in tribal areas. To develop this model, we use 1990 U.S. Census data, MIRS 

data, household survey data, and the lender survey to identify: (a) the in-place market; (b) the 

market caused by mobility of Native American households; and (c) the current composition of the 

mortgage market in tribal areas. The section concludes with a summation of the private market 

and a discussion of what private sector products are likely to have the greatest demand among 

Native Americans. 

The geographies of interest when considering the need for private financing in Indian 

country are somewhat different than those we have explored in the ear1ier sections of the report. 

The geographies explored here reflect: (a) different land rules and histories--reservation/trust land, 

New Mexico Pueblos, California Rancherias, Alaska Native Villages, T JSAs, and TDSAs84; and 

(b) past and current initiatives to promote private lending--the past lending programs in Minnesota 

and Wisconsin and the recently initiated Residential Master Lease Act on the Navajo reservation. 

Current Conditions 

Current Mortgages. In general, while most Native Americans living in tribal areas are 

owners very few of them have mortgages. Of those that reported having mortgages on 1990 

Census forms, it is likely that many were citing their payments under HUD's Mutual Help program 

as a "mortgage". Furthermore, it is unclear how many Native Americans may have had 

mortgages on land that only recently has been designated as Trust Land. This pattern is in stark 

contrast to Native American owner households outside of tribal areas, most of whom have private 

mortgages. 

Table 9.2 makes use of 1990 U.S. Census data to show the total number of Native 

American owner households reporting having a mortgage. From that total, we have subtracted 

the total number of IHA homeownership units built before 1990 that are currently in management 

(Old Mutual Help, New Mutual Help, and Turnkey) to estimate the number of AlAN households 

that currently have a private mortgage. 

On Reservations and Trust Lands, the Minnesota and Wisconsin subarea stands out with 

27 percent of the AlAN owner households currently having a private mortgage. While this is 

significantly less than among owner Native American households living off tribal land (their rate 

84 See Chapter 2 for more details about the different land rules 
Assessment of American Indian Housing Needs and Programs: Final Report 241 

Table 9.2 
 

CURRENT MORTGAGE LENDING TO NATIVE AMERICANS 
 

Approx. AlAN 

'Total AlAN TotailHA HHswl Percent 

HHsw/Mtgs. OWner Units Pvt. Mtgs. OWner HHs wI 

(000) (000) (000) Pvt. Mtgs. 

ReservatlonlTrust Lands 

Navajo Nation 2.5 1.9 0.6 2.1 

Pueblos 1.5 2.2 0.0 0.0 

California Tribal Areas 1.2 1.5 0.0 0.0 

MNlWI Tribal Areas 2.1 0.9 1.2 27.2 

Other ResITrust Land 15.2 13.7 1.5 3.8 

Other Tribal Areas 

Alaska Tribal Areas 3.0 3.9 0.0 0.0 

TJSA (Oklahoma) 32.9 9.1 23.8 41.3 

TOSA 6.7 0.0 6.7 49.7 

Near Tribal Areas 

Re~nderofAJaska 4.0 0.0 4.0 64.4 

Other Surrounding Co. 60.4 0.0 60.4 68.0 

Remainder Of U.S. 

Re~ning Counties 141.4 0.0 141.4 71.5 

is 68 percent in surrounding counties and 71.5 percent in the remaining counties)85, it strongly 

suggests that the Minnesota Housing Finance Authority's Tribal Indian Housing Program and 

efforts of the banks in Wisconsin (described ear1ier) have had a noticeable impact, while little 

private mortgage activity has occurred elsewhere on Reservation and Trust Lands. 

In fact, outside of Minnesota and Wisconsin, only a small number of other Indian areas 

appear to have a noticeable number of mortgages other than those through the IHA ownership 

programs - notably the Flathead Reservation in Montana, the Qualla Cherokee Reservation in 

North Carolina, the Nez Perce in Idaho, the Colville Reservation in Washington (each apparently 

have more than 50 mortgages). 

85 Even with an active private market for homeownership, it is unlikely these numbers would get close to the 

numbers for the off-Tribal area Native Americans because so many of the owners in Indian areas are very poor and 

will not qualify for private financing. Federal programs such as Mutual Help and low-income rental programs (such as 

the Low Income Housing Tax Credit) are necessary to address that other need. 
Assessment of American Indian Housing Needs and Programs: Final Report 242 

Although the land rules for Alaska Native Villages are significantly different than for 

Reservations and Trust Lands, they too have virtually no private mortgage market activity. T JSAs 

and TDSAs, however, do indeed appear to have a significant percent of owner households with 

private mortgages: 41 and 50 percent respectively. As noted earlier in this report, both types of 

areas are less dominated by trust land and generally exhibit more of the characteristics typical 

in private housing markets. 

Outside of tribal areas, Native Americans owners are actually more likely to have a private 

mortgage than non-Indians. This clearly shows that many Native Americans outside of tribal 

actively use private mortgage financing. The higher rates of mortgage financing for Native 

Americans may be explained by their relative youth compared to the non-AlAN population, 

suggesting that they have not had mortgages long enough to pay them off. 

Current Lending Activity-HMDA data analysis. Another method to analyze lending 

activity to Native Americans is to use 1993 Home Mortgage Disclosure Act (HMDA) data on 

Native Americans seeking and receiving loans for home purchase. Although the geographic 

coverage of HMDA data is limited essentially to metropolitan areas, representing counties with 

only one-half of all Native American households, some clear lending patterns seem worthy of 

note. 

Regression analysis was used to investigate the relationships between the percent of 

Native American households in a county receiving a home purchase loan in 1993 (dependent 

variable) and a limited set of explanatory variables--standard market factors, factors unique to 

Native Americans, and mortgage industry factors. (Richardson, 1995). 

Variables measuring standard market factors behaved the same way in the estimated 

regression model for Native Americans as for other racial groups, e.g., the proportion of Native 

American households receiving loans was positively (and significantly) related to their average 

income and homeownership rate and to the level of mortgage activity in the county. 

Of greater interest are the factors unique to Native Americans: the higher the proportion 

of Native Americans in a county's population the /owerthe percent of Native Americans receiving 

a home purchase loan in 1993. (A dummy variable included for Oklahoma and Alaska had 

positive coefficient, whereas the dummy variable for counties containing Indian areas had a 

negative coefficient.) Not surprisingly, higher rates of Native Americans are denied mortgages 

in the counties where relatively few Native Americans receive mortgages. (See Annex 9A). 

A potential explanation for the lower number of loans in some parts of Indian country could 

lie in the inability of banks to sell the loans they have made to Native Americans in those areas 

on the secondary market. The percent of home purchase loans made to Native Americans in 
Assessment of American Indian Housing Needs and Programs: Final Report 243 

1993 that were not sold on the secondary market has a negative impact on the rate of loans 

made to Native Americans. 

Housing Problems among Higher Income Native Americans. The result of a 

inoperative housing market in many tribal areas appears partly responsible for the high rates of 

overcrowding and physical deficiency of housing in many Tribal Areas. While a good deal of the 

housing need can be attributed to past Federal practices, low incomes associated with limited 

educations and" few job opportunities, and remote locations, there is an indication that some of 

the problem is due to a lack of private financing in Indian country. 

While the decennial census reports that the homeownership rate for Native Americans 

living in Tribal Areas is 69 percent, many of these homes were built without the aid of any 

financing for the family. As a result, the physical condition of this housing is often substandard. 

The lack of private financing makes this is true for higher income as well as lower income Native 

Americans living in many Tribal Areas. 

Table 9.3 shows that an extremely high proportion of Native Americans living on 

reservation or trust lands earning 80 percent or more of median income are experiencing major 

problems with overcrowding and plumbing problems. Among non-Indians above 80 percent of 

median income, the rates of overcrowding and/or physical deficiencies are much lower. Clearly 

the problems are highest among the higher income Native Americans living in the Navajo Nation-­

62.3 percent for owners and 43.8 percent for renters. Of considerable interest is that Minnesota 

and Wisconsin (with progressive private mortgage investments in Tribal Areas) have rates of 

problems noticeable below those on other Reservations and Trust Lands. 

For those living in Alaska Tribal Areas the problems are similar to those of Navajo Nation. 

For families eaming 80 percent or more of median income, half of all renters (50.1 percent) and 

46 percent of all owners are experiencing major housing problems. 

These problems for relatively higher income AlAN families on Reservation and Trust Land 

in Alaska Native Villages stand in marked contrast to AlAN households living in Oklahoma and 

areas near to, but not on, Tribal lands. In these areas, where private financing is more readily 

available, only 9 to 15 percent of renters and 3 to 5 percent of owners are overcrowded or have 

facility deficiencies. 

