Archived - Evaluation of INAC's On-Reserve Housing Support

Date: February 2011
Project Number: 1570-7/07068

Evaluation, Performance Measurement, and
Review Branch Audit and Evaluation Sector

Table of Contents

• List of Acronyms
• Glossary of Selected Terms
• Executive Summary
• Management Response/Action Plan
• 1. Overview
• 2. Program Description
• 3. Evaluation Methodology
• 4. Evaluation Findings - Relevance
• 5. Evaluation Findings - Performance (Results/Success)
• 6. Evaluation Findings - Design and Delivery
• 7. Evaluation Findings - Cost-Effectiveness and Efficiency
• 8. Evaluation Findings - Other Evaluation Issues
• 9. Future Research Considerations
• 10. Conclusions and Recommendations
• Appendix A - Terms of Reference
• Appendix B - Evaluation Matrix

List of Acronyms

Glossary of Selected Terms

Aboriginal Identity Population
The Aboriginal identity population is composed of those persons who identified to Statistics Canada that they identified with at least one Aboriginal group, that is, North American Indian, Métis or Inuit, and/or those who reported being a Treaty Indian or a Registered Indian, as defined by the Indian Act of Canada, and/or who reported that they were members of an Indian band or First Nation.

Adequate On-reserve Housing Units
An adequate housing unit is defined as one that does not require major renovations or replacement and which does possess basic plumbing facilities, specifically, hot and cold running water, inside toilets and installed baths or showers. Note: The calculation of "adequate" housing is based on the formula: Adequate = Total Units – Replacement Required – Major Renovations Required.

Band
A band is a group of Indians for whose collective use and benefit lands have been set apart or money is held by the Crown, or it is a group of Indians declared to be a band for the purposes of the Indian Act. Each band has its own governing band council, usually consisting of one chief and several councillors. Community members choose the chief and councillors by election or sometimes through custom. The members of a band generally share common values, traditions, language and practices rooted in their ancestral heritage. Today, many bands prefer to be known as First Nations.

Community Well-being Index (CWB)
Community Well-being is a composite index based on selected indicators from the Canadian Census. The score for each of the composite indicators (income, education, housing and labour) is out of 100 and the total score is the sum of all composite indicators divided by 4.

CWB Scores are determined using the following formulae:

• CWB Income = {Log(income per capita) – [Log(2000) / Log(40000) – Log(2000)]}
• CWB Education = {(2/3 x Proportion of population 20 and over with at least a high school diploma) + (1/3 x Proportion of population 25 and over with at least a Bachelor's degree)}
• CWB Housing = {[(1 – Proportion of people living in dwellings with more than one person per room) + (1 – proportion of people living in houses in need of major repair)] / 2}
• CWB Labour = {[(Employment Rate among those 20-65) + (Labour Force Participation Rate among those 20-65)] / 2}

Crowded
Statistics Canada defines a household as crowded when there is more than one person per room.

Economic Family
For the Canadian Census, this refers to a group of two or more persons who live in the same dwelling and are related to each other by blood, marriage, common-law or adoption.& A couple may be of opposite or same sex. For 2006, foster children are included.

First Nation Direct
Key informant interviews were conducted with several groups, including First Nations representatives who live and work in First Nation communities and have direct responsibility for housing on-reserve. Their views are identified as "First Nation, Direct."

First Nation High Level
Key informant interviews were conducted with several groups, including some First Nations representatives who work with provincial/territorial organizations or tribal councils, which have regional responsibilities. Their view is identified as "First Nations, High Level."

Geo-zone
A geo-zone is the distance a First Nations Band would have to travel to reach a service centre, that is a place where community members can gain access to government services, banks and suppliers): Zone 1: within 50km; year-round access; Zone 2: within 50-350km; year round access; Zone 3: within over 350km; year-round access; and zone 4: varying distances without year-round access.

Housing Authorities
Housing Authorities are administrative bodies on a reserve, which are responsible for managing the planning, forecasting and day-to-day operations around housing. They are usually responsible for making recommendations to the chief and council on new or revised housing policies, programs and plans. On some reserves, they may also take responsibility for assuring that Shelter Allowance funds are applied to utility bills and mortgages held on rental units built under Canada Mortgage and Housing Corporation's (CMHC) Section 95.

