Native American Housing: Information on HUD's Housing Programs for Native
Americans (Letter Report, 03/28/97, GAO/RCED-97-64).
Pursuant to a legislative requirement and a congressional request, GAO
reviewed the Department of Housing and Urban Development's (HUD) housing
programs for Native Americans, focusing on the: (1) funding history and
measurable results of the housing programs administered by HUD for
Native Americans in or near tribal areas; (2) significant factors that
complicate and make costly the provision of housing assistance to Native
Americans in or near tribal areas; (3) potential initial impact of the
recently enacted Native American Housing Assistance and
Self-Determination Act of 1996 on HUD's oversight of housing assistance
to Native Americans living in or near tribal areas; and (4) the extent
to which gaming occurs in tribal areas, its profitability, and whether
HUD takes revenues from gaming into account when allocating funding to
Native American housing authorities.
GAO noted that: (1) from fiscal year (FY) 1986 through FY 1995, HUD
provided $4.3 billion for housing and community development in tribal
areas; (2) of this amount, HUD provided $3.9 billion to approximately
189 Indian housing authorities to develop and maintain affordable
housing and assist low-income renters; (3) in this period, the
authorities used the funds to construct over 24,000 single-family homes,
operate and maintain existing housing, and encourage other development;
(4) over the decade, HUD also provided direct block grants totalling
over $424 million to eligible tribes for community development and
mortgage assistance; (5) many factors complicate and make costly the
development and maintenance of affordable housing for Native Americans;
(6) these factors include the remoteness and limited human resources of
many Indian housing authorities and the Indian communities they serve,
land-use restrictions and the inhospitality of the land, the difficulty
that contractors and Indian housing authorities have in complying with
statutory requirements to give hiring preference to Native Americans,
and vandalism and neglect, which draw on scarce maintenance funds; (7)
HUD believes that, initially, its workload could increase as it monitors
tribes' compliance with the new Indian housing legislation set to take
effect on October 1, 1997; (8) the new act changes the way HUD provides
housing assistance to Native Americans by requiring block grants to each
of the over 550 federally recognized tribes instead of categorical
grants to the 189 Native American housing authorities that currently
exist; (9) moreover, to qualify for the block grants, tribes must submit
housing plans for HUD's approval; (10) although the law requires HUD to
conduct only a limited review of the tribes' plans, HUD officials
believe that this activity will, for the first year at least, be a
labor-intensive function for HUD field offices; (11) of the 356 Indian
tribes in the continental United States alone, 177 operated 240 gaming
facilities as of July 1996; (12) according to 1994 and 1995 data
submitted by 85 of these tribes, their gaming revenues after expenses
totalled about $1.5 billion; (13) HUD officials told GAO that they do
not take gaming revenues directly into account when allocating funds
because, in addition to these revenues, HUD would need to know other
business revenues and federal assistance available to each tribe in ord*
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-97-64
TITLE: Native American Housing: Information on HUD's Housing
Programs for Native Americans
DATE: 03/28/97
SUBJECT: Native Americans
Housing programs
Indian lands
Low income housing
Federal aid for housing
Block grants
Hiring policies
Indian affairs legislation
Housing repairs
Community development
IDENTIFIER: HUD Public Housing Program
HUD Indian Housing Program
HUD Mutual Help Home Ownership Program
HUD Rental Program for Native Americans
HUD Home Investment Partnership Program
Community Development Block Grant
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Cover
================================================================ COVER
Report to the Subcommittee on VA, HUD, and Independent Agencies,
Committee on Appropriations, House of Representatives
March 1997
NATIVE AMERICAN HOUSING -
INFORMATION ON HUD'S HOUSING
PROGRAMS FOR NATIVE AMERICANS
GAO/RCED-97-64
Native American Housing
(385646)
Abbreviations
=============================================================== ABBREV
BIA - Bureau of Indian Affairs
CGP - Comprehensive Grant Program
CIAP - Comprehensive Improvement Assistance Program
HUD - Department of Housing and Urban Development
IHA - Indian housing authority
LOCCS - Letter of Credit Control System
MIRS - Management Information and Retrieval System
NIGC - National Indian Gaming Commission
VA - Veterans Administration
Letter
=============================================================== LETTER
B-276138
March 28, 1997
The Honorable Jerry Lewis
Chairman
The Honorable Louis Stokes
Ranking Minority Member
Subcommittee on VA, HUD,
and Independent Agencies
Committee on Appropriations
House of Representatives
Despite the Department of Housing and Urban Development's (HUD)
investment of $4.3 billion (in constant 1995 dollars) over the last
decade, housing problems for low-income Native Americans are still
more severe than for other Americans as a whole. In tribal areas,\1
where three-quarters of a million American Indians and Alaska Natives
live, the Urban Institute recently reported that 40 percent of the
households live in overcrowded or physically inadequate housing,
compared to only 6 percent of the U.S. population.\2 Providing safe
and decent housing at a reasonable cost in tribal areas is difficult
because of the austere and remote nature of the setting. Moreover,
the need for this housing is growing as Native Americans increase in
number and more of them return to their homelands.
In the Subcommittee's June 18, 1996, report accompanying the fiscal
year 1997 appropriations bill, you requested that we evaluate HUD's
housing programs for Native Americans. As agreed with your offices,
this report addresses the following questions:
-- What have been the funding history and measurable results of the
housing programs administered by HUD for Native Americans in or
near tribal areas?
-- What are the significant factors that complicate and make costly
the provision of housing assistance to Native Americans in or
near tribal areas?
-- What could be the initial impact of the recently enacted Native
American Housing Assistance and Self-Determination Act of 1996
on HUD's oversight of housing assistance to Native Americans
living in or near tribal areas?
-- To what extent does gaming occur in tribal areas, what is its
profitability, and does HUD take revenues from gaming into
account when allocating funding to Indian housing authorities?
--------------------
\1 Tribal areas include reservations for American Indians, villages
of Alaska Natives, and other special types of areas so designated by
the U.S. Census.
\2 In 1993, HUD commissioned a study by The Urban Institute Center
for Public Finance and Housing that resulted in the May 1996 report
entitled Assessment of American Indian Housing Needs and Programs.