This sharp contrast in housing conditions for owners with higher incomes living or 

reservation and in Alaskan Villages, compared to land for which private financing is possible, 

appears linked to the lack of availability of credit opportunities for financing the repair, expansion, 

replacement, or rebuilding of their homes. To test this, regression analysis was used to compare 

the percent of higher income AlAN households with housing problems with the percent of 
Assessment of American Indian Housing Needs and Programs: Final Report 244 

Table 9.3 
 

HOUSING PROBLEMS AMONG NATIVE AMERICANS HOUSEHOLDS 
 

ABOVE 80 PERCENT OF MEDIAN INCOME 
 

AlAN HH above 80% of median Income 

Overcrowding and/or 

physical deficiencies 

Total HHs Homeowner 

(000) Rate Owners Renters 

Reservationlrrust Lands 

Navajo Nation 8.9 69.6 62.3 43.8 

Pueblos 2.8 87.5 23.8 22.0 

California Tribal Areas 1.3 74.5 13.4 19.8 

MNIWI Tribal Areas 2.0 83.8 10.5 13.4 

Other ResfTrust Land 19.6 75.4 17.6 19.1 

Other Tribal Areas 

Alaska Tribal Areas 4.8 71.8 44.3 49.4 

T JSA (Oklahoma) 42.2 80.6 3.7 9.0 

TOSA 9.0 79.7 8.0 12.3 

Near Tribal Areas 

Remainder of Alaska 7.0 63.4 10.0 15.3 

Other Surrouncling Co. 89.8 67.3 5.8 11.6 

Remainder Of U.S. 

Remaining Counties 206.3 67.2 3.6 8.6 

Total 393.7 69.6 7.2 11.3 

households with a private mortgage.S6 Controlling for the fraction of households with low 

incomes and the fraction of households that are elderly, the percent of Native Americans who are 

owners with a mortgage is very negatively (and significantly) related to the percent of higher 

income Native American households with overcrowding and/or physical deficiencies. This 

suggests that the development of private financing in Tribal Areas could help address some of 

the overcrowding and facility needs among higher income Native Americans living in those areas. 

86 For this analysis, the mutual help units were not subtracted out of the total owners with mortgages. 
Assessment of American Indian Housing Needs and Programs: Final Report 245 

The Potential Market 

The size of the potential market for private lending in Tribal Areas can be thought of as 

having two components: 

(1) The in-place market--Native American households now living in Tribal Areas who 

would probably use private financing if were available; and 

(2) The mobility market--Native American households outside of Tribal Areas who 

would move to the Tribal Area if private financing was available. 

The In-Place Market. A model for estimating the in-place market hinges on: (1) higher 

income Native American owner households with overcrowding and physical deficiency problems; 

(2) higher income renter households; and (3) mobility within tribal areas. 

Table 9.4 uses the number of AlAN renters above 80 percent of median income along with 

the number of higher income AlAN owners with housing problems in Tribal Areas to provide a low 

and higher estimate of the in-place market. The high estimate is simply the total number of 

higher income renters plus the total number of AlAN owners with facility or overcrowding needs. 

The low-end estimate assumes the rental rate and level of problems can only be brought down 

as low as they are in Oklahoma (where 9.4 percent of households above 80 percent of median 

income are renters and 3.7 percent of higher income owners have overcrowding or physical 

deficiency problems). Thus to calculate the low-end rate: 

Total AlAN HH in a Tribal Area >80% of Median * .094 

= Expected number of higher income AlAN HH likely to remain renters with a private market 

Current number of AlAN HH in a Tribal Area >80% of Median 

= Expected Market for homeownership from current AlAN renters 

and 

Total AlAN Owners in a Tribal Area >80% of Median * .037 

= 	 Expected number of higher income AlAN Owner HH likely to still have overcrowding or 

facility problems with a private market 

Current number of AlAN owner HH in a Tribal Area >80% of Median Income with 

overcrowding or facility problems 

= 	 Expected Market for homeownership from current AlAN owners with overcrowding or 

facility problems 
Assessment of American Indian Housing Needs and Programs: Final Report 246 

Table 9.4 

IN-PLACE ACCRUED DEMAND AMONG NATIVE AMERICAN HOUSEHOLDS ABOVE 

80 PERCENT OF MEDIAN INCOME FOR PRIVATE LENDING 

AlAN HH above 80% of median Income 

OWners wI 

Overcrowd. 

and/or Estimated 

physical In-Place Market 

TotalHHs Renters problems Low High 

(000) (000) (000) (000) (000) 

ReservatlonlTrust Lands 

Navajo Nation 8.9 2.7 3.9 4.6 6.6 

Pueblos 2.8 0.4 0.6 0.5 1.0 

California Tribal Areas 1.3 0.3 0.1 0.1 0.5 

MNIWI Tribal Areas 2.0 0.3 0.2 0.1 0.5 

Other Res/Trust Land 19.6 4.8 2.6 3.1 7.4 

Other Tribal Areas 

Alaska Tribal Areas 4.8 1.3 1.5 1.8 2.9 

TJSA (Oklahoma) 42.2 8.2 1.3 0.0 9.4 

TOSA 9.0 1.8 0.6 0.4 2.4 

Total 91.6 19.9 10.7 10.7 30.6 

Thus: 

Expected Market for homeownership from current AlAN renters 

+ Expected Market for homeownership from current AlAN owners with overcrowding or 

facility problems 

= Total low-end expected market for homeownership financing products in AlAN tribal areas 

After calculating these figures, it is possible to roughly estimate that the total in-place 

market for private financing for AlAN homeownership in Tribal Areas ranges from a low of 10,700 

to a high of 30,600. 

It is recognized that higher income households who did not report facilities or overcrowding 

may also wish to seek mortgage financing for the building or rehabilitation of their current units 

and might use such improvements as a means to offer off-reservation relatives housing within the 

reservation. Also, there are no data available from either census or HMDA that can assist in 

estimating the percentage of Native American renters or owners who could qualify for specific 
Assessment of American Indian Housing Needs and Programs: Final Report 247 

terms and conditions of financing. There is, for example, no information available on the credit 

worthiness of Native American households earning over 80 percent of median income. It is also 

clear that the estimate of need for single-family financing does not mean that tribal leaders might 

not also seek financing for multifamily housing to complement their existing stock for families or 

the elderly. Tribes with income derived from local resources or gaming could also help underwrite 

the financing of homeownership housing for their members, even when their incomes are not 

sufficient to appear as over the local median. There is no means to estimate the size of such 

additions to the'potential for residential mortgage credit. 

The Mobility Market. The potential for attracting non-reservation based families back 

onto tribal land with private mortgage financing would entail making a number of assumptions and 

estimates which extend beyond the capacity of existing research and data systems. The 

residential mobility of tribal members would be affected by the customary predictors of residential 

mobility including job access, educational opportunities for children, distance and means of 

transportation available, credit worthiness, and the types of properties and mortgage terms 

available. Households making such moves from renter tenure status living in a nearby 

metropOlitan area could be different than those already living in owner occupied housing at a 

considerable distance from the Tribal Area. The potential migration of Native American elders 

onto their reservations to occupy housing for which financing was available is another subject that 

warrants additional research. 

The Potential for Expanding AlAN Homeownership Outside of Tribal Areas 

It also appears that there are notable prospects for expanding AlAN homeownership (and 

therefore, mortgage lending) outside of Tribal Areas. We have not attempted a similar estimate 

of the potential, but the conclusion is supported by the fact that in all such areas, at moderateand higher-income levels (above 80 percent of the local median), AlAN homeownership rates are 

well below those for non-Indians. 

• 	 In counties surrounding Tribal Areas, only 67 percent of AlAN households at with 

incomes above 80 percent of median are owners (compared to 77 percent for nonIndians in the same income groups); in 1990, there were 31,300 AlAN renter 

households in these counties with incomes above 80 percent of the local median. 

• 	 In metropOlitan areas elsewhere, the moderate- and higher-income ownership rate 

is 66 percent for AlAN households vs. 75 percent for non-Indians; 54,900 AlAN 

renters in these income groups lived in such ,areas in 1990. 

• 	 In other non-metropolitan areas, ownership rates are higher for both groups but, 

again, the AlAN rate is below that for non-Indians (73 percent vs. 83 percent); 
Assessment of American Indian Housing Needs and Programs: Final Report 248 

another 12,700 AlAN renters with incomes above 80 percent of median lived in 

these areas in 1990. 

CONCLUSIONS AND POLICY DIRECTIONS 

Convincing arguments can be made for expanding reliance on the conventional housing 

finance system in the United States to meet the needs of prospective Indian homebuyers, 

because it represents the least-cost solution. Whereas creating new financial institutions targeted 

at Indian homebuyers would be extremely costly, the extant system of primary and secondary 

mortgage lending institutions with its enormous stocks of financial capital and technical know-how 

could serve existing and projected mortgage financing needs in Indian country at minimal 

marginal COSt.87 What is needed to open the existing private financial system to Indians, it is 

argued, is increased communication, trust, and understanding among lenders, tribes, and 

prospective Indian borrowers. 

Many view the challenge of opening up conventional lending sources to Indians to be 

daunting at best. Those who believe only increased communication between tribes and lenders 

is needed are considered naive by many knowledgeable observers. First, many rural areas are 

thought to be badly underserved by private lenders, and the problem magnified in Indian country. 

Second, even where private lenders are located in Indian country, they are often reluctant to lend 

to Indians because of low profit expectations due to the perceived low loan demand volume and 

perceived high risk from lending on trust lands. 

Both views are undoubtedly correct, depending on the situation. At the one extreme are 

lending institutions such as Firstar Bank of Minocqua and Associated Bank of Green 8ay--both 

of which have been making profitable mortgage loans on Indian reservations for several years. 