Local Operational Control
Local operational control refers to a band's ability to exercise management over all aspects of housing locally within the community or within region of a community's tribal council. To be given local operational control, communities need to develop knowledge and expertise about housing as well as have a proven record of sound project management and good governance.

Lot Servicing
To service a lot means to ensure the provision of piped water and sewer services from the lot line to the house. Lot servicing can also include the provision of individual wells and septic systems where housing densities are not sufficient to warrant piped systems. Consideration may also be given to include the extension of roads. A lot must be serviced in order to be eligible for CMHC Section 95 funding.

Minor Repairs
INAC considers minor repairs to include the repair of missing or loose floor tiles, bricks or shingles, defective steps, railing or siding, and the like.

Major Repairs
Major repairs refer to the repair of defective plumbing or electrical wiring, structural repairs to walls, floors or ceilings and the like.

New Unit Production
The total number of houses constructed over time and/or the average number of houses constructed per community are referred to as new unit production.

Occupied Dwelling Characteristics
The Canada Mortgage and Housing Corporation definition of an Aboriginal household has been used for the household and occupied private dwelling characteristics for the Aboriginal identity population. An Aboriginal household is defined by CMHC as one of the following:

1. a non-family household in which at least 50 percent of household members self-identified as Aboriginal; or
2. a family household that meets at least one of two criteria:
   
   
   • at least one spouse, common-law partner, or lone-parent self-identified as an Aboriginal; or
   • at least 50 percent of household members self-identified as Aboriginal.

Private Dwellings
For the 2006 Census, Statistics Canada defines a private dwelling as: living quarters designed for or converted for human habitation in which a person or group of persons reside or could reside. In addition, a private dwelling must have a source of heat or power and must be an enclosed space that provides shelter from the elements, as evidenced by complete and enclosed walls and roof and by doors and windows that provide protection from wind, rain and snow.

Registered or Treaty Indian
The expression 'Registered Indian' refers to those persons who reported they were registered under the Indian Act of Canada. Treaty Indians are persons who are registered under the Indian Act of Canada and can prove descent from a band that signed a treaty. The Registered Indian counts may differ from administrative counts maintained by Indian and Northern Affairs Canada, because some Indian reserves and settlements were incompletely enumerated as well as methodological and conceptual differences between the two sources.

Rooms per Dwelling
A room is an enclosed area within a dwelling, which is finished and suitable for year-round living (e.g., kitchen, dining-room, or bedroom). Bathrooms, halls, vestibules and rooms used solely for business purposes are not counted as rooms.

Third party management
Third party management refers to a scenario where a third-party manager is appointed by INAC when a First Nation's finances are in disarray, the First Nation is unable to comply with condition attached to INAC funding agreements and/or when an auditor raises significant concerns when deficits are very high.

Executive Summary

The purpose of this evaluation was to review the impact of INAC's On-Reserve Housing Support Program and related policies and processes on the state of on-reserve housing from the implementation of the new housing policy covering a study period of 1996 to 2009-10. The evaluation was required as part of the Transfer Payment Policy to support the renewal of INAC's Capital Facilities and Maintenance authorities associated with the on-reserve housing policy in 2010. Note that this evaluation does not cover funds distributed as part of Canada's Economic Action Plan (CEAP), as the evaluation was carried out before impacts resulting from CEAP could be validly assessed.

Since its inception in 1960, the purpose of the On-Reserve Housing Support Program and related policies and processes has been to provide financial and other support to First Nations for safe and affordable on-reserve housing, which is at a comparable standard to that enjoyed by other Canadians. The Government of Canada's support for housing on-reserve is provided through Indian and Northern Affairs Canada (INAC) and the Canada Mortgage and Housing Corporation (CMHC). The Government of Canada invests approximately $272 million per year to assist First Nations in meeting on-reserve housing needs. INAC's CFM program receives $138 million of this funding; CMHC receives $134 million. In the 2005 federal budget, a further $295 million was approved to be spent over a five year period. Of this $295 million, $192 million was allocated to INAC for new construction, lot servicing and renovation.

The evaluation was initiated in 2008 by the Evaluation, Performance Measurement and Review Branch (EPMRB) and was initially intended to be a joint evaluation with CMHC. In December 2009, due to resource constraints, CMHC withdrew from joint participation in order to proceed with gathering information necessary to report to the Treasury Board on specific questions regarding Budget 2005 investments. Therefore, the scope of this study was reduced and officially covers only INAC housing-related programming.