The purposes of this study were to (1) evaluate the housing problems
and needs of American Indians and Alaska Natives, (2) assess the
effectiveness of existing federal housing programs in meeting those
needs, and (3) compare alternative approaches and suggest ways in
which federal policy could improve housing for Native Americans.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
From fiscal year 1986 through fiscal year 1995, HUD provided $4.3
billion (constant 1995 dollars) for housing and community development
in tribal areas. Of this amount, HUD provided $3.9 billion to
approximately 189 Indian housing authorities\3 to develop and
maintain affordable housing and assist low-income renters. In this
period, the authorities used the funds to construct over 24,000
single-family homes, operate and maintain existing housing, and
encourage other development. Over the decade, HUD also provided
direct block grants totaling over $424 million to eligible tribes for
community development and mortgage assistance.
Many factors complicate and make costly the development and
maintenance of affordable housing for Native Americans. These
factors include
-- the remoteness and limited human resources of many Indian
housing authorities and the Indian communities they serve,
-- land-use restrictions and the inhospitality of the land,
-- the difficulty that contractors and Indian housing authorities
have in complying with statutory requirements to give hiring
preference to Indians, and
-- vandalism and neglect, which draw on scarce maintenance funds.
HUD believes that, initially, its workload could increase as it
monitors tribes' compliance with the new Indian housing legislation
set to take effect on October 1, 1997. The new act changes the way
the Department provides housing assistance to Native Americans by
requiring block grants to each of the over 550 federally recognized
tribes in the continental United States, Alaska, and Hawaii instead
of categorical grants to the 189 Indian housing authorities that
currently exist. Therefore, the number of entities that HUD has to
oversee and assist could increase significantly. Moreover, to
qualify for the block grants, tribes must submit housing plans for
HUD's approval. Although the law requires HUD to conduct only a
limited review of the tribes' plans, HUD officials believe that this
activity will, for the first year at least, be a labor-intensive
function for HUD field offices.
Of the 356 Indian tribes in the continental United States alone, 177
operated 240 gaming facilities as of July 1996.\4 According to 1994
and 1995 data submitted by 85 of these tribes, their gaming revenues
after expenses totaled about $1.5 billion. HUD officials told us
that they do not take gaming revenues directly into account when
allocating funds because, in addition to these revenues, HUD would
need to know other business revenues and federal assistance available
to each tribe in order to determine a fair allocation. However,
tribes generally can use gaming revenues for many purposes, including
education, health facilities, and housing. Therefore, to the extent
that HUD takes a tribe's general economic well-being and housing
needs into account, it is indirectly factoring gaming revenues into
its funding allocation decisions.
--------------------
\3 An Indian housing authority is a business entity established by a
tribal government, organized under tribal or state law, to develop
and manage assisted housing units.
\4 See Profile of Indian Gaming (GAO/GGD-96-148R, Aug. 20, 1996).
We are currently updating this report with an analysis of more
complete financial data.
BACKGROUND
------------------------------------------------------------ Letter :2
The United States Housing Act of 1937 established the Public Housing
Program to provide decent, safe, and sanitary housing for low-income
families. For many years, this act was interpreted to exclude Native
Americans living in or near tribal areas. In 1961, however, HUD and
the Bureau of Indian Affairs (BIA) determined that Native Americans
could legally participate in the rental assistance for low-income
families authorized by the 1937 act and issued regulations to
implement this determination. In 1988, the Indian Housing Act
established an Indian housing program separate from public housing
under the Housing Act of 1937 and prompted HUD to issue regulations
specific to this program. With the recently enacted Native American
Housing Assistance and Self-Determination Act of 1996 (regulations
are scheduled to take effect on October 1, 1997), the Congress
completed the process of separating Indian housing from public
housing.
According to the May 1996 report by the Urban Institute, the housing
needs of Native Americans are growing. Their population rose sixfold
over the past four decades to over 2 million in 1990, 60 percent of
whom live in tribal areas or in the surrounding counties. Compared
to non-Indians, Native Americans are more family-oriented--37 percent
of Native American households are married couples with children
versus 28 percent of non-Indian households. Compared to non-Indians,
Native Americans have a higher unemployment rate (14 percent versus 6
percent), a smaller number of workers in "for-profit" firms per
thousand people (255 versus 362), and a higher share of households
with very low incomes (33 percent versus 24 percent). Moreover,
Indian housing conditions are much worse than housing conditions in
other areas of the country: 40 percent of Native Americans in tribal
areas live in overcrowded or physically inadequate housing, compared
to 6 percent of the U.S. population.
Through its Native American Programs headquarters office and its six
field offices, and with the help of approximately 189 Indian housing
authorities (IHA), HUD administers the majority of the housing
programs that benefit Native American families in or near tribal
areas. Several significant differences exist, however, between HUD's
assistance to these families and to families (non-Indian and Indian)
living in urban and other areas. First, HUD's support for Native
Americans derives, in part, from the nation's recognition of special
obligations to the Native American population and is reflected in
treaties, legislation, and executive orders. Second, the federal
government deals with recognized tribes directly in a
sovereign-to-sovereign relationship, rather than through the general
system of state and local government. This status allows tribes to
establish their own system of laws and courts. Third, the BIA often
holds in trust a considerable amount of land for a tribe as a whole;
thus, this land is not subdivided into many private holdings as
occurs in the rest of the country.\5 This trust arrangement has
frustrated the development of private housing markets in tribal areas
and has long been seen as providing special justification for
government assistance in housing production.
--------------------
\5 BIA also provides a relatively small amount of funding,
approximately $20 million annually, through its Housing Improvement
Program for improving existing housing.
HUD PROVIDES MOST FUNDING FOR
HOUSING ASSISTANCE THROUGH
INDIAN HOUSING AUTHORITIES
------------------------------------------------------------ Letter :3
Under current regulations, IHAs administer most of the low-income
housing assistance that HUD provides to Native Americans. But HUD
also provides some housing assistance directly to tribes and
individuals. Funding provided through housing authorities is used to
-- develop housing for eventual ownership by individual families
through the Mutual Help Program, under which families lease and
then buy their home by making payments to an IHA of
approximately 15 percent of their income and must cover their
own routine operating and maintenance expenses;
-- develop and maintain rental housing for low-income families
through the Rental Housing Program, under which, as with the
public housing program, low-income families rent housing from
the IHA at a cost of 30 percent of their adjusted income;
-- modernize and rehabilitate established low-income housing
through the public housing modernization program; and
-- subsidize IHAs to defray operating expenses that rental income
does not cover and provide rental vouchers for low-income
families.