At the other extreme are those lending institutions such as First Interstate which have been 

charged with systematically excluding Indian reservations from their service areas. 

Given the numerous recent initiatives identified earlier in this chapter, it is clear that the 

expanded/extended private finance system option is currently being pursued. Intensified efforts 

to open up conventional lending markets to prospective Indian homebuyers have occurred too 

recently to accurately gauge their results. Moreover, they generally have been undertaken in 

areas with best prospects for success, e.g., in Navajo country because of its Residential Master 

87An estimated 75 percent to 90 percent of the 230 lending institutions which are members of the Seattle Federal 

Home Loan Bank have Native Americans within their CRA-designated service areas. Estimates provided by Judy 

Chaney, Community Investment Officer, Seattle FHLB (telephone conversation), August 9, 1994. 
Assessment of American Indian Housing Needs and Programs: Final Report 249 

Lease Act. However, the assessments of market potential presented earlier in this chapter 

suggest that, for the private housing finance industry, the issue is indeed worth pursuing more 

broadly. 

Local Actions-Establishing Market Pre-Conditions 

Enhancing private financing for housing in Indian country cannot occur only through the 

actions of outsiders. Tribes must also decide whether they want to pursue this goal for their 

members and, if so, to make internal changes that will create an environment more conducive 

for it. Private markets develop only where govemmeR-ts have taken action to develop legal, 

institutional, and other preconditions. 

The difficulty in establishing an increased role for the private sector within Tribal Areas 

mirrors the difficulties currently being encountered by the Eastem European countries. Nation 

states which were formerly dominated by the Soviet Union's centrally directed economic system 

are struggling to develop the conditions necessary for markets to function. Shifting to a larger 

role for the private sector may pose an even greater challenge for Indian nations which maintain 

substantial dependence on the Federal government. 

A key requirement for development of a viable market economy is self-interested behavior 

on the part of resource owners and entrepreneurs as well as by consumers. Indeed, underlying 

the desire to amass wealth, including in the form of home equity, is the desire to "get ahead." 

Some argue that in much of Indian culture, individual success is subordinated to the tribe's 

collective well-being, thereby presumably placing Indian households at a disadvantage in the 

competition for scarce resources within the private sector. 

However, the evidence is mixed regarding the proclivity of Native Americans to act 

collectively through government vs. individually within private economies. Self-employment 

among AlAN workers is less than among non-Indians (5.7 percent vs. 7.0 percent), for example, 

and employment in the for-profit sector is less for Indians than for non-Indians (64 percent vs. 71 

percent). On the other hand, labor force participation rates are actually somewhat higher for 

Indians than for non-Indians in all area types except Tribal Areas. Rates of labor force 

participation, self employment, and dependence on government jobs vary dramatically among 

area types. This would tend to indicate that the less developed private housing sectors in Tribal 

Areas may owe more to differences in resource availability and to historical accident than to 

cultural differences between Indians and non-Indians. 

Currently receiving considerable attention in AlAN Areas has been the issue of property 

rights, especially of land. Whereas individual ownership (fee simple) is the predominant form of 

property rights in the U.S., communal ownership is the principal form of land ownership in most 
Assessment of American Indian Housing Needs and Programs: Final Report 250 

Tribal Areas, with home owners maintaining leaseholds.ss The collectivist tradition of Indian 

tribes is viewed by some as among the most significant barriers to their economic development; 

they urge the BIA and Indian leaders to move away from collectivism and toward private property 

rights.s9 However, recent innovations discussed above show that using private land parcels in 

fee simple ownership as collateral for loans is not an absolute requirement. Other arrangements 

can be made to work, and tribal governments should consider options that will work best given 

their own traditions and legal and institutional settings. Broader suggestions include: 

• Ensuring that markets are locally and tribally based. Unless tribal communities 

are involved in the development of market institutions and processes, they are unlikely to have 

confidence in the policies and programs that result. Consultation must occur on a continuing 

basis among tribal leaders, private housing providers, and public officials. 

• Maintaining a sufficiently long-term policy perspective. Uncertainty and 

instability are substantial barriers to development of long-term market solutions. Long-term 

community planning and stable funding of housing assistance and technical support programs are 

among the public actions which will help ensure an environment conducive to private financing 

of housing and related economic development activities. 

• Encouraging innovation and creativity in addressing local housing and 

community development needs. Program inflexibility and institutional rigidity frustrate creativity 

and innovativeness within private as well as public sectors. The proposed transfer of additional 

policy and program responsibilities from the Federal government to tribal communities is intended 

largely to permit greater flexibility in the use of available resources to meet specific local needs. 

• Develop local private housing market intermediaries. Buying and selling, 

borrowing and lending, and other market transactions require interaction between demander and 

supplier. In many Tribal Areas, such interaction is difficult at best, in some cases because of lack 

of information, in other cases because of a lack of trust, in still other cases because of racial 

discrimination. The need, therefore, is for intermediaries to bring Native American housing 

seekers, tribal officials, and private housing service providers together where appropriate as well 

as to provide education and outreach services. 

88For example, on Navajo reservations (the largest and most autonomous), an estimated 98 percent of the land is 

collectively owned. 

895ee, for example, Frum, 1994. 
Assessment of American Indian Housing Needs and Programs: Final Report 251 

Local Actions--Taking Advantage of the IHAs 

It is at the local level, however, that the need for increased information flow and 

intermediation is greatest. The common feature that seems to distinguish Tribal Areas exhibiting 

notable private financing of home purchases from other Areas is the presence of an individual or 

an organization strategically positioned to bridge the gap between housing demanders and 

housing suppliers. Among private financial institutions reporting success in making mortgage 

loans on trust lands in our survey, for example, frequently either the lending institution itself or 

one of its loan officers is located on or close to the reservation. 

From the standpoint of the tribe's efforts to attract private financing for housing, it would 

seem that the IHAs that currently administer HUD programs would be extremely well positioned 

to serve as a proactive intermediary. Melding governmental institutions and program activities 

with private sector financial capital would seem to have obvious benefits. For example, IHAs 

could serve as effective conduits through which private as well as public loanable funds are 

channeled into Indian country.90 

IHAs were developed to provide the institutional bridge between tribal demand for housing 

and the Federal government's supply of financing for Indian housing.91 Generally, IHAs appear 

to have performed that role reasonably well for the low-income sector of the housing market as 

it exists on reservations and trust lands. 

As indicated above, IHAs could conceivably play an important part in bringing together 

prospective Indian homebuyers and conventional mortgage lenders--by explaining the mortgage 

finance process to Indian households, explaining tribal customs and procedures to lenders, and 

reducing misconceptions and misunderstandings on both sides. Indeed, some believe IHAs 

"could potentially be effective vehicles for lenders to funnel credit to reservations" (Federal Home 

Loan Bank of Seattle, 1993). 

For this to happen, it will be important that the IHAs orient their efforts in ways suggested 

by the discussion of their functions and potential under the block-grant approach to assisted 

housing discussed in Chapter 8. They must become broadly creative and entrepreneurial in 

advancing housing improvement in their tribal areas, seeking financing from a variety of sources. 

90Norwest sees the IHA and tribal council as playing a critical intermediary role in the private housing finance market 

because: "They know the community better than we do. They have the respect of the community and the community 

trusts them." Ibid. 

91Potentially important opportunities exist for IHAs to play an increased role in virtually all facets of Indian housing; 

hence, the following discussion occurs within a broader context than the need for institutions to facilitate increased flows 

of mortgage money to Indian homebuyers. 
Assessment of American Indian Housing Needs and Programs: Final Report 252 

Clearly, they must act, and be seen as, agents of their tribes (and, where needed, eliminate any 

lingering images that they are agents of HUD). 

Directions for National Policy 

The recent innovations at the national level discussed earlier lay the groundwork for 

expanded national policy support for private mortgage financing in Tribal Areas. The Federal 

government can take a number of steps to support these directions. 

First, it can continue to encourage enhanced interest by existing Government Sponsored 

Enterprises (GSEs) in the provision of mortgage financing in Tribal Areas. Both Fannie Mae and 

Freddie Mac are already playing an increasingly active role in this arena. Encouraging their 

constancy in this role should be a matter of national policy. 

Second, it can act to broaden the range of national intermediaries available. An attractive 

embodiment of this idea is creating the proposed Native American Financial Services 

Organization (NAFSO). The basic objectives of NAFSO, as proposed, are to: (1) facilitate flows 

of savings among Tribal areas as well as to channel funds from national finance markets into 

local Native American housing markets; and (2) provide technical assistance, information, and 

other support of local housing finance markets in Tribal Areas. Features and functions include: 

• 	 federally chartered, for-profit, limited term, national institution; 

• 	 federal seed monies, matched by participating tribal contributions and any private 

investment as desired; 

• 	 creation of a second tier of local Native American Financial Institutions (NAFls) 

which would provide home mortgages and business loans to qualifying Native 

Americans; 

• 	 technical assistance to NAFls relative to securing, serviCing, packaging and selling 

mortgage and consumer loans to the existing secondary markets; 

• 	 assistance to secondary markets (Fannie Mae and Freddie Mac) in identifying and 

eliminating barriers relating to purchase of mortgages and loans from existing 

private lending institutions and NAFls; and 

• 	 purchase of mortgages and loans when and if secondary markets do not achieve 

purchase goals of these NAFI mortgages and loans. 
Assessment of American Indian Housing Needs and Programs: Final Report 253 

Finally, the Federal govemment can act to broaden its own information provision in this 

regard, and to use mechanisms it has developed for other purposes in this regard. A good 

example, in this regard is the Fair Housing Initiatives Program (FHIP). This program is a vehicle 

through which funds could be channeled to Indian interest groups to broaden knowledge of the 

intricacies of home purchase and financing across Native American communities and, in 

particular, take steps to address discrimination. 