The methodology for the evaluation, as approved by the Evaluation, Performance Measurement and Review Committee, utilized multiple lines of evidence, including primary data sources such as key informant interviews and case studies and secondary data such as a literature review and a review of administrative and statistical data. The evaluations of the Ministerial Loan Guarantees Program and the Shelter Allowance Program also served to inform this study.

The evaluation was undertaken by EPMRB, which prepared the Terms of Reference and draft final report, in collaboration with a number of consulting firms. Donna Cona undertook a literature review and case studies. T.K. Gussman Associates Inc., in association with the consulting firm DPRA, conducted key informant interviews. KPMG provided evaluations of the Ministerial Loan Guarantee Program (MLG) and the Shelter Allowance Program as it relates to on-reserve housing. A.J. Doxtdator and Associates undertook a post hoc analysis of the condition assessments of a selection of on-reserve housing units carried out for the case studies. The final evaluation report was prepared by Karen Ginsberg Management Consulting Inc.

Key findings and conclusions from the evaluation are as follows:

Relevance

There is a continued need for federal support to on-reserve housing. There is an existing shortfall in housing and an ongoing concern for future shortfalls given the conditions of housing on-reserve and projected population growth over the next 25 years. The commitment to fund on-reserve housing aligns well to broad government commitments and to the priorities of INAC.

At the outset of the introduction of the 1996 On-Reserve Housing Policy, there was a consensus between the government and First Nations that there was already a shortfall of adequate housing on–reserve. Despite ongoing construction of new housing on-reserve, the shortfall still exists and appears to be growing rather than diminishing. Overcrowding is also very much a reality on-reserve. Even though the proportion of houses which are "overcrowded" has been reduced by one third in the 13 year time frame, it is still six times higher than that of non-Aboriginal Canadians.

With an existing backlog and a forecasted rise in population, more adequate housing units are required in the future. New needs are being generated as quickly as the housing can be built.

The broad consensus is that the current On-Reserve Housing Policy is in alignment with Government of Canada objectives and the objectives of INAC. However, many stakeholders reiterated what had been stated in the 2003 OAG Progress Report - that the specific roles and responsibilities of each of INAC and CMHC were unclear and called on the organizations to bring greater clarity to their working arrangements and communicate them to First Nations. According to the 2006 OAG Progress Report, INAC and CMHC, in collaboration with the Assembly of First Nations and regional First Nations organizations, have jointly developed a management control framework that defines their respective roles and responsibilities for addressing housing shortages on reserves. Thus, in its assessment of progress, the progress report indicated that this recommendation had been fully implemented. However, all interviewee groups stated that the specific roles and responsibilities of both INAC and CMHC were unclear.

Performance

The number of units built and repaired relative to targets for spending Budget 2005 funds has been very positive. However, population growth and the demand for housing is outstripping the speed with which new housing units can be produced and existing ones repaired. There have been absolute gains in the numbers of lots, which are serviced and "shovel ready." However, there has been limited success with respect to absolute gains in housing stock relative to need.

Housing units on-reserve are not being well-maintained. Most First Nations leaders feel that there is insufficient funding to get ahead of the curve of need. As quickly as new units come on stream, they require aggressive maintenance because of the overcrowding and heavy "wear and tear" they take. There is not yet sufficient capacity within First Nations communities to do the maintenance, and limited personal funds with which to pay for someone else to do the work. The consequences are manifold: maintaining housing stock is costly, poorly maintained housing is unsafe and contributes to poor health, which in itself generates additional costs.

Interviewees from all groups stated that there has not been a clear articulation of roles and responsibilities by INAC or CMHC and as a result there has been ongoing confusion about the roles and responsibilities regarding on-reserve housing, especially among First Nations. Moreover, there is no shared understanding or acceptance of what shared responsibility means for the management of on-reserve housing. Notwithstanding this, all interviewees recognised that local control is a critical success factor for the future of on-reserve housing. INAC and CMHC are supporting these efforts by researching best practices.

With respect to accountability, a recent audit of the on-reserve housing program identified opportunities to strengthen governance over housing in the areas of program design, performance management, risk management and guidance.

Thirteen years after the introduction of the policy, First Nations are still asking for help to build capacity. There is little evidence that the efforts of INAC have yet yielded positive results in this regard. The evaluation found no evidence of a strategic and coordinated approach to capacity building on the part of INAC and CMHC.