Funding available to tribes and individuals includes
-- loan guarantees for home mortgages,
-- block grants through the HOME Investment Partnership Program for
tribes to develop affordable housing in tribal areas, and
-- community development block grants to enhance infrastructure and
other economic development activities.
Figure 1 shows the funding for fiscal year 1995 for these programs,
and table 1 describes the programs' results.
Figure 1: Funding for Major
Housing and Community
Development Programs for Native
Americans, Fiscal Year 1995
(Dollars in Millions)
(See figure in printed
edition.)
Source: Based on data from HUD's Office of Native American Programs.
Table 1
Results of Major Housing and Community
Development Programs for Native
Americans, Fiscal Year 1995
(Dollars in millions)
Funding for
Program FY 1995 Significant results
---------------------- ---------------- ----------------------------
Mutual Help Program $123 1,289 units planned
Rental Housing Program 121 495 units planned
Modernization of low- 161 Funded modernization
income housing activities such as
replacing roofs and
converting and enlarging
many of the 82,000 units
managed by IHAs
IHAs' operating 71 Subsidized IHA expenses for
subsidies preventive maintenance,
planning, rent collection,
tenant counseling and
contracting
Section 184 loan 3 Provided guarantees for 477
guarantees units
HOME Investment 14 Provided grants to 12 Native
Partnership Program American tribes to
construct 303 new houses,
rehabilitate 191 houses,
and acquire 54 houses
Community Development 46 Approved projects for
Block Grant Program housing rehabilitation,
infrastructure, buildings
(such as community
buildings), and economic
development
======================================================================
Total $539 2,434 units planned
----------------------------------------------------------------------
As shown in figure 2 and table 2, over the past decade HUD provided a
total of $4.3 billion for these programs, which have produced or
planned to produce a total of 24,002 housing units. Additional
information on the funding and the programs is contained in appendix
I.
Figure 2: Funding for Major
Housing and Community
Development Programs for Native
Americans, Fiscal Years 1986-95
(Constant 1995 Dollars in
Millions)
(See figure in printed
edition.)
Source: Based on data from HUD's Office of Native American Programs.
Table 2
Results of Major Housing and Community
Development Programs for Native
Americans, Fiscal Years 1986-95
(Constant 1995 dollars in millions)
Funding for
Program FY 1986-95 Significant results
-------------------------- ---------------- ------------------------
Mutual Help Program $1,612 15,721 units completed
Rental Housing Program 829 8,281 units completed
Modernization of low- 926 Rehabilitated housing
income housing units to meet HUD's
standards and upgraded
IHAs' management,
financial, and
accounting control
systems
IHAs' operating subsidies 548 Subsidized IHAs'
expenses for managing
the 82,000 assisted
units and provided
funding for various
management activities
Section 184 loan 3 Provided guarantees for
guarantees 477 units in 1995,the
program's first year
HOME Investment 54 Provided 59 grants to
Partnership Program construct,
rehabilitate, and
acquire houses
Community Development 370 Supported housing
Block Grant Program programs and
homeownership
assistance; the
construction of
community facilities,
such as roads, water,
and sewer facilities
and community
buildings; and economic
development activities
======================================================================
Total $4,342 24,002
----------------------------------------------------------------------
PROVIDING HOUSING ASSISTANCE
FOR NATIVE AMERICANS IS
CHALLENGING AND COSTLY
------------------------------------------------------------ Letter :4
The cultural and geographic environment of tribal areas differs from
mainstream America and causes HUD and IHAs to encounter unique
challenges and costly conditions as they administer and provide
housing programs for Native Americans. Because there are over 550
separate Indian nations, with unique cultures and traditions, not all
of these conditions are equally prevalent throughout tribal areas,
nor do they have a common impact on developing and maintaining
housing. Among the challenges and conditions highlighted in our
discussions with officials of HUD and several IHAs, as well as in the
May 1996 study by the Urban Institute, are
-- the remoteness and limited human resources of many IHAs and the
Native American communities they serve;
-- the lack of suitable land and the inhospitality of the climate;
-- the difficulty contractors and IHAs have in complying with
statutory requirements to give hiring preference to Native
Americans; and
-- the pressure that vandalism, tenants' neglect, and unpaid rent
put on scarce maintenance funds.
REMOTE RESERVATIONS LIMIT
INFRASTRUCTURE AND
AVAILABILITY OF HUMAN
RESOURCES
---------------------------------------------------------- Letter :4.1
The extent and pattern of Native American landholding are very
different today from what they were at the beginning of the 19th
century. During that century, the land area over which Indians had
sovereignty and which was available for creating reservations was
often reduced to small pieces in isolated areas.
The remoteness of some tribal areas has created significant problems
for housing development. In contrast to metropolitan areas, where
basic infrastructure systems (sewers, landfills, electricity, water
supply and treatment, and paved roads) are already in place, remote
tribal areas require a large capital investment to create these
systems to support new housing. Table 3 shows the investment needed
at the Gila River Housing Authority in Sacaton, Arizona, to build a
single-family home. According to HUD officials, the cost of site
improvements--creating and connecting to the "off-site"
infrastructure--is 43 percent higher than for a public housing
project in an urban area near the Gila River Indian Reservation.
Table 3
Typical Costs of Building a New Gila
River Home and Connecting It to Needed
Services
Expense Category Cost Percent of total
--------------------------- ------------ ---------------------------
Administration $4,522 6
Homeowner counseling and 803 1
training
Planning and surveys 7,693 10
Site improvements and off- 16,780 22
site infrastructure
Construction of dwelling 39,049 50
Dwelling equipment (e.g., 707 1
ranges and refrigerators)
Structures for storage and 8,000 10
vehicles
======================================================================
Total $77,554 100
----------------------------------------------------------------------
Source: HUD's Southwest Office of Native American Programs.
The remoteness of many of the tribal areas also increases the cost of
transporting supplies, raises labor costs, and reduces the
availability of supplies and of an "institutional infrastructure" of
developers and governmental and private entities. For example,
transporting a drilling rig over many miles and hours into the desert
to a tribal area in California is far more costly than if the well
had been needed in a less remote area. In addition, in its study of
Native Americans' housing needs, the Urban Institute found that
private housing developers, contractors, and suppliers; governmental
planners and building inspectors; private financial institutions; and
nonprofit groups\6
are all less available in remote tribal areas.