Concluding Comments 

Development of private sector housing capacity will require a combination of Federal 

actions on both demand and supply sides of the market, tailored to specific local needs. Federal 

policy initiatives must be based on two types of area-by-area assessments. One was a primary 

focus of this study, i.e., determining local housing needs in terms of affordability, adequacy, and 

crowding. The other would determine local capacity needs in terms of institutions and processes 

for mobilizing scarce resources to address identified housing needs. Housing and capacity needs 

are closely related; for example, private sector capacity building will be most needed in those 

areas having substantial numbers of moderate-income households. 

In some Tribal Areas, Federal efforts are unlikely to prompt significant private sector 

response to Native Americans' housing needs without extraordinary resource outlays. In those 

areas, the most viable strategy may be development of entirely new institutional arrangements, 

e.g., the NAFSO proposal. Such an institution could fill a serious need within selected areas by 

equipping housing authorities to assist homebuyers in obtaining mortgage financing--both public 

and private--through financial intermediation. 

But ample evidence exists to indicate that the barriers to expanded and effective local 

housing markets in tribal areas are not insurmountable. Indeed, Federal housing policy can 

contribute greatly to meeting the critical housing needs of Native Americans by promoting 

development of local private housing markets, thereby helping meet those needs not otherwise 

addressed by subsidized programs targeted at low-income households. 

In summary, the number of AlAN households at moderate- and higher-income levels is 

substantial. Yet when categorized by income level and family status, AlAN homeownership rates 

are typically well below those of non-Indian households. Opportunities to increase Indian 

homeownership on market terms appear significant, and with modest subsidies, it should be 

possible to extend ownership to many more AlAN households. 

The small-scale survey of mortgage lenders conducted indicated that private lending 

institutions near Tribal Areas in almost all parts of the country now regularly originate some 

mortgages for Indian homebuyers, although the volumes remain extremely small--the reasons 
Assessment of American Indian Housing Needs and Programs: Final Report 254 

include lack of knowledge and initiative by tribes and their members as well as caution due to 

continued perception of high risks on the part of lenders. Major lenders and secondary market 

institutions at the national level, however, are currently exhibiting considerable interest in finding 

ways to serve AlAN households in all locations more effectively. 

It is a positive sign that private intermediaries are beginning to recognize that expanded 

lending to AlAN households and communities may be a promising market opportunity. However, 

policy support is needed to translate this opportunity into reality at sufficient scale. 

REFERENCES 

Annez and Wheaton. 1984. "Economic Development and the Housing Sector," Economic 

Development and Cultural Change. July. 

Burns and Grebler. 1986. "Resource Allocation to Housing Investment." Economic 

Development and Cultural Change. October. 

Federal Home Loan Bank of Seattle. 1993. Bringing Private Resources to Native Lands: A 

Guide to Housing Finance for Native Americans, Alaska Natives and Native Hawaiians. 

Seattle: Federal Home Loan Bank of Seattle. October. 

Frum, David. 1994. "Clinton Pow Wow--Serious Reservations." The Wall Street Journal, April 

24. 

Community Investment Reporter. 1994. "Lenders Eye Blackpipe Case." Community Investment 

Reporter. pp. 202-203. 

Profit Wise Profiles. 1994. "Lending on Native American Lands: An Important CRA Opportunity. 

Profit Wise Profiles. Volume 1, Issue 2, June. 

Mayo, Stephen, Stephen Malpezzi, and Gross. "Shelter Strategies for the Urban Poor." The 

World Bank Research Observer. Summer 1986. 

Montana Human Rights Commission. 1989. Final Report FAIR Housing Assistance Program: 

Private Fair Housing Enforcement Focusing on American Indians, Helena, Montana. 
Assessment of American Indian Housing Needs and Programs: Final Report 255 

National American Indian Housing Council. 1993. Feasibility Study: A Predevelopment Loan 

Fund on Native American Trust Lands. Washington, D.C.: National American Indian 

Housing Council. 

National Association of Realtors. 1988. Real Estate in the U.S. Economy: Impacts on GNP, 

Income and Employment. A National Association of Realtors Staff Study. Washington, 

D.C.: National Association of Realtors. 

Richardson, Todd. 1995. "HMDA Data Analysis," unpublished paper, U.S. Department of 

Housing and Urban Development, Office of Policy Development and Research. 

Washington, D.C. 

U.S. Government Printing Office. 	 1995. "Outlay Equivalent Estimates for Tax Expenditures in 

the Income Tax." Analytical Perspectives: Budget of the United States Govemment, 

Fiscal Year 1996. Washington, D.C. 
Assessment of American Indian Housing Needs and Programs: Final Report 256 

Annex 9A 

Multiple Regression Analysis 

Weight by total number of home loans to Native American households in 1993 

Dependent Variable: 

PHOTPUR = 	 Percent of Native American Households in County receiving 

a loan for a home purchase in 1993 

Variable(s) Entered on Step Number: 

1. AREASD = 	 Dummy variable. If county has Indian areas, AREASD=1. 
 

2. 	 PHPURNS = Percent of home purchase loans made to Native Americans 
 

in 1993 not sold on the secondary market. 
 

3. 	 FOGT95 = Percent of AlAN households in county greater than 95% of 
 

median that are owners. 
 

4. OKAK = 	 Dummy variable. If county in Oklahoma or Alaska, OKAK=1. 
 

5. 	 PHFHA = Percent of AlAN households receiving home purchase loan in 
 

1993 who used FHA. 
 

6. AVGINC = 	 Average Income of Native American Households in County. 
 

7. PIND = 	 Percent of total households in county that are Native American. 
 

8. 	 PHDENY = Percent of AlAN households applying for home purchase loan that 
 

were denied in 1993. 
 

9. 	 PNINMG = Percent of total households in county that are non-Indian and 
 

have a mortgage 
 

Multiple R .63813 

R Square .40721 

Adjusted R Square .40684 

Standard Error 3.13138 

Analysis of Variance 

DF Sum of Squares Mean Square 

Regression 9 96858.13916 10762.01546 

Residual 14379 140998.33835 9.80557 

F= 1097.54098 Signif F = .0000 
Assessment of American Indian Housing Needs and Programs: Final Report 257 

Annex 9A (continued) 

Multiple Regression Analysis 

Variables in the Equation 

Variable B SE B Beta T Sig T 

AREASD -1.082693 .068893 -.113299 -15.716 .0000 

FOGT95 .040911 .002561 .114563 15.973 .0000 

OKAK 2.307382 .138513 .111350 16.658 .0000 

PHPURNS -.044741 .002298 -.156063 -19.467 .0000 

AVGINC 9.34583E-05 3.4869E-06 .210103 26.803 .0000 

PHFHA -.015367 .002027 -.054369 -7.581 .0000 

PIND -.314003 .014369 -.161660 -21.853 .0000 

PHDENY -.099268 .003882 -.192002 -25.572 .0000 

PNINMG .077384 .003827 .163631 20.221 .0000 

(Constant) .349277 .244377 1.429 .1530 

Listwise Deletion of Missing Data 

Equation Number 1 Dependent Variable. PPR3GT80 

Block Number 1. Method: Enter PWMTG PCTL T50 PCTELD 

Variable(s) Entered on Step Number 1. PCTELD 

2. PCTLT50 

3. PWMTG 

Multiple R .61594 

R Square .37939 

Adjusted R Square .37938 

Standard Error 9.48382 

Analysis of Variance 

OF Sum of Squares Mean Square 

Regression 3 21618239.03577 7206079.67859 

Residual 393182 35363934.29462 89.94291 

F = 80118.37135 Signif F = .0000 

Variables in the Equation 

Variable B SE B Beta T Sig T 

PCTELD -.467995 .002468 -.253578 -189.647 .0000 

PCTLT50 .219956 .001543 .210634 142.519 .0000 

PWMTG -.312959 9.6530E-04 -.505330 -324.209 .0000 

(Constant) 28.030701 .108093 259.320 .0000 
Assessment of American Indian Housing Needs and Programs: Final Report 258 

