RECOMMENDATIONS Based on the findings and analysis above, the following recommendations proposed for (1) The Department of Housing & Urban Development and (2) Pueblo TDHE in New Mexico.
The Department of Housing & Urban Development Recommendations:
I. STRENGTHEN NAHASDA NON-COMPETITIVE BLOCK GRANT FUNDING The funding capacity for NAHASDA non-competitive block grants must be strengthened and take into consideration the rise in construction cost and inflation rate today. Without proper funding support, TDHEs are not able to provide adequate housing support to tribal members. Although in 2019, HUD has attempted to offer competitive-IHBG funding as a means for TDHEs to acquire upwards at max $5 million USD. The competitive-IHBG allocation cycle is sporadic and applying is a time-consuming process in itself. Thus far less than 9% of 574 tribes have been awarded funds. In lieu of uplifting the competitive-IHBG; I propose HUD allocates at minimum $1,229,775,847 to noncompetitive IHBG funds for 2021 and makes a valid effort to adjust funds annually to keep pace with construction material cost and inflation.
II. ELIMINATE MAXIMUM RENT LEVELS CAPS FOR IHBG PROJECTS Pueblo TDHEs are developed to primarily serve low income households on tribal land. According to HUD guidelines, any IHBG funded project has a rent cap of 30% of a household’s income and households who fall under the national or county 80% AMI are eligible for IHBG projects. The only expectation to this rule is if a TDHE provides housing to a higher income essential worker, such as a police officer or firefighter, in which they must get approved by HUD. I propose HUD seeks to offer tribes and TDHEs more self-determination in providing housing services to middle/high income tribal households who currently are not eligible for IHBG units. By permitting TDHEs to allocate at least 30% of IHBG funds to provide housing to middle/higher income households. TDHEs will be able to develop housing for households who might opt to relocate off tribal land to find built housing in surrounding cities in lieu of building new on tribal land. Lastly servicing middle/higher income households will enable TDHEs to generate more revenue collected through rent or mortgage payments that can be saved or utilized for maintenance or infrastructure development projects.
III. MAKE ACCESS TO INNOVATIVE APPROACHES TO HOUSING DEVELOPMENT MORE ACCESSIBLE TO TDHE Create an online database featuring tribal housing development categorized by sections such as cultural development, in-house financing, LIHTC, building construction by type, cost, and more, that TDHEs can access online. For featured innovative projects, I propose financially compensating respected TDHE staff to travel and present their work to other tribes and/ 63