The limited human resources of many IHAs also contribute to the high
cost of developing and maintaining housing. HUD's Deputy Assistant
Secretary for Native American Programs told us that housing
authorities that recruit their staff from a small tribal population
often have difficulty finding qualified managers to administer
multimillion-dollar housing grants. This problem is made worse when
coupled with the statutory requirement to give Indians first
consideration for such jobs. According to the Deputy Assistant
Secretary, because many Indian applicants lack formal education, the
time they need to become familiar with specialized housing operations
can be longer than that needed by applicants from the larger pool
enjoyed by a public housing authority in an urban area.
The executive director at the Gila River Housing Authority echoed
these views when he described his inability to hire skilled and
dependable tribal members. He pointed out that many skilled members
have personal problems caused by drugs and alcohol, causing the
housing authority to search outside the tribal area for much of its
labor force. He also said that because members of the available
semiskilled workforce need a significant amount of training before
they are employable, he cannot afford to hire them. Moreover, some
of the tribe's laborers are drawn to cities away from the
reservation, he explained, because of the greater employment
opportunities and higher wages there.
This lack of skilled human resources is costly. HUD officials told
us that as a general rule in the construction industry, labor costs
should not exceed 50 percent of the total cost, but in tribal areas
labor costs can run as high as 65 percent because contractors
generally have to bring in skilled workers and pay for lodging or
commuting costs.
--------------------
\6 Most of the few nonprofits that do exist are either just beginning
operations or have operated less than 2 years in tribal areas. In
its preliminary investigation for a HUD-funded study due out this
month, the National American Indian Housing Council has identified
only six nonprofit organizations that provide housing assistance to
tribes.
LAND-USE RESTRICTIONS AND
THE INHOSPITALITY OF THE
LAND COMPLICATE THE
DEVELOPMENT AND MAINTENANCE
OF LOW-INCOME HOUSING
---------------------------------------------------------- Letter :4.2
Although the dominant visual impression in many tribal areas is a
vast expanse of unused land, a lack of available land is, in fact, a
constraint that many IHAs face as they develop low-income housing.
Factors that limit the availability of land for housing include the
trusts in which BIA holds the land that, until this year, limited
leases to 25 years in many instances. Special environmental and
other restrictions also exist. For example, in planning for
development, IHAs and tribes avoid archaeological and traditional
burial sites because cultural and religious beliefs preclude using
these sites for housing. In many cases, sufficient tribal land
exists for housing, but environmental restrictions prohibit the use
of much of it for housing. The Urban Institute's survey of IHAs
revealed that, overall, wetlands restrictions, water quality
considerations, and contaminated soils add to the cost of housing in
tribal areas.
In the Western desert, once low-income housing is developed, the
severity of the climate can complicate maintenance. The effects of
the high salt and mineral content in the water and soil were evident
at the Gila River Housing Authority, where water damages water
heaters and copper and cast iron pipes. The executive director told
us that the average life of a hot water heater costing $300 is about
6 months. To remedy the problem with the corrosion of plumbing, the
Gila River IHA has begun placing plumbing in ceilings for better
access and converting to plastic piping. The high mineral content in
the water also damages water circulation systems of large fans called
"swamp coolers," used for summer cooling. The executive director
told us that because of calcium buildup, the IHA must replace the
coolers annually. He also explained that the soil's high salt
content causes housing foundations and sewer systems to deteriorate.
Figures 3 and 4 illustrate the damage caused to swamp coolers and
foundations.
Figure 3: Corroded Swamp
Cooler at the Gila River Indian
Reservation, Arizona
(See figure in printed
edition.)
Figure 4: Deteriorated House
Foundation at the Gila River
Indian Reservation, Arizona
(See figure in printed
edition.)
COMPLYING WITH INDIAN HIRING
PREFERENCE AND DAVIS-BACON
ACT REQUIREMENTS ADDS
ADDITIONAL BURDEN TO IHAS
---------------------------------------------------------- Letter :4.3
Certain statutes, including the Indian Self Determination and
Education Assistance Act and the Davis-Bacon Act,\7 are intended to
protect and provide opportunities for specific groups. However, IHA
officials and HUD officials whom we contacted believe that these
statutes can make developing housing in tribal areas more costly
because they have the the effect of raising the cost of labor in
comparison to local wage rates or restricting the supply of labor.
The Indian Self Determination and Education Assistance Act of 1975
requires IHAs to award contracts and subcontracts to Indian
organizations and Indian-owned economic enterprises. IHA executive
directors find that complying with the requirement is difficult and
believe that it adds to contractors' time and cost to bid on work for
IHAs. The officials said that factors that undermine the requirement
include a lack of qualified Indian contractors in the area, the
creation of fraudulent joint ventures that are not owned or managed
by Indians, and the occasional need to use qualified firms outside
the region that do not understand local conditions.
Under the Davis-Bacon Act, firms that contract with IHAs for housing
development must pay wages that are no less than the wage rates
prevailing in the local area. However, HUD officials told us that
this requirement generally increases IHAs' cost of developing housing
in tribal areas. The increased cost occurs because the applicable
Davis-Bacon wage rate is often based on HUD's wage surveys of large
unionized contractors who are based in larger metropolitan areas;
therefore, the rate is about $10.00 per hour higher than the wage
rate prevailing in the local tribal area. Officials of the
Chemehuevi Housing Authority, in California, told us that because of
high Davis-Bacon wage rates, their cost to develop a single family
home ranges between $85,000 and $98,000. Using the prevailing rate
of approximately $6.50 to $8.00 per hour, they estimate the
development cost to be between $65,000 and $80,000. .
--------------------
\7 The Davis-Bacon Act provides that workers in certain trades
involved in federal construction contracts be paid wages determined
by the Secretary of Labor to be prevailing in the area of
construction.
NEGLECT AND VANDALISM DRAW
ON MAINTENANCE BUDGETS THAT
ARE SHRINKING BECAUSE OF
UNPAID RENT
---------------------------------------------------------- Letter :4.4
If housing units are abused through neglect or vandalism and not
well-maintained on an ongoing basis, costly major repairs can be
needed. These avoidable repairs put pressure on maintenance budgets
that are shrinking because of the high rate of unpaid rent in tribal
areas. Moreover, maintaining assisted housing for Native Americans
is an increasingly difficult challenge because of its age--44 percent
of the stock was built in the 1960s and 1970s.