AnnexA 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

REGION 1 - NORTH CENTRAL 

2800 MI Pine Creek Reservation (state) None 20 22 22 8 

1610 MI Isabella Reservation and T.L. MI043 580 872 22,931 280 

170 MI Bay Mills Reservation MI062 283 380 441 117 

1880 MI L'Anse Reservation and T.L. MI065 701 697 3,317 289 

1410 MI Hannahville Community and T.L. MI075 206 190 196 40 

1830 MI Lac Vieux Desert Reservation MI085 0 147 147 44 

3635 MI Sault Ste. Marie Reserv. and T.L. MI149 0 501 723 135 

1370 MI Grand Traverse Reservation and T.L. MI197 0 233 263 88 

2285 MN Minnesota Chippewa T.L. None 210 31 31 10 

1940 MN Leech Lake Reservation MN012 2,759 3,421 8,783 1,065 

4595 MN White Earth Reservation MN013 2,550 2,798 8,785 962 

1125 MN Fond du Lac Reservation MN015 514 1,083 3,211 384 

3100 MN Red Lake Reservation MN016 2,823 3,560 3,690 923 

4485 MN Vermillion Lake Reservation MN018 103 35 35 17 

335 MN Bois Forte (Nett Lake) Reservation MN081 392 326 335 96 

1355 MN Grand Portage Reservation MN175 195 205 308 100 

2270 MN Mille Lacs Reservation MN204 293 354 380 99 

3385 MN Sandy Lake Reservation MN204 0 26 28 10 

2055 MN Lower Sioux Community MN207 65 212 241 61 

2985 MN Prairie Island Community MN207 80 26 30 9 

3680 MN Shakopee Community MN207 77 182 229 65 

4445 MN Upper Sioux Community MN207 51 23 26 12 

1825 WI Lac du Flambeau Reservation WI009 1,093 1,431 2,408 458 

2560 WI Oneida (West) Reservation WI010 1,821 2,450 17,940 775 

140 WI Bad River Reservation WI012 699 837 1,031 279 

3085 WI Red Cliff Reservation and T.L. WI013 590 729 876 235 

4015 WI Stockbridge Reservation WI014 582 448 565 174 

2965 WI Potawatomi Reservation and T.L. WI035 220 247 266 76 

3885 WI Sokaogon Chippewa Commun.and T.L. WI036 173 303 337 93 

1815 WI Lac Courte Oreilles Reserv. and T.L. WI054 1,145 1,767 2,437 534 

3305 WI St. Croix Reservation WI062 392 436 485 142 

4650 WI Wisconsin Winnebago Reserv. and T.L. WI238 349 526 608 157 

2175 WI Menominee Reservation WI243 2,377 3,216 3,411 871 

REGION 2 - EASTERN 

2865 AL Poarch Creek Reservation and T.L. AL204 0 190 255 80 

9140 CT Mohegan TDSA (state) None 0 240 24,636 138 

2145 CT Mashantucket Pequot Reservation CT050 6 50 71 21 

3650 CT Schaghticoke Reservation (state) CT065 2 5 10 5 

2700 CT Paucatuck Eastern Pequot Res.(state) CT067 16 16 16 8 

2240 FL Miccosukee Reservation None 213 72 72 12 

225 FL Big Cypress Reservation FL059 351 444 449 117 

360 FL Brighton Reservation FL059 323 415 528 139 

1475 FL Hollywood Reservation FL059 416 480 1,412 161 

3665 FL Seminole T.L. FL059 0 80 105 27 

4125 GA Tama Reservation (state) None 30 9 20 2 
Assessment of American Indian Housing Needs and Programs: Final Report 259 