Design and Delivery

Since the housing subsidy program began in the mid-1960s, there were no significant changes to the program until the introduction of a new housing policy in 1996. The 1996 policy was communicated to First Nations by means of the National Housing Procedures Guide document. The key feature of the policy was that First Nations that opted into it could have greater flexibility in how they spent housing funds. At the start-up, First Nations received one-time funding for initial costs but little in the way of guidance and capacity-building.

The design of the 1996 On-Reserve Housing Policy and its resultant programs did not adequately incorporate a First Nations' perspective and was poorly communicated to First Nations. There was no consensus in 1996, and none exists yet amongst stakeholders, as to the meaning of the key tenet of the policy – shared responsibility. Moreover, the ensuing lack of support for adequate capacity–building has meant that the design was inherently flawed. There has not yet been a strategic, coordinated plan between the INAC and CMHC, with First Nations, as to how to build capacity. Ongoing confusion for First Nations concerning the roles and responsibilities of INAC and CMHC further detracts from the effectiveness of the design.

First Nations who wish to consider home ownership appear able to access the Ministerial Loan Guarantees, which are often a pre-condition for purchase of a home. For other First Nations, home ownership is not an immediate priority and their challenge is to establish a fair and effective rental regimes.

The design issues which came to the forefront in the evaluation included that: First Nations do not feel that their perspectives are reflected in the policy, and that neither multiyear funding nor multiyear plans, which were essential elements in the policy, materialized.

Cost-Effectiveness and Efficiency

With very limited performance data, it has been next to impossible for this evaluation to determine the cost-effectiveness of the On-Reserve Housing Program using conventional measures. The recent audit of the On-Reserve Housing Program leaves no doubt that, with the present reporting mechanisms, there are problems around attribution and that much of the data around costs is not subject to meaningful review and challenge. As First Nations take increasing control of managing their housing, they too will have a greater interest in being able to measure cost-effectiveness. How to achieve a true analysis of cost-effectiveness is an issue, which warrants considerable attention well in advance of another evaluation of the program.

Other

Ministerial Loan Guarantees

MLGs have been well-used by a very large percentage of First Nations as one instrument that has enabled the construction of approximately 26,000 houses between 1996 and 2007. While the default rate is very low, the continued rise in the contingent liability has the potential to create cash flow problems and future borrowing limitations. While there is a strong interest amongst First Nations in exploring home ownership, the usage of MLGs appears to be heavily weighted on housing quantity outcomes with the vast majority of MLGs being used to support CMHC's Section 95 housing [Note 1].

Shelter Allowances

Shelter Allowance is an important source of funds for First Nation communities to pay for costs related to Section 95 housing, which comprise a significant portion of recent housing developments. Shelter Allowance funds are used to grow the overall housing stock but are generally not used towards repairs or maintenance. Stakeholder interviews, case study findings and historical trends indicate that Shelter Allowance is not enough to cover the rent and/or mortgage payments, as well as fuel and utility costs and repairs and maintenance. Shelter Allowance has not been able to leverage any additional funding for housing on-reserve other than the Section 95 subsidy.

Recommendations

It is recommended that INAC, working with First Nations and seeking the active involvement of CMHC and other key stakeholders:

1. Develop a policy statement building on the 1996 Policy and other On-Reserve Housing Initiatives. The policy statement should lay out clear objectives and be flexible enough in its application to ensure it meets the different types of needs in First Nation communities.
2. Support and work with First Nations to clarify and strengthen accountability and governance structures, including roles and responsibilities, performance measurement, financial management, and community housing plans.
3. Develop a strategic approach to advance capacity building initiatives in order to:
   
   
   • better manage and monitor housing stock (where possible, INAC should work with other government departments to leverage resources for First Nation capacity development);
   • advance local operational control; and
   • achieve the minimum standards of the National Building Code (e.g., quality construction, repairs and maintenance) to ensure long-lasting and environmentally sustainable units.
4. Support and work with First Nations to ensure houses are built to address overcrowding and deterioration and to maximise the use of resources bearing in mind current and future pressures on housing stock.
5. Undertake research, in partnership with First Nations and CMHC, to identify:
   
   
   • cost-effective design options for on-reserve housing construction and renovation;
   • the impact of demographic trends on the needs for on-reserve housing;
   • options for effective management of on-reserve housing portfolios; and
   • options for effective governance of on-reserve housing.