For housing units in HUD's Rental Housing Program for Native
Americans, the Urban Institute reported that 65 percent of the IHA
officials responding to its telephone survey identified tenants'
abuse and vandalism of vacant homes as the factors contributing most
to maintenance costs. The Urban Institute also reported that fewer
than 10 percent of the officials identified any of the survey's other
contributors to maintenance costs, including poor materials, poor
construction, and a lack of preventive maintenance. For units under
the Mutual Help Program (which are owned or leased by the residents),
the Urban Institute reported that IHA officials cited residents'
neglect to perform needed maintenance as accounting for 30 percent of
poor physical conditions of this segment of the housing stock.
Our discussions with IHA officials reinforce these findings. The
executive director at the Gila River Housing Authority told us that
vandalism by juveniles was a major problem for him and that because
the tribal area borders Phoenix, Arizona, it is more susceptible to
gang activity and violence. Chemehuevi Housing Authority officials
pointed out that once a family that has neglected to perform expected
maintenance moves out and the tribe turns the housing back to the
IHA, the housing authority often incurs a large and unexpected
rehabilitation cost before it can lease the unit to another family.
Figure 5 shows the effects of vandalism at the Gila River Indian
Reservation.
Figure 5: Effects of Vandalism
at the Gila River Indian
Reservation, Arizona
(See figure in printed
edition.)
The high level of unpaid rent among assisted Native American families
has exacerbated the problem of accomplishing needed maintenance.
Routine and preventive maintenance is an operating expense that an
IHA pays for with rental income and an operating subsidy that HUD
provides to help defray expenses. However, according to HUD,
appropriations for these subsidies have not been sufficient to cover
all operating expenses not covered by rental income. Therefore,
shortfalls in rental income will generally result in less funds to
spend on maintenance.
In recent years, these shortfalls have been at high levels for both
the Rental Housing and the Mutual Help programs. For example, the
Urban Institute reported that at the end of 1993, 36 percent of all
tenants in the rental program were delinquent in their rent payments,
and the cumulative accounts receivable for tenants' rent averaged
$208 per rentable unit. In contrast, the average delinquency rate in
public housing is only 12 percent.
To counter shortfalls in rental income, some IHAs enforce strong
eviction policies. Others, on the other hand, are either unwilling
or unable to do so. They attributed their ineffective policies to
such factors as tribal court systems that do not support evictions,
the conflict of such policies with tribal culture, and their own lack
of forceful management. Regardless of the reason, these shortfalls
coupled with insufficient operating subsidies likely will lead to
deferred maintenance and higher costs for major repairs in the
future.
NATIVE AMERICAN HOUSING
ASSISTANCE AND SELF-
DETERMINATION ACT OF 1996 COULD
INITIALLY INCREASE HUD'S
WORKLOAD
------------------------------------------------------------ Letter :5
By establishing a block grant mechanism to replace all housing
assistance that tribes currently receive indirectly through their
IHAs and HUD--except for the funding set aside for Native Americans
in the Community Development Block Grant Program--the act allows
greater discretion for tribes to address their housing needs.
Moreover, block grants will ensure that Indian housing is separate
from public housing not only administratively in HUD's line
organization--as the 1988 legislation accomplished--but also
financially.
The new statute stipulates that tribes will not receive less housing
assistance under the new law than they did in fiscal year 1996 for
the modernization of existing rental housing and operating subsidies
to pay for expenses not covered by rental income.\8 Among other
provisions, the new statute also provides the following:
-- The existing housing authority or some other entity designated
by a tribe must administer the block grant funds and develop
1-year and 5-year housing plans for HUD's approval. The 1-year
plan must present (1) a statement of housing needs, (2) the
financial resources available to the tribe, and (3) a
description of how the available funds will be used to leverage
additional resources.
-- In distributing the block grants, HUD shall consider, among
other factors, (1) the number of low-income housing units that a
tribe already owns or operates, (2) the extent of poverty and
economic distress and the number of Native American families,
and (3) other objectively measurable conditions specified by HUD
and the tribe. These conditions could include the relative
affluence and other sources of income, if known, of the tribe.
-- The Secretary of HUD shall monitor block grant recipients--who
must submit performance reports to the Secretary--for compliance
with the law and take corrective actions when a tribe or its
housing entities do not comply with the program's requirements.
-- A tribe can pledge future grant funds to secure a guaranteed
loan and can lease land held in trust for up to 50 years.
The new act could, at least initially, cause HUD's oversight workload
to increase. One reason for this is that the number of entities
receiving funding will likely rise: Under current law, HUD funds
only 189 IHAs, while under the new law, HUD may have to fund all 550
tribes independently. Both HUD and IHA officials we contacted
believe that tribes will abandon some "umbrella" IHAs--those that
serve more than one tribe--that have not performed well. And some
tribes will simply choose to manage their own housing assistance
programs.
HUD's Deputy Assistant Secretary for Native American Programs
believes that new requirements needing oversight, such as the housing
plans, and tribes' new opportunities, such as the borrowing program
and ability to lease land for up to 50 years, will put added pressure
on HUD's field offices to work closely with the grant recipients. He
said that during the first years after the new act is in effect, HUD
will need to monitor all tribes or housing entities to determine
their initial understanding of and compliance with the new statute
and its provisions.
Other HUD officials and Indian housing officials we contacted at two
IHAs generally viewed the new legislation positively and said that
the most attractive feature of the act is the new flexibility it
offers for developing housing. They also cited the availability of a
lease of 50 years--increased from the current 25 years--which will
provide lenders an incentive to enter into mortgage agreements with
Native Americans who lease land with the intention of building a
home. The executive director of the National American Indian Housing
Council said that the annual plans will require a kind of housing
needs assessment that heretofore has not been done. She believes,
moreover, that the new program's success will depend on the extent to
which HUD is effective in reviewing the required plans, monitoring
the tribes' implementation of the plans, and acting on potential
noncompliance.
--------------------
\8 This stipulation holds unless the total appropriation for all
assistance is less than the amount received in 1996 for modernization
and operation.
MANY TRIBES RECEIVE GAMING
REVENUES, BUT HUD DOES NOT
CONSIDER THEM DIRECTLY WHEN
DETERMINING HOUSING ASSISTANCE
------------------------------------------------------------ Letter :6
About 177, or half of the 356 federally recognized tribes in the
continental United States operated gaming facilities as of July 1996.