Annex A (Continued) 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

3280 IA Sac and Fox (Iowa) Reservation IA112 492 572 586 130 

9190 MA Wa.mpanoag-Gay Head TOSA MA176 0 283 11,639 123 

2760 ME Penobscot Reservation and T.L. ME012 398 393 469 177 

2850 ME Pleasant Point Reservation ME013 504 514 542 148 

1575 ME Indian Township Reservation ME014 333 542 624 168 

2300 MS Mississippi Choctaw Reserv. and T.L. MS092 3,166 4,056 4,257 924 

990 NC Eastern Cherokee Reservation NC041 4,844 5,287 6,311 1,839 

9040 NC Coharie TOSA (state) NC171 0 1,422 116,224 585 

9090 NC Haliwa-Saponi TOSA (state) NC171 0 2,244 6,431 738 

9120 NC Lumbee TOSA (state) NC171 0 28,775 50,228 8,931 

9130 NC Meherrin TOSA (state) NC171 0 201 55,274 86 

9180 NC Waccamaw Siouan TOSA (state) NC171 0 1,297 2,771 405 

9160 NJ Ramapough TOSA (state) None 0 139 652 54 

2895 NY Poospatuck Reservation (state) None 94 164 196 62 

3765 NY Shinnecock Reservation (state) None 194 355 397 124 

4225 NY Tonawanda Reservation None 438 448 483 168 

4360 NY Tuscarora Reservation None 873 353 709 182 

80 NY Allegany Reservation NY040 925 1,068 7,312 417 

540 NY Cattaraugus Reservation NY040 1,855 1,979 2,183 681 

3320 NY SI. Regis Mohawk Reservation NY436 1,763 1,923 1,974 619 

2555 NY Oneida (East) Reservation NY445 0 41 41 12 

2415 RI Narragansett Reservation RI028 0 19 30 5 

525 SC Catawba Reservation (state) SC063 728 111 177 48 

2160 VA Mattaponi Reservation (state) None 68 72 74 24 

2650 VA Pamunkey Reservation (state) None 50 37 47 29 

9020 VA Chickahominy TOSA (state) None 0 482 2,749 193 

9070 VA Eastern Chickahominy TOSA (state) None 0 8 98 8 

REGION 3 - OKLAHOMA 

5090 OK Cherokee T JSA OK045 52,135 66,435 399,134 27,628 

5130 OK Chickasaw T JSA OK047 14,037 21,013 257,513 9,381 

5150 OK Choctaw T JSA OK049 18,963 28,245 209,353 11,883 

5210 OK Creek TJSA OK051 6,685 45,190 635,454 20,482 

5710 OK Creek-Seminole Joint Area T JSA OK051 3,718 531 2,419 185 

5070 OK Caddo-Wichita-Oelaware T JSA OK077 6,208 599 8,208 231 

5300 OK Iowa TJSA OK090 1,532 307 4,137 112 

5580 OK Sac and Fox T JSA OK090 0 4,575 51,092 1,816 

5770 OK Iowa-Sac and Fox Joint Area T JSA OK090 0 20 835 17 

5010 OK Abs.Shawnee-Cit.Band Potawatomi T JSA OK091 4,282 6,129 91,012 2,676 

5600 OK Seminole T JSA OK093 0 3,772 22,993 1,272 

5520 OK PawneeTJSA OK094 0 1,628 15,413 628 

5380 OK Kiowa-Comanche-Apache T JSA OK098 3,338 12,979 205,740 4,457 

5110 OK Cheyenne-Arapaho T JSA OK100 3,225 6,824 150,665 2,496 

5490 OK Otoe-Missouria T JSA OK114 1,191 475 2,750 153 

2595 OK Osage Reservation OK127 4,749 6,100 41,393 2,588 

5640 OK Tonkawa TJSA OK141 0 881 12,268 336 

5340 OK KawTJSA OK145 1,045 687 13,227 291 
Assessment of American Indian Housing Needs and Programs: Final Report 260 

Annex A (Continued) 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

REGION 4 - SOUTH CENTRAL 

9060 KS Delaware-Muncie TOSA (state) None 0 23 299 6 

1770 KS Kickapoo Reservation KS048 356 368 478 108 

2960 KS Potawatomi (Kansas) Reservation KS084 331 503 1,079 175 

3285 KS Sac and Fox (KS-NE) Reservation and T.L. KS151 13 35 162 12 

4315 LA Tunica-Biloxi Reservation None 7 18 36 10 

9010 LA Apache Choctaw TOSA (state) None 0 684 22,646 239 

9030 LA Clifton Choctaw TOSA (state) None 0 181 552 61 

9100 LA Jena Band of Choctaw TOSA (state) None 0 336 60,394 168 

9170 LA United Houma Nation TOSA (state) None 0 10,018 817,374 3,654 

635 LA Chitimacha Reservation LA244 185 231 311 96 

795 LA Coushatta Reservation LA260 203 42 42 16 

50 TX Alabama and Coushatta Reservation TX338 494 548 548 155 

4755 TX Ysleta Del Sur Pueblo TX429 365 248 370 97 

REGION 5 - PLAINS 

3925 CO Southern Ute Reservation C0010 855 1,037 7,886 346 

4470 CO Ute Mountain Reservation and T.L. C0047 1,128 1,299 1,366 373 

2550 IA Omaha Reservation NE013 1,275 1,925 5,238 419 

1590 KS Iowa Reservation KS067 26 96 227 42 

305 MT Blackfeet Reservation MT008 5,525 7,031 8,488 1,978 

1250 MT Fort Peck Reservation MT009 4,273 5,822 10,722 1,712 

1150 MT Fort Belknap Reservation and T.L. MT010 1,870 2,308 2,485 645 

3205 MT Rocky Boy's Reservation and T.L. MT011 1,549 1,860 1,931 411 

2490 MT Northern Cheyenne Reserv. and T.L. MT012 3,101 3,564 3,906 913 

1110 MT Flathead Reservation MT013 3,771 5,128 21,061 1,970 

845 MT Crow Reservation and T.L. MT014 3,954 4,706 6,341 1,093 

1160 NO Fort Berthold Reservation NOO05 2,640 3,054 5,387 851 

4345 NO Turtle Mountain Reserv. and T.L. NOO06 5,774 6,730 7,101 1,982 

910 NO Devils Lake Sioux Reservation NOO08 2,261 2,665 3,574 644 

3970 NO Standing Rock Reservation SOO06 4,800 4,872 7,956 1,213 

1860 NO Lake Traverse (Sisseton) Reservation S0015 2,700 2,810 10,840 800 

4625 NE Winnebago Reservation NE045 1,140 1,154 2,346 335 

3565 NE Santee Reservation NE105 420 438 740 149 

1340 NV Goshute Reservation NV015 105 76 79 30 

2810 SO Pine Ridge Reservation and T.L. SOO01 12,735 11,006 12,119 2,497 

3235 SO Rosebud Reservation and T.L. SOO02 6,978 7,998 9,632 2,046 

2030 SO Lower Brule Reservation SOO03 850 984 1,095 238 

855 SO Crow Creek Reservation SOO04 1,474 1,521 1,763 358 

605 SO Cheyenne River Reservation SOO05 4,107 5,092 7,743 1,426 

4700 SO Yankton Reservation S0012 1,688 2,002 6,281 518 

1100 SO Flandreau Reservation S0049 158 252 280 84 

3840 UT Skull Valley Reservation None 13 17 17 5 

4390 UT Uintah and Ouray Reservation UTOO1 2,050 2,667 17,235 725 

2625 UT Paiute of Utah Reservation UT010 186 285 624 86 

4610 WY Wind River Reservation WY001 4,159 5,717 21,915 1,594 
Assessment of American 261 Indian Housing Needs and Programs: Final Report 

Annex A (Continued) 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

REGION 6 - ARIZONA-NEW MEXICO 

1440 AZ Havasupai Reservation None 267 416 433 99 

2735 AZ Payson (Yavapai-Apache) Community None 0 103 103 38 

3355 AZ San Carlos Reservation AZOll 5,872 7,060 7,239 1,697 

3340 AZ Salt River Reservation AZ014 2,624 3,547 4,856 876 

1310 AZ Gila River Reservation AZ015 2,093 9,101 9,578 2,303 

1140 AZ Fort Apache Reservation AZ016 6,880 9,902 10,506 2,378 

1545 AZ Hualapai Reservation and T.L. AZ017 809 812 833 219 

735 AZ Colorado River Reservation AZ018 1,965 2,374 7,944 752 

1220 AZ Fort McDowell Reservation AZ019 345 568 628 145 

695 AZ Cocopah Reservation AZ020 349 549 584 141 

465 AZ Camp Verde Reservation AZ022 173 574 624 148 

4710 AZ Yavapai Reservation AZ022 66 151 193 61 

1720 AZ Kaibab Reservation AZ024 93 65 120 18 

2665 AZ Papago Reservation AZ026 6,959 8,490 8,587 2,204 

3605 AZ San Xavier Reservation AZ026 851 1,087 1,129 280 

1505 AZ Hopi Reservation and T.L. AZ027 6,707 7,002 7,215 1,679 

2680 AZ Pascua Yaqui Reservation AZ040 561 2,270 2,406 519 

2130 AZ Maricopa (Ak-Chin) Reservation AZ042 375 411 450 101 

4785 AZ Zuni Pueblo NM019 5,988 7,094 7,445 1,499 

2430 AZ Navajo Reservation and T.L. AZ012 126,359 143,507 148,658 35,371 

60 NM Alamo Navajo Reservation AZ012 1,062 1,226 1,259 263 

480 NM Canoncito Reservation AZ012 969 1,183 1,193 275 

3055 NM Ramah Navajo Community AZ012 1,163 175 175 48 

1840 NM Laguna Pueblo and T.L. NM012 3,564 3,649 3,724 1,018 

2205 NM Mescalero Apache Reservation NM013 1,922 2,519 2,664 625 

1700 NM Jicarilla Apache Reservation NM014 1,715 2,404 2,636 634 

10 NM Acoma Pueblo and T.L. NM031 2,437 2,566 2,590 601 

680 NM Cochiti Pueblo NM031 613 792 1,410 220 

1625 NM Isleta Pueblo NM031 2,289 2,723 2,953 898 

1685 NM Jemez Pueblo NM031 1,504 1,734 1,734 380 

3370 NM Sandia Pueblo NM031 227 405 3,944 136 

3400 NM San Felipe Pueblo NM031 1,789 1,884 2,525 339 

3430 NM San Juan Pueblo NM031 851 1,275 5,237 378 

3480 NM Santa Ana Pueblo NM031 407 491 624 124 

3495 NM Santa Clara Pueblo NM031 1,839 1,295 10,230 437 

3585 NM Santo Domingo Pueblo NM031 2,139 2,721 2,773 360 

4770 NM Zia Pueblo and T.L. NM031 524 638 638 146 

2400 NM Nambe Pueblo and T.L. NM040 194 313 1,358 125 

2785 NM Picuris Pueblo NM040 125 164 1,899 52 

2880 NM Pojoaque Pueblo NM040 94 159 2,481 73 

3415 NM San IIdefonso Pueblo NM040 488 334 1,586 106 

4140 NM Taos Pueblo and T.L. NM040 1,034 1,252 4,701 428 

4170 NM Tesuque Pueblo and T.L. NM040 236 223 702 63 

REGION 7 - CALIFORNIA-NEVADA 

20 CA Agua Caliente Reservation None 65 135 19,839 64 

95 CA Alturas Rancheria None 7 3 3 3 
Assessment of American Indian Housing Needs and Programs: Final Report 262 

Annex A (Continued) 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

185 CA Benton Paiute Reservation None 12 61 75 31 

215 CA Big Bend Rancheria None 8 5 5 2 

240 CA Big Lagoon Rancheria None 8 9 12 4 

265 CA Big Sandy Rancheria None 0 36 59 13 

275 CA Big Valley Rancheria None 0 31 81 24 

325 CA Blue Lake Rancheria None 0 27 53 14 

415 CA Cabazon Reservation None 8 37 858 8 

555 CA Cedarville Rancheria None 6 7 10 2 

750 CA Colusa (Cachil Dehe) Rancheria None 17 18 20 8 

780 CA Cortina Rancheria None 2 19 29 7 

1010 CA Elk Valley Rancheria None 0 50 128 13 

1640 CA Jackson Rancheria None 15 16 27 7 

1980 CA Lookout Rancheria None 12 62 62 21 

1995 CA Los Coyotes Reservation None 45 93 181 47 

2115 CA Manzanita Reservation None 13 37 66 19 

2190 CA Mesa Grande Reservation None 0 54 63 22 

2255 CA Middletown Rancheria None 39 18 76 5 

2330 CA Montgomery Creek Rancheria None 1 8 8 2 

2745 CA Pechanga Reservation None 117 242 391 119 

3095 CA Redding Rancheria None 0 44 72 10 

3145 CA Resighini Rancheria None 18 49 51 12 

3185 CA Roaring Creek Rancheria None 24 20 20 3 

3550 CA Santa Ysabel Reservation None 181 144 173 57 

3750 CA Shingle Springs Rancheria None 0 2 12 2 

3855 CA Smith River Rancheria None 0 96 189 33 

4030 CA Sulphur Bank (EI-Em) Rancheria None 115 91 96 24 

4095 CA Table Bluff Rancheria None 0 39 45 19 

4110 CA Table Mountain Rancheria None 0 35 44 13 

4275 CA Trinidad Rancheria None 47 61 71 30 

4430 CA Upper Lake Rancheria None 0 11 70 6 

4680 CA XL Ranch Reservation None 24 23 23 15 

4760 CA Yurok Reservation None 0 494 1,343 177 

155 CA Barona Rancheria CA080 222 351 573 102 

435 CA Cahuilla Reservation CA080 29 77 107 28 

450 CA Campo Reservation CA080 86 106 270 42 

1850 CA La Jolla Reservation CA080 141 151 162 32 

2360 CA Morongo Reservation CA080 313 526 1,109 197 

2635 CA Pala Reservation CA080 433 581 1,125 199 

2715 CA Pauma Reservation CA080 86 132 151 37 

3165 CA Rincon Reservation CA080 297 432 1,478 162 

3445 CA San Manuel Reservation CA080 24 38 59 16 

3460 CA San Pasqual Reservation CA080 133 221 517 77 

3525 CA Santa Rosa Reservation CA080 12 39 58 12 

3540 CA Santa Ynez Reservation CA080 120 254 317 79 

3870 CA Soboba Reservation CA080 0 372 442 104 

4255 CA Torres-Martinez Reservation CA080 11 158 1,628 43 

4500 CA Viejas Rancheria CA080 142 229 431 59 

1170 CA Fort Bidwell Reservation CA083 93 131 136 45 

1395 CA Grindstone Creek Rancheria CA083 72 101 101 20 

4060 CA Susanville Reservation CA083 82 148 491 50 
Assessment of American Indian Housing Needs and Programs: Final Report 263 