Management Response/Action Plan

Project Title: Evaluation of INAC's On-Reserve Housing Support - Project Number: 1570-7/07068

I recommend this Management Response and Action Plan for approval by the Evaluation, Performance Measurement and Review Committee

Original signed on February 22, 2011 by

Name: Judith Moe
Position: A/Director, Evaluation, Performance Measurement and Review Branch

I approve the above Management Response and Action Plan

Original signed on February 22, 2011 by

Name: Gina Wilson
Position: Senior Assistant Deputy Minister, Regional Operations Sector

The Management Response / Action Plan for the Evaluation of INAC's On-Reserve Housing Support were approved by the Evaluation, Performance Measurement and Review Committee on February 22, 2011.

1. Overview

This document constitutes the final report of the evaluation of Indian and Northern Affairs Canada's (INAC) On-Reserve Housing Support Program. The final reports of the evaluations of Shelter Allowance as it relates to On-Reserve Housing, and Ministerial Loan Guarantees (MLG), will be posted alongside this report. Note that this evaluation does not cover funds distributed as part of Canada's Economic Action Plan (CEAP), as the evaluation was carried out before impacts resulting from CEAP could be validly assessed.

The primary purpose of the housing program is to provide financial and other support to First Nations for safe and affordable on-reserve housing, which is at a comparable standard enjoyed by other Canadians. The Government of Canada's support for housing on-reserve is provided through INAC and the Canada Mortgage and Housing Corporation (CMHC). Table 2.1 identifies INAC and CMHC's on-reserve housing related programs.

The Evaluation, Performance Measurement and Review Branch (EPMRB), part of the Audit and Evaluation Sector, initiated this evaluation in 2008 and the evaluation covers INAC programming over the period from 1996-97 to 2009-10. The branch undertook part of the evaluation process using both internal resources and external resources. Two different associates of the consulting firm of Donna Cona undertook a literature review and a series of case studies. T.K. Gussman Associates Inc., in association with the consulting firm DPRA, undertook key informant interviews. The consulting firm KPMG provided evaluations of the MLG and the Shelter Allowance Program as it relates to on-reserve housing. The firm A.J. Doxtdator and Associates undertook a post hoc analysis of the condition assessments of a selection of on reserve housing units. CMHC contributed various recent research relevant to the evaluation questions. The Terms of Reference and draft final report were prepared internally. The draft of the report was prepared by the firm Karen Ginsberg Management Consulting Inc. and finalised by EPMRB.

The evaluation was required as part of the Transfer Payment Policy on all direct spending and was expected to support the renewal of INAC's Capital Facilitates and Maintenance (CFM) authorities associated with the on-reserve housing policy in 2010 (see Terms of Reference, Appendix A). The report is prepared in five parts: the introduction and program profile; methodology (including scope, timing, evaluation issues, methods used); summary of findings; conclusions; and recommendations.

The evaluation was originally intended to be a joint evaluation with CMHC and the Terms of Reference of the evaluation, approved April, 25, 2008 (Appendix A), by INAC's Audit and Evaluation Committee reflect that understanding. Initial activities were undertaken in tandem with CMHC on the understanding that INAC would cover these costs upfront until CMHC gained the formal approval of their Management Committee.

There were early consultations with the Assembly of First Nations (AFN), which led to a two day workshop in November 2008 comprised of the AFN's Chiefs Committee on Housing and Infrastructure along with the supporting AFN's Technician's Committee. At its conclusion, the AFN confirmed its interest in the evaluation and in helping determine its scope. Participants also agreed to strike two committees to help guide and inform the evaluation process: 1) an Advisory Committee comprised of program and evaluation staff from INAC, CMHC, and Health Canada; members of the AFN's Housing and Infrastructure Secretariat; as well as two regional members from the AFN's Technicians' Committee and 2) a Strategic Evaluation Committee, co-chaired by the Heads of Evaluation from CMHC and INAC, and comprised of the INAC Assistant Deputy Minister, Education, Social Development Programs and Partnerships Sector; the Vice President, Policy and Planning Sector; Vice-President for Assisted Housing Sector; and the co-Chairs of the Chief's Committee on Housing and Infrastructure.

The Advisory Committee provided input into the evaluation Terms of Reference, overall approach, and methodology and interpretation of findings.

The Strategic Evaluation Committee's purpose was to enhance linkages between evaluation, policy and program development.