As we reported in August 1996,\9 our analysis of financial statements
submitted for fiscal years 1994 and 1995 by the 85 tribes that
responded by May 5, 1996, to the National Indian Gaming Commission's
(NIGC) request for information shows that Indian gaming activities
provide an additional, and in many cases significant, source of
revenues.\10 These 85 tribes operated 110 gaming facilities and
earned a total net income (after all expenses) of $1.5 billion.\11
HUD does not take these revenues into account directly as it assesses
IHAs' needs for federal housing assistance because the Department has
not obtained the financial information describing tribes' gaming
activities or financial resources. Therefore, HUD cannot relate the
revenues and assets to tribes' housing needs. Moreover, tribes'
income from gaming, as from other sources, accrues directly to the
tribes rather than the IHAs and can be used to provide a wide range
of economic assistance to tribal communities. Thus, to the extent
that gaming revenues enhance tribes' overall economic well-being, HUD
considers them indirectly in its funding allocations.
--------------------
\9 See Profile of Indian Gaming (GAO/GGD-96-148R, Aug. 20, 1996).
We are currently updating this report with an analysis of more
complete financial data.
\10 The NIGC was established under provisions of the Indian Gaming
Regulatory Act (P.L. 100-497, 102 Stat. 2467) with specified
authority over the conduct of gaming on tribal lands and the
obtaining of financial records summarizing the activities.
\11 A total of 177 tribes operated 240 gaming facilities as of July
1996, but as of May 5, 1996, only 85 had reported their financial
results to the NIGC. Expenses do not include federal income taxes
because Indian tribes are not subject to them.
FOR MANY TRIBES, GAMING
REVENUES ARE SIGNIFICANT
---------------------------------------------------------- Letter :6.1
The 85 tribes reported total revenues from their gaming facilities of
$3.8 billion, from which they derived their net revenues of $1.5
billion. Of this amount, 74 tribes received about $1.2 billion in
transfers from their gaming facilities. The Indian Gaming Regulatory
Act requires that tribes use these transferred revenues for tribal,
governmental, or charitable purposes in accordance with a revenue
allocation plan approved by BIA. The allocation plan may also
provide for the distribution of a portion of the net income directly
to individual tribal members.
Our analysis of the income transferred from facilities to the 74
tribes shows that transfers ranged from about $17,000 to over $100
million. The remaining 11 tribes did not receive transfers from
their gaming facilities. More than two-thirds of the 85 tribes
received $10 million or less from gaming. Transfers to the tribes
may not have occurred for several reasons, including a facility's not
having net income for the year-end, not having accumulated earnings
from prior years, or retaining all of the year's net income. About
$300 million was retained by the gaming facilities. Figure 6 shows
the results of our analysis of the transfers.
Figure 6: Number of Tribes
Receiving Transfers of Gaming
Income, Fiscal Years 1994-95
(See figure in printed
edition.)
Note: Eleven tribes received no transfers of gaming income.
Source: Based on the most recently filed financial statements for
gaming facilities submitted to the NIGC for either 1994 or 1995.
Our analysis of the distribution to individual tribal members shows
that BIA had approved 34 of the reported 177 tribes with gaming
facilities to distribute a portion of their net revenues directly to
tribal members. The proportion of net revenues to be distributed
ranged from 2 percent to 69 percent.
HUD IS NOT REQUIRED AND
LACKS THE DATA TO TAKE
GAMING REVENUES DIRECTLY
INTO ACCOUNT
---------------------------------------------------------- Letter :6.2
For the most part, housing needs are the primary factor that HUD is
required to consider when allocating funds to IHAs for housing
programs. And tribes' economic well-being, to the extent that HUD
can determine it, is the deciding factor when allocating community
development funding to them. HUD provides this funding to IHAs on
the basis of projected operating expenses or applications for grant
funds that demonstrate housing needs in accordance with a specified
formula used to allocate funding across all housing authorities. By
regulation, HUD also awards new housing development funds to IHAs
through a competitive process based on factors such as housing needs,
the length of time since last funding award, occupancy levels of
existing units, and the current mix and status of units under
construction.
For community development programs--such as the Community Development
Block Grant Program and the HOME Investment Partnership Program--HUD
provides funding directly to tribes instead of to IHAs. For these
programs, HUD officials explained that tribes compete for these funds
on the basis of the number of low-income persons needing assistance.
According to HUD officials, tribes that generate significant income
from tribal businesses (including gaming) generally do not have a
large enough number of low-income persons and, therefore, do not rank
high enough to receive funds in these programs. The household income
of low- and moderate-income beneficiaries of funds from the Community
Development Block Grant Program, for example, generally must not
exceed 80 percent of the median income for the area. In reporting
these income levels to HUD, the applicants are required to identify
distributions, if any, of tribal income (from gaming or other
sources) to families, households, and individuals.
The Deputy Assistant Secretary told us that none of these funding
criteria requires HUD to consider the specific amount and use of
revenues that tribes receive from gaming or other sources. However,
we believe that such information could be available to HUD if the
Department took the necessary actions to obtain it.
UNDER BLOCK GRANTS, HUD
COULD COMPARE HOUSING NEEDS
WITH BUSINESS REVENUES IF
THEY WERE KNOWN
---------------------------------------------------------- Letter :6.3
The Native American Housing Assistance and Self-Determination Act of
1996 does not specifically require HUD to take gaming or other
revenues into account for funding purposes. Nevertheless, the act
requires HUD to develop a housing assistance allocation formula that
reflects the housing needs of Indian tribes and is based on (1) the
number of low-income units owned or operated pursuant to a contract
between the Department and IHAs; (2) the extent of poverty and
economic distress within tribal areas; and (3) other objectively
measurable conditions specified by HUD, which, we believe, could
include business revenues.
HUD's Deputy Assistant Secretary for Native American Programs told us
that if HUD is required or chooses to use a tribe's gaming revenues
to offset its need for housing assistance, then certain other
information also would need to be known and factored into the funding
allocation decision. For example, consistent treatment of all tribes
would require that HUD also know the amounts of significant tribal
revenues from other sources, such as land leases and mineral rights
sales, as well as from other federal programs that assist Native
Americans.