Annex A (Continued) 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

1490 CA Hoopa Valley Reservation CA090 1,502 1,780 2,199 569 

825 CA Coyote Valley Reservation CA097 0 124 139 31 

3250 CA Round Valley Reservation and T.L. CA097 528 549 1,181 190 

250 CA Big Pine Rancheria CA098 269 344 455 104 

290 CA Bishop Rancheria CA098 784 979 1,437 352 

350 CA Bridgeport Colony CA098 47 28 28 12 

1195 CA Fort Independence Reservation CA098 31 42 58 17 

1970 CA Lone Pine Rancheria CA098 172 164 235 63 

4300 CA Tule River Reservation CA099 424 750 803 199 

720 CA Cold Springs Rancheria CA129 63 136 163 39 

3520 CA Santa Rosa Rancheria CA129 117 281 319 78 

4330 CA Tuolumne Rancheria CA129 73 68 85 33 

955 CA Dry Creek Rancheria CA130 41 69 75 9 

1515 CA Hopland Rancheria CA130 10 160 208 45 

1925 CA Laytonville Rancheria CA130 105 123 137 43 

2100 CA Manchester (Point Arena) Rancheria CA130 77 173 212 58 

2820 CA Pinoleville Rancheria CA130 0 51 70 22 

3195 CA Robinson Rancheria CA130 0 125 167 28 

3265 CA Rumsey Rancheria CA130 11 10 19 0 

3735 CA Sherwood Valley Rancheria CA130 17 6 6 2 

3985 CA Stewarts Point Rancheria CA130 72 89 89 15 

585 CA Chemehuevi Reservation CA133 23 88 325 40 

1750 CA Karok Reservation and T.L. CA134 0 12 400 7 

1915 NV Las Vegas Colony None 106 71 86 20 

4045 NV Summit Lake Reservation None 15 8 8 3 

510 NV Carson Colony NV003 213 251 265 86 

940 NV Dresslerville Colony NV003 127 141 153 50 

4560 NV Washoe Reservation NV003 4 58 146 19 

3010 NV Pyramid Lake Reservation NV004 720 967 1,358 314 

965 ID Duck Valley Reservation NV006 932 1,003 1,096 327 

4515 NV Walker River Reservation NV008 471 612 811 212 

1210 NV Fort McDermitt Reservation NV009 463 382 399 109 

4725 NV Yerington Reservation and T.L. NV010 192 349 470 131 

1070 NV Fallon Colony NV011 46 143 162 53 

1075 NV Fallon Reservation NV011 258 338 369 132 

3130 NV Reno-Sparks Colony NV012 451 242 242 56 

2315 NV Moapa River Reservation NV014 182 177 377 52 

975 NV Duckwater Reservation NV015 103 136 151 51 

1040 NV Ely Colony NV015 67 79 85 23 

4155 NV Te-Moak Reservation and T.L. NV016 343 853 950 324 

2015 NV Lovelock Colony NV017 117 78 92 31 

4635 NV Winnemucca Colony NV017 35 54 54 14 

4740 NV Yomba Reservation NV020 57 100 106 25 

1280 AZ Fort Yuma (Quechan) Reservation CA054 1,105 1,123 2,102 353 

1235 AZ Fort Mojave Reservation and T.L. CA100 204 535 692 186 

REGION 8· PACIFIC NORTHWEST 

705 ID Coeur d'Alene Reservation and T.L 10007 541 756 5,778 273 

1800 10 Kootenai Reservation 10007 40 96 101 24 
Assessment of American Indian Housing Needs and Programs: Final Report 264 

Annex A (Continued) 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

2445 10 Nez Perce Reservation 1D008 1,463 1,885 16,159 630 

1185 10 Fort Hall Reservation and T.L. 10009 2,542 3,085 5,114 824 

400 OR Burns Paiute Reservation and T.L. None 160 150 198 38 

815 OR Cow Creek Reservation None 0 25 89 8 

1365 OR Grand Ronde Reservation None 0 2 49 2 

4405 OR Umatilla Reservation None 908 1,030 2,549 336 

4545 OR Warm Springs Reservation and T.L. OR013 2,016 2,871 3,143 694 

9110 OR Klamath TDSA OR037 0 1,858 40,883 683 

9050 OR Coquille Indian TOSA OR038 0 6,236 403,521 3,176 

1655 WA Jamestown Klallam Reserv. and T.L. None 0 10 34 3 

4690 WA Yakima Reservation and T.L. WA022 5,168 6,198 27,448 1,671 

4075 WA Swinomish Reservation WA023 414 581 2,285 185 

3040 WA Quinault Reservation WA027 943 967 1,271 276 

2070 WA Lummi Reservation WA028 1,259 1,608 3,164 379 

2085 WA Makah Reservation WA029 803 956 1,238 327 

1735 WA Kalispel Reservation WA037 98 84 90 30 

3940 WA Spokane Reservation WA037 1,050 1,213 1,451 376 

2375 WA Muckleshoot Reservation and T.L. WA040 379 875 3,836 182 

760 WA Colville Reservation WA043 3,500 3,779 7,034 1,274 

2910 WA Port Gamble Reservation WA044 266 386 555 97 

3030 WA Quileute Reservation WA047 273 290 352 98 

575 WA Chehalis Reservation WA048 200 286 504 94 

2040 WA Lower Elwha Reservation and T.L. WA050 69 103 112 33 

4290 WA Tulalip Reservation WA051 768 1,204 7,103 371 

1460 WA Hoh Reservation WA052 46 107 116 29 

2460 WA Nisqually Reservation WA052 75 460 649 111 

2925 WA Port Madison Reservation WA052 148 374 4,834 133 

3780 WA Shoalwater Reservation WA052 28 83 129 25 

3825 WA Skokomish Reservation WA052 305 415 618 132 

3955 WA Squaxin Island Reservation and T.L. WA052 35 146 194 45 

2475 WA Nooksack Reservation and T.L. WA056 66 456 697 129 

3625 WA Sauk-Suiattle Reservation WA062 0 50 112 19 

4000 WA Stillaguamish Reservation WA062 0 95 112 28 

4455 WA Upper Skagit Reservation WA062 0 161 173 51 

3000 WA Puyallup Reservation and T.L. WA063 856 977 32,435 384 

REGION 9 - ALASKA 

110 AK Annette Islands Reserve AK002 0 1,206 1,464 378 

6150 AK Angoon AK004 412 507 643 114 

6530 AK Chilkat AK004 113 122 140 38 

6535 AK Chilkoot AK004 0 16 219 8 

6660 AK Craig AK004 170 288 1,260 121 

7050 AK Hoonah AK004 543 527 729 166 

7090 AK Hydaburg AK004 253 353 388 114 

7160 AK Kake AK004 467 516 687 168 

7220 AK Kasaan AK004 14 42 54 20 

7310 AK Klawock AK004 210 377 705 123 

8005 AK Pelican AK004 0 74 212 26 

8350 AK Saxman AK004 194 321 380 73 
Assessment of American Indian Housing Needs and Programs: Final Report 265 

Annex A (Continued) 
 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 
 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

8685 AK Tenakee Springs AK004 0 13 92 10 

8980 AK Yakutat AK004 279 290 544 101 

6130 AK Anaktuvuk Pass AK005 191 238 272 60 

6220 AK Atkasook AK005 99 201 213 45 

6260 AK Barrow AK005 1,720 1,756 2,750 458 

7170 AK Kaktovik AK005 148 194 235 60 

7880 AK Nuiqsut AK005 181 319 335 84 

8080 AK Point Hope AK005 434 585 629 129 

8090 AK Point Lay AK005 63 121 148 43 

8910 AK Wainwright AK005 372 472 502 127 

6120 AK Ambler AK006 155 290 317 61 

6380 AK Buckland AK006 161 315 317 69 

6690 AK Deering AK006 138 152 157 48 

7260 AK Kiana AK006 325 339 367 81 

7300 AK Kivalina AK006 237 299 304 58 

7340 AK Kobuk AK006 59 61 72 14 

7400 AK Kotzebue AK006 1,574 2,065 2,751 515 

7810 AK Noatak AK006 259 344 352 73 

7840 AK Noorvik AK006 467 519 548 97 

8380 AK Selawik AK006 504 555 579 120 

8450 AK Shungnak AK006 179 217 225 55 

6070 AK Alatna AK007 29 23 23 11 

6110 AK Allakaket AK007 129 131 143 47 

6180 AK Anvik AK007 91 71 78 29 

6195 AK Arctic Village AK007 98 86 92 35 

6280 AK Beaver AK007 65 93 96 35 

6350 AK Birch Creek AK007 31 36 41 17 

6440 AK Chalkyitsik AK007 96 91 95 25 

6610 AK Circle AK007 60 58 73 17 

6720 AK Dot Lake AK007 38 18 49 9 

6740 AK Eagle AK007 57 30 35 20 

6830 AK Evansville AK007 27 27 64 13 

6880 AK Fort Yukon AK007 442 502 579 170 

6910 AK Galena AK007 215 368 806 128 

6970 AK Grayling AK007 129 208 217 50 

7010 AK Healy Lake AK007 29 42 48 15 

7070 AK Hughes AK007 71 51 60 21 

7080 AK Huslia AK007 178 176 192 66 

7190 AK Kaltag AK007 236 221 241 63 

7415 AK Koyukuk AK007 91 110 112 34 

7450 AK Lake Minchumina AK007 0 7 29 7 

7520 AK McGrath AK007 165 258 524 97 

7540 AK Manley Hot Springs AK007 12 39 123 18 

7630 AK Minto AK007 141 192 197 55 

7730 AK Nenana AK007 214 156 377 64 

7780 AK Nikolai AK007 82 104 113 38 

7870 AK Northway AK007 102 113 121 36 

7890 AK Nulato AK007 329 392 399 90 

8190 AK Rampart AK007 47 72 72 30 

8230 AK Ruby AK007 171 129 175 33 
Assessment of American Indian Housing Needs and Programs: Final Report 266 

Annex A (Continued) 
 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 
 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

