rebidding. Publication of prototypes in June (as is usually the case) each year means that IHA's find themselves in the middle of the construction season.

And finally, the Farmers Home Administration should modify regulations so their programs can be made available to Indians.

RECOMMENDATIONS

1. That Congress and the Office of Management and Budget continue to support not less than 6,000 units of Indian Housing per year until inventory supports near "saturation" level.

2. That the Senate Select Committee request the Denver Region VIII HUD Office of Indian Programs to reconsider Northern Cheyenne Housing Authority's status for immediate release of units.

3. That HUD, Congress and OMB provide for In-Service Training for Indian Housing Authority Commissioners and Staff and that it must be regular and periodic. Occasional workshops and annual conferences are not adequate to the need. Most operating budgets do not allow for reasonably comprehensive training programs.

4. HUD shall work out a mechanism with DOL whereby separate wage rates based on data supplied by the Tribe or the Housing Authority would be established for each area with a long-term solution of workable apprenticeship and training programs for Indian Reservations. Or to eliminate the imposition of the act entirely.

5. That HUD will publish prototypes twice each year for Indian areas, more specifically, reflecting the Department of Energy's new construction standards "Building Energy Performance Standards" limiting the amount of energy that can be consumed within a given structure.

6. That 701 Comprehensive Planning grants will be made available to Indian Tribes and not competition with off-reservation organizations.

7. And finally, that the Farmers Home Administration be requested to revise their federal regulations on assisted programs to overcome barriers now prohibiting Indians on reservations from participating in those programs. Those programs could then serve the upper low-income and moderate income Indian families. It is not enough just to include the words "and Indian groups, bands, Tribes," regulations must be changed to make it possible that such programs can be utilized.

Again, thank you for your consideration of these comments and requests.

The Office of Indian Programs (CP), in the near future, will
allocate housing resources to Indian Tribes in Region VIII.
Before the actual allocation can be made to housing authorities,
the Regional Office must receive its funding authorization for
this fiscal ---

introduction

An application for housing shall not be approved unless HUD deter-
mines that the Indian Housing Authority (IHA) has, or will achieve
within a reasonable time prescribed by HUD, the capability to
provide adequate administration in compliance when all applicable
HUD requirements. Generally stated, as a minimum, the IHA shall
have the capability to comply with all HUD requirements for:

the prompt collection of rents and required homebuyer
payments

the prompt processing of evictions in cases of nonpayment

or other serious breach of a lease or homebuyer agreemen

the prompt completion of development

the proper handling of funds

the maintenance of complete and accurate books of accounts
and records

the timely preparation and submission e reports

- determination of rents and required houyer payments

- occupancy of housing units

maintenance of property

2

In allocating housing resources, the Office of Indian Programs will utilize the following strategy. To determine the allocation to each housing authority, four factors will be used in determining the housing need and administrative capacity of each IHA.

Factor 1 - Market and Housing Demand

Each IHA issued a Program Reservation must have an adequate market and demand for the number and type of units allocated. In arriving at an allocation of units for an IHA, a termination will be made that:

a.

There are a sufficient number of eligible families who are
ready, willing and able to occupy the number, size and type
of units allocated.

----b. - Twenty percent of the project(s) will be occupied by families whose incomes do not exceed fifty percent of the median income.

C.

The number of units proposed for each location is based on the
preference indicated by families on their application.

d. The number of families who can afford to pay the administrative charge plus utilities adequately justifies the number of Hutual Help units allocated.

Each IHA in this category will be allocated units inmediat.ly
and unconditionally.

b. Total TARS at December 31, 1979 (10 - 500 percent of monthly
charges)

Each IHA in this category will be alloca,d units immediately
Before the IHAs in this category are alleated units..

> Fsical Year 1931, the level of TARS at Dember 31, 1979, must
be reduced by 10 percent. Collection of elinquent accounts
from IHA employees, board members and Tral Council membe:
should be given first priority.

3

Total TARS at December 31, 1979 (500 1000 percent of monthly charges)

Each IHA in this category must reduce the level of TARS at
December 31, 1979, by 20 percent on or before July 31, 1980,
before an allocation will be made to that IHA. If the
reduction of 20 percent is not met, no housing units will be
allocated to the IHA. Collection of delinquent accounts from
IHA employees, board members and Tribal Council members should
be given first priority.

d. Total TARS at December 31, 1979 (1000+ percent of monthly
charges)

.

Each A in this category must reduce the level of TARS at December 31, 1979, by 33 percent on or before July 31, 1980, before an allocation will be made to that IHA.

If the

reduction of 33 percent is not met, no housing units will be allocated to the IHA. Collection of delinquent accounts from IHA employees, board members and Tribal Council members should be given first priority.

Factor 3- Construction Progress

For each IHA, the following two elements will be considered before an allocation is made:

a. At the time of proposed reservation, if two or more projects
are substantially beyond the contract completion date
no housing units will be allocated to the IHA, for if

b.

At the time of proposed reservation two or more projects have
needed ACC Amendments in the last year, in order to complete
the projects, no housing units will be allocated to the IHA
(this does not apply to projs ended before the start of
construction.)

Factor 4 - Audit Findings

For each HA, the following factor will be considered before an allocation is made:

At the time of proposed reservation, if two or more serious audit findings are outstanding, no housing units will be allocated to the IHA. A sericus audit finding is defined as a major deficiency in one or more of the areas of dministrative capability outlined in Section 805.207 of the Indian Housing Regulations-thatimmediate corrective action to comply with_wm ennyis·

Immediately upon Regional Office receipt of its Fiscal Year 1980 Funding Authorization, each IHA will be notified, in writing, of its status with regard to this housing allocation strategy. In addition, each IHA will be notified, by letter, of the specific deficiencies identified from the housing strategy which need corrective action. This letter will also contain recommendations on corrective action which the IHA may take to resolve the issue.

For each IHA not meeting the above requirements for administrative capability, specific plans to provide technical assistance to those. IHAs will be developed by March 31, 1960. These plans for OIP assistance to the IHA will be developed in consultation with the affected IHA.