In a Strategic Evaluation Committee meeting in June 2009, it was decided that a phased approach to the evaluation would be implemented whereby INAC and CMHC were each to lead on selected portions. INAC began work in July 2009 on the MLG and Shelter Allowance evaluations. In September 2009, INAC commissioned the literature review and key informant interviews. In December 2009, In December 2009, due to resource constraints, CMHC withdrew from joint participation in order to proceed with gathering specific information necessary to report to the Treasury Board on questions regarding Budget 2005 investments. Therefore, the scope of this study was reduced and officially covers only INAC housing-related programming. They did, however, agree to participate on the Advisory Committee. As a consequence, the original Terms of Reference were modified to reflect that CMHC would not be a joint partner, thus reducing the scope to focus specifically on INAC's on-reserve housing activities.

2. Program Description

2.1 Background and Scope/Activities

INAC supports First Nations on-reserve housing through its On-Reserve Housing Support Program, MLG Program and Shelter Allowances Program. Responsibilityfor the management of INAC's support to on-reserve housing falls within the purview of the CFM Program of the Community Infrastructure Branch of the Education and Social Development Programs and Partnerships Sector; and the Infrastructure Operations Directorate of the Operations and Planning Support Branch, Regional Operations Sector.

In the 1960s, INAC first introduced a housing program to assist in the construction and renovation of houses on reserves. The program provided subsidies for new residential construction and the renovation and rehabilitation of existing houses.

The 1996 On-Reserve Housing Policy was introduced in order to provide greater flexibility [Note 2] and more control to First Nations over their housing policies or programs. [Note 3] The policy is based on four elements:

• First Nations control (community-based housing programs);
• First Nation expertise (capacity development);
• Shared responsibility (shelter charges and ownership options); and
• Better access to private capital (debt financing).

First Nations could opt in or out of the 1996 Housing Policy. If they opted in, they were given the flexibility to use INAC's housing funds in support of the implementation of their community-based housing plans, which could include maintenance and insurance, debt charges, training, management and/or supports to establish housing authorities. The base budget allocated to housing in 1996 was $138 million per year. During the first five years after the introduction of the policy, an estimated $160 million in additional funds were also provided to those First Nations which opted into the policy. These additional funds came from a variety of sources: Cabinet allocations to the post–Royal Commission on Aboriginal Peoples (RCAP) Gathering Strength initiatives, the program Integrity and Rust Out initiatives and later from Canada's Economic Action Plan. Generally, the supplemental allocations were to accelerate the production of new housing and major repairs and renovations.

Table 2.1: Summary of INAC and CMHC programs, which support on-reserve housing

The flexibility offered through the 1996 Housing Policy required that First Nations establish a set of housing policies, housing programs and create a multiyear housing plan. Guidelines [Note 4] were published to assist First Nations in developing these policies, programs and plans. The initial incentive for developing the plans was the additional capital funding. The incentive over the longer-term was a more flexible funding arrangement.

Those First Nations that opted out of the1996 Housing Policy, which included all of the First Nations in British Columbia and about 20 percent of those in Ontario, were required to continue to operate under the provisions of the housing subsidy program. This meant that their housing capital funding could only be used for construction, rehabilitation or renovation to be released on a project-by-project basis, rather than as a lump sum. These communities may also have been eligible for other funding for advisory services and program support related to housing management, housing planning, technical assistance, training, housing inspections, maintenance management and fire safety. However, First Nations opting into the policy after its introduction in 1996-97 were not eligible for any portion of the $160 million in supplemental funding allocated at the beginning of the policy.

Additional funding was made available for on-reserve housing in Budget 2005. These funds were administered under a separate management control framework and were proposal driven. Reporting on these funds was separate from reporting on other housing revenue received through the Housing Subsidy Program or the 1996 On-Reserve Housing Policy.

Ministerial Loan Guarantee

MLGs are used to assist First Nations in accessing loans to finance housing on reserve. Reserve lands are held by the Crown for the use and benefit of First Nations, as set out in the Indian Act. The Indian Act (section 89[1]) protects Indian property from seizure by a non-Indian. Section 89 (1) of the Indian Act effectively prevents the seizure of real property located on reserve by a lender. These restrictions pose an impediment to chief and councils, individuals, and Indian businesses seeking loan financing, such as mortgages for on-reserve projects, including housing. To address this risk to the lender, INAC issues MLGs to First Nations to enable them to secure loans for on-reserve housing. MLGs can be used to secure loans for the purpose of construction, acquisition or renovation of on-reserve housing projects. More information on the administration of MLGs is detailed in the appended evaluation report.