AGENCY COMMENTS
------------------------------------------------------------ Letter :7
We provided a draft this report to HUD, the National American Indian
Housing Council, the Gila River Indian Housing Authority, and the
Chemehuevi Housing Authority for review and comment. We discussed
the report with officials of each agency, including the Deputy
Assistant Secretary for Native American Programs and the executive
directors of the Housing Council and the two IHAs. These officials
commented that the report accurately described the results of HUD's
Indian housing programs and their special environmental and cultural
conditions.
SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :8
For information on Native American housing programs, including
funding and results and the factors that complicate HUD's delivery of
those programs, we obtained data from various sources. We reviewed
pertinent legislation, HUD's documentation on the programs, its
regulations on Indian housing, reports by its Office of Inspector
General, and reports by the Urban Institute's Center for Public
Finance and Housing. We discussed issues with officials from HUD's
headquarters Office of Native American Programs in Denver, Colorado,
and field offices in Denver, Colorado, and Phoenix, Arizona. We also
interviewed HUD's Rocky Mountain District Inspector General for Audit
and the Executive Director of the National American Indian Housing
Council. In addition, we visited the Gila River Housing Authority,
Sacaton, Arizona, and Chemehuevi IHA, Havasu Lake, California, to
meet with officials and gain a perspective of HUD's Indian housing
programs and observe the condition of housing units.
We drew from our August 1996 report on Indian gaming for information
on the extent of gaming on tribal lands, its profitability, the
revenue distribution. To determine gaming's impact on HUD's funding
allocation decisions, we reviewed the regulations governing HUD's
funding of Indian housing and we spoke with officials from HUD,
primarily HUD's Deputy Assistant Secretary for Native American
Programs.
We performed our work from August 1996 through February 1997 in
accordance with generally accepted government auditing standards.
---------------------------------------------------------- Letter :8.1
As arranged with your offices, we plan send copies of this report to
other appropriate Senate and House committees; the Secretary of HUD;
the Commissioner of Indian Affairs, BIA; and the Director, Office of
Management and Budget. We will make copies available to others on
request. Please call me at (202) 512-7631 if you or your staff have
any questions. Major contributors to this report are listed in
appendix II.
Judy A. England-Joseph
Director, Housing and Community
Development Issues
FUNDING AND RESULTS FOR MAJOR
HOUSING PROGRAMS FOR NATIVE
AMERICANS
=========================================================== Appendix I
The funding for and accomplishments of HUD's housing and community
development programs for Native Americans have been steady or
increasing in proportion to the increases in the Department of
Housing and Urban Development (HUD) appropriations over the 1986-95
decade, as discussed below.
INDIAN HOUSING DEVELOPMENT
PROGRAM IS THE PRIMARY VEHICLE
FOR FUNDING
--------------------------------------------------------- Appendix I:1
HUD's Indian Housing Development Program consists of two
components--the Rental Housing Program\1 and the Mutual Help
Program.\2 From 1961, when Native Americans first began to receive
assistance under the Housing Act of 1937, through fiscal year 1995,
HUD provided Indian housing authorities (IHA) over $5 billion (in
nominal dollars) for Indian housing programs and constructed over
82,000 units. About one-third of the construction has taken place
during the 10-year period between 1986 and 1995. As shown in the
figures below, over the 10-year period, HUD provided almost $2.4
billion to 189 IHAs specifically to develop housing for low-income
families. With these funds, the IHAs have built or planned to build
over 24,000 housing units. Sixty-five percent of these units,
15,721, were Mutual Help units and the remainder were Low-income
Rental units.
Figure I.1: Indian Housing
Development Program's Funding
for the Mutual Help and Rental
Housing Programs, Fiscal Years
1986-95
(See figure in printed
edition.)
Source: Based on data from HUD's Management Information and
Retrieval System's (MIRS) database.
Figure I.2: Indian Housing
Development Program's Housing
Units Fiscal Years 1986-95
(See figure in printed
edition.)
Source: Based on data from HUD's MIRS database.
--------------------
\1 Under the Rental Housing Program, IHAs rent housing to eligible
low-income families for a payment that is the highest of 30 percent
of the family's adjusted income, 10 percent of its annual income, or
the portion of the family's public assistance allocated specifically
for housing.
\2 Through its Mutual Help Program, HUD provides homeownership
opportunities and financial assistance to qualified low-income Native
American families to purchase--after leasing for 15 to 20
years--decent, safe, and sanitary housing of modest design.
MODERNIZATION PROGRAM ALSO
SUPPORTS IHAS' HOUSING
--------------------------------------------------------- Appendix I:2
Under its housing modernization program, HUD provides funds to IHAs
to rehabilitate properties in deteriorated physical condition and to
upgrade the management and operation of existing Indian housing
developments. HUD allocates modernization funds under both the
Comprehensive Grant Program (CGP) to IHAs that own or operate 250 or
more units and the Comprehensive Improvement Assistance Program
(CIAP) to IHAs with fewer than 250 units. Overall, since 1986,
congressional appropriations to HUD for the modernization of all
public housing have steadily increased, and IHAs have benefitted
proportionately. However, as is shown in table I.1, after HUD
implemented the CGP in fiscal year 1992, funding for CIAP declined,
and in fiscal year 1995, funding for both programs declined.
Table I.1
Funding for the Modernization Program,
Fiscal Years 1992-95
(Nominal dollars in millions)
Program FY 1992 FY 1993 FY 1994 FY 1995
---------------------- ---------- ---------- ---------- ----------
CIAP $35.3 $25.9 $25.6 $22.5
CGP 86.3 137.3 146.4 138.9
======================================================================
Total $121.6 $163.2 $172.0 $161.4
----------------------------------------------------------------------
Source: Based on data from HUD's Letter of Credit Control System's
(LOCCS) database.
OPERATING SUBSIDIES PROVIDE
FUNDS FOR IHAS' ONGOING
EXPENSES
--------------------------------------------------------- Appendix I:3
Section 9 of the United States Housing Act of 1937, as amended,
authorizes HUD to subsidize the operation of low-income public
housing projects. Because rental income may not be sufficient to
cover all the expenses incurred by a housing authority in its
operation and maintenance of rental housing, HUD provides such
subsidies to IHAs through its Performance Funding System on the basis
of their projected operating expenses. The subsidy amount for an IHA
is the difference between the projected estimate of operating costs
and an estimate of income from rents and other sources. Overall, HUD
has provided just over $500 million in operating subsidies to IHAs
for Indian housing programs between 1985 and 1995. As shown in table
I.2, since 1992 the trend in HUD's funding for operating subsidies
for the Mutual Help and Rental Housing programs has been upward, with
a sharp increase (almost 34 percent) for the latter program between
1993 and 1994. Well over 60 percent of the operating subsidy funding
HUD provided IHAs supported the Rental Housing Program.