8410 AK Shageluk AK007 120 131 135 38 

8570 AK Stevens Village AK007 61 101 101 34 

8600 AK Takotna AK007 25 9 36 4 

8610 AK Tanacross AK007 101 105 105 37 

8620 AK Tanana AK007 307 274 349 94 

8690 AK Tetlin AK007 104 84 91 22 

8725 AK Tok AK007 0 87 935 33 

8900 AK Venetie AK007 129 171 182 42 

6370 AK Brevig Mission AK008 138 168 188 48 

6650 AK Council AK008 0 4 6 2 

6800 AK Elim AK008 203 248 269 72 

6920 AK Gambell AK008 425 542 548 118 

6950 AK Golovin AK008 85 113 123 46 

7120 AK Inalik AK008 136 183 192 39 

7410 AK Koyuk AK008 180 232 240 58 

8280 AK SI. Michael AK008 227 290 315 63 

8340 AK Savoonga AK008 463 495 514 116 

8420 AK Shaktoolik AK008 159 167 175 40 

8440 AK Shishmaref AK008 369 418 433 108 

8510 AK Solomon AK008 4 6 6 3 

8560 AK Stebbins AK008 316 427 448 87 

8680 AK Teller AK008 196 133 154 40 

8850 AK Unalakleet AK008 546 510 646 154 

8920 AK Wales AK008 122 140 159 38 

8940 AK White Mountain AK008 116 145 174 45 

6030 AK Akiachak AK009 398 416 462 107 

6040 AK Akiak AK009 191 272 285 61 

6060 AK Alakanuk AK009 491 518 540 115 

6140 AK Andreafsky AK009 93 345 406 83 

6160 AK Aniak AK009 218 352 529 100 

6230 AK Atmautluak AK009 206 253 262 49 

6310 AK Bethel AK009 2,417 2,994 4,687 838 

6460 AK Chefornak AK009 221 302 310 66 

6480 AK Chevak AK009 445 559 597 135 

6570 AK Chuathbaluk AK009 0 89 99 17 

6670 AK Crooked Creek AK009 91 98 108 28 

6750 AK Eek AK009 220 254 264 67 

6810 AK Emmonak AK009 517 538 610 129 

6960 AK Goodnews Bay AK009 161 218 232 58 

7060 AK Hooper Bay AK009 598 817 846 178 

7180 AK Kalskag AK009 108 136 163 36 

7230 AK Kasigluk AK009 325 416 440 84 

7290 AK Kipnuk AK009 358 452 462 93 

7380 AK Kongiganak AK009 231 307 313 57 

7390 AK Kotlik AK009 280 448 462 102 

7430 AK Kwethluk AK009 441 543 568 123 

7440 AK Kwigillingok AK009 343 250 258 62 

7480 AK Lime Village AK009 39 44 47 15 

7510 AK Lower Kalskag AK009 237 285 289 64 

7560 AK Marshall AK009 246 252 283 63 
Assessment of American Indian Housing Needs and Programs: Final Report 267 

Annex A (Continued) 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name 01 Tribal Area Code 1980 1990 1990 holds 

7590 AK Mekoryuk AK009 153 168 168 57 

7650 AK Mountain Village AK009 539 640 706 131 

7700 AK Napakiak AK009 254 323 334 74 

7710 AK Napaskiak AK009 239 310 326 70 

7755 AK Newtok AK009 124 199 217 37 

7770 AK Nightmute AK009 116 168 174 22 

7900 AK Nunapitchuk AK009 295 375 385 87 

7950 AK Oscarville AK009 56 44 44 10 

8040 AK Pilot Station AK009 306 452 467 98 

8050 AK Pitkas Point AK009 82 123 131 37 

8060 AK Platinum AK009 44 64 67 23 

8180 AK Quinhagak AK009 402 468 509 125 

8200 AK Red Devil AK009 18 40 54 9 

8245 AK Russian Mission AK009 252 229 240 52 

8275 AK SI. Mary's AK009 243 27 34 4 

8360 AK Scammon Bay AK009 241 337 346 76 

8430 AK Sheldon Point AK009 98 99 112 24 

8490 AK Sleetmute AK009 95 93 115 35 

8580 AK Stony River AK009 56 49 49 21 

8730 AK Toksook Bay AK009 312 389 405 77 

8755 AK Tuluksak AK009 228 329 353 60 

8765 AK Tuntutuliak AK009 209 283 300 66 

8770 AK Tununak AK009 283 286 300 68 

6080 AK Aleknagik AK010 138 175 194 49 

6500 AK Chignik AK010 95 78 171 28 

6510 AK Chignik Lagoon AK010 41 46 78 13 

6515 AK Chignik Lake AK010 123 106 125 33 

6620 AK Clark's Point AK010 70 46 62 21 

6700 AK Dillingham AK010 891 1,122 2,017 378 

6760 AK Egegik AK010 57 84 120 37 

6790 AK Ekwok AK010 71 65 73 26 

7100 AK Igiugig AK010 25 20 29 4 

7110 AK Iliamna AK010 38 48 66 15 

7140 AK Ivanol Bay AK010 37 30 38 8 

7280 AK King Salmon AK010 0 105 684 37 

7360 AK Kokhanok AK010 80 151 161 39 

7370 AK Koliganek AK010 112 182 191 51 

7470 AK Levelock AK010 69 98 112 38 

7550 AK Manokotak AK010 273 381 398 88 

7680 AK Naknek AK010 161 252 590 105 

7740 AK Newhalen AK010 82 177 192 42 

7750 AK New Stuyahok AK010 311 381 398 81 

7830 AK Nondahon AK010 161 154 172 50 

8000 AK Pedro Bay AK010 31 41 41 11 

8010 AK Perryville AK010 103 105 110 24 

8035 AK Pilot Point AK010 57 47 54 14 

8140 AK Pori Heiden AK010 59 84 111 26 

8530 AK South Naknek AK010 124 105 133 30 

8720 AK Togiak AK010 443 519 606 130 

8780 AK Twin Hills AK010 67 37 44 16 
Assessment of American Indian Housing Needs and Programs: Final Report 268 

Annex A (Continued) 

LISTING OF CENSUS DESIGNATED TRIBAL AREAS 

AlAN Population Total AlAN 

Area IHA Pop. HouseCode ST Name of Tribal Area Code 1980 1990 1990 holds 

8810 AK Ugashik AK010 11 4 6 2 

6400 AK Cantwell AK011 28 39 145 13 

6550 AK Chistochina AK011 27 43 62 12 

6560 AK Chitina AK011 20 17 46 8 

6640 AK Copper Center AK011 85 144 426 54 

6990 AK Gulkana AK011 43 75 113 26 

7600 AK Mentasta Lake AK011 55 80 102 23 

8480 AK Slana AK011 8 2 63 2 

8650 AK Tazlina AK011 4 80 258 23 

6770 AK Eklutna AK012 42 31 381 15 

7330 AK Knik AK012 5 37 276 14 

7800 AK Ninilchik AK012 58 411 10,491 193 

8300 AK Salamatof AK012 43 110 1,007 29 

8390 AK Seldovia AK012 117 39 315 13 

8790 AK Tyonek AK012 222 109 121 48 

6020 AK Akhiok AK013 101 81 81 24 

7210 AK Karluk AK013 96 74 82 18 

7460 AK Larsen Bay AK013 120 143 164 29 

7930 AK Old Harbor AK013 315 253 276 75 

7960 AK Ouzinkie AK013 163 183 214 68 

8150 AK Port Lions AK013 158 133 206 47 

6470 AK Chenega AK015 0 62 94 14 

6820 AK English Bay AK015 98 147 161 41 

6840 AK Eyak AK015 0 13 168 5 

6980 AK Grouse Creek Group AK015 0 104 630 49 

8130 AK Port Graham AK015 141 124 145 59 

8640 AK Tatitlek AK015 53 98 111 25 

6050 AK Akutan AK016 66 81 605 18 

6210 AK Atka AK016 90 93 101 24 

6850 AK False Pass AK016 60 59 67 20 

7270 AK King Cove AK016 367 184 457 52 

7720 AK Nelson Lagoon AK016 55 71 80 32 

7790 AK Nikolski AK016 48 25 38 19 

8260 AK SI. George AK016 153 138 143 40 

8290 AK SI. Paul AK016 483 531 752 144 

8320 AK Sand Point AK016 357 422 859 147 

8860 AK Unalaska AK016 200 273 3,089 59 

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