Shelter Allowance

Shelter allowances are paid by INAC to income assistance recipients based on financial need and rates established by provinces. The rates paid under the Shelter Allowance are based on family size and family income. Shelter allowances can be used to pay for rent, utilities on rental properties and certain other allowable shelter costs. Provincial/territorial legislation generally requires individuals on income assistance to show proof of a rental agreement to be eligible to receive a shelter allowance in addition to income assistance. This proof could include rent or receipts, billings or rental agreements. This obligation makes it necessary for First Nation communities to establish and administer rental regimes if they have community members living in band housing. The amount of rent the band charges for a rental property must be reasonable in terms of household need, size, condition of housing and prevailing community rental practice. More information on the administration of Shelter Allowance is detailed in the appended evaluation report.

CMHC Programs

CMHC's on-reserve housing programs are described in the Terms of Reference, Appendix A. The current evaluation did not officially include an examination of results related to CMHC programming.

2.2 Program Objectives and Expected Outcomes

The broad objectives of INAC's 1996 On-Reserve Housing Policy are best captured in the guidelines to the 1996 housing policy. According to those guidelines, the intended outcomes were the:

• Protection and extension of dwelling life;
• Construction of affordable new housing;
• Promotion of individual pride and responsibility; and
• The creation of effective linkage between housing activities and training, job creation and business development on a reserve.

While there is no specific logic model for the housing policy, there is a draft logic model for the CFM Program within which INAC does not specifically mention housing but does speak to improved technical capacity and reduced health and safety risks due to poor maintenance at the short- to medium-term outcome level. It also speaks to improved quality of life, improved First Nations' capacity and improved progress towards self-sufficiency and to prolonging the life cycle of assets as a long term outcome result. Questions to be posed by the evaluation were guided by the outcomes listed above.

2.3 Program Management, KeyStakeholders and Beneficiaries

2.3.1 Program Management

On-reserve housing is currently administered by two federal organizations: CMHC and INAC. Within INAC, on-reserve housing is an activity which falls within the Community Infrastructure Branch, which also includes Innovation and Partnerships; Policy, Programs and Procedures; and Strategic Initiatives. Additionally, as part of INAC's regional operations, there is an Infrastructure Operations Directorate in the Regional Operations Sector, which implements the housing program at the regional level. Table 2.1 provides a summary of the INAC and CMHC programs which support on-reserve housing. Both INAC and CMHC have regional offices. INAC's regional offices are responsible for the delivery of INAC housing program components, in accordance with Headquarters' policies, guidelines and procedures.

INAC provides funding for housing primarily through the Minor Capital funding stream of the CFM Program. Funding under this component is provided in two ways: as minor capital contribution toward First Nation housing programs under the 1996 On-Reserve Housing Policy; and through direct proposal-driven housing subsidies to First Nations that did not adopt the housing policy.

Under the 1996 Housing Policy, funds are provided to First Nations as part of their minor capital allocation, which is based mainly on a population-driven formula. There is flexibility provided for the use of funds under this policy: they can be used for construction and renovation as well as for implementation of First Nations community-based plans such as for maintenance and insurance, debt servicing, training, management and supports to establish housing authorities.

Funds are transferred to first Nations annually as part of either Comprehensive Funding Agreements (CFAs) or through the five year DIAND First Nations Funding Agreements (DFNFAs).

Under the subsidy housing program, set amounts of subsidies are provided on a project by project basis strictly for construction, rehabilitation or renovation of houses. These subsidies are not intended to cover the full cost of construction or renovation and range from $19,000 to $45,000. They are calculated using remoteness and environmental indices that are based on several factors, including construction and transportation costs and economic conditions in the community. The subsidies average approximately $6,000 per unit for renovation of existing housing.

2.3.2 Key Stakeholders and Beneficiaries

The beneficiaries of the 1996 On-Reserve Housing Policy are intended to be the First Nations who have access to the financial and other support provided through the on-reserve housing programs. They include:

• Bands/settlements (land, reserves, trusts);
• Regional, district councils and chiefs' councils;
• Tribal councils; and
• The Assembly of First Nations.

While First Nations on reserve are also stakeholders, there are others who have an interest in a