Table I.2
IHAs' Operating Subsidies, Fiscal Years
1992-95
(Nominal dollars in millions)
Indian housing program needing
operating subsidy FY 1992 FY 1993 FY 1994 FY 1995
------------------------------ -------- -------- -------- --------
Mutual Help Program $9.0 $10.0 $15.0 $17.0
Rental Housing Program 37.0 41.0 55.0 54.0
Turn Key III Program\a 0.7 0.5 1.5 0.4
======================================================================
Total $46.7 $51.5 $71.5 $71.4
----------------------------------------------------------------------
\a The Turn Key III Program is the management component for "Turn
Key" units and provides homeownership opportunities for low-income
families using a lease purchase arrangement. HUD has not funded the
development of "Turn Key" housing units since 1979.
Source: Based on data from HUD's LOCCS database.
LOAN GUARANTEE PROGRAM IS
ANOTHER SOURCE OF FUNDING
--------------------------------------------------------- Appendix I:4
Section 184 of the Housing and Community Development Act of 1992
authorized the Indian Home Loan Guarantee Program to give Indian
families and IHAs access to sources of private financing that might
otherwise not be available without a federal guarantee. HUD uses the
funds to guarantee loans for constructing, acquiring, or
rehabilitating one to four family dwellings per loan. The guaranteed
loans must be for homes that are standard housing (i.e., conforming
to HUD's standards), located on Indian trust lands, or in Native
American tribal areas. The approval of guarantees is based on
applicants' having a satisfactory credit record, enough cash to close
the loan, and sufficient steady income to make monthly mortgage
payments without difficulty. During fiscal year 1995--the program's
first year of operation--HUD used the program's appropriation of $3
million to guarantee $22.5 million in home loans in tribal areas.
This funding guaranteed 74 homeownership loans for individuals and
403 loans administered by IHAs, with the loans ranging from a low of
$21,000 to a high of $175,000.
HOME INVESTMENT PARTNERSHIP
PROGRAM DEVELOPS AFFORDABLE
HOUSING
--------------------------------------------------------- Appendix I:5
The National Affordable Housing Act of 1990 created HUD's HOME
Investment Partnership to expand the supply of decent and safe
affordable housing. HUD awards HOME funds competitively to federally
recognized Indian tribes and Alaska Native villages. These
governments, in turn, make loans or grants for rehabilitating,
acquiring, or newly constructing both owner-occupied and rental
housing. Recipients must have a low income (an adjusted family
income must be 80 percent or less of the area's median income), and
in the case of rental housing, some tenants must have very low income
(50 percent or less of the area's median income). The HOME program
first became available to Native Americans in 1992. Since then,
under the program HUD has awarded a total of $51 million to Indian
tribes, resulting in 560 new units constructed, 1,400 units
rehabilitated, and 178 existing units purchased.
INDIAN COMMUNITY DEVELOPMENT
BLOCK GRANT PROGRAM PROVIDES
NEEDED FUNDS
--------------------------------------------------------- Appendix I:6
In 1978, HUD began providing IHAs with Indian Community Development
Block Grants as a set-aside\3 in the overall Community Development
Block Grant for cities and towns across the country. The block grant
program's objective is to help IHAs and tribes develop viable
communities that include decent housing, suitable living
environments, and economic opportunities--primarily for persons of
low and moderate income. HUD's regulations provide for two
categories of grants, "imminent threat grants" and "single-purpose
grants." For the first type, the HUD Secretary can set aside up to 5
percent of each year's allocation for noncompetitive, first-come,
first-served grants to eliminate problems that pose an imminent
threat to public health and safety. The second type, single-purpose
grants, constitutes the remainder of the funding; HUD provides these
grants on the basis of annual competition governed by requirements
and criteria set forth in a "notice of funds availability" published
in the Federal Register.
As funding for the total Community Development Block Grant Program
has increased, so has the amount set aside for Native Americans.
This amount has grown in real terms from $36 million in fiscal year
1986 to $46 million in fiscal year 1995.
Table I.3
Funding for Indian Community Development
Block Grants, Fiscal Years 1986-95
(Constant 1995 dollars in millions)
Fiscal year Amount
---------------------------------------- ----------------------------
1986 $36.1
1987 35.0
1988 32.0
1989 32.5
1990 30.3
1991 34.8
1992 36.5
1993 41.9
1994 45.1
1995 46.0
======================================================================
Total $370.2
----------------------------------------------------------------------
Source: Based on data from HUD's LOCCS database.
For fiscal year 1995, the set-aside for grants addressing imminent
threats was $1.5 million, with $44.5 million remaining for
single-purpose grants.
Nationally, HUD received 217 applications from tribes/tribal
organizations for 267 separate projects in 1995. As shown in table
I.4, of those approved, the most requested projects were for
infrastructure and buildings--accounting for about 87 percent of all
the projects approved and funded. The three types of projects that
directly address housing--new development, rehabilitation, and land
to support new housing--received a very small portion of the funding:
$5 million, or about 13 percent, of the grant funds approved.
Table I.4
Types of Projects Funded With Indian
Community Development Block Grants,
Fiscal Year 1995
(Dollars in millions)
Number
Type of project approved Amount funded
-------------------------------------- -------------- --------------
Infrastructure 37 $15
Non-housing building 50 20
New housing development 0 0
Housing rehabilitation 8 3
Land for housing 6 2
======================================================================
Total 101 $40
----------------------------------------------------------------------
Source: Based on data from HUD's LOCCS database.
--------------------
\3 Before 1990, the allocation of Indian Community Development Block
Grant funds was generally at the discretion of the Secretary of HUD
and represented 1 percent of the total Community Development Block
Grant. As part of the amendments to the Housing and Community
Development Act of 1974 in the National Affordable Housing Act of
1990, the 1-percent ratio became a requirement.
MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix II
RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION
Lawrence J. Dyckman, Associate Director
Eric A. Marts, Assistant Director
Leslie A. Smith
Luis Escalante, Jr.
Willie D. Watson
*** End of document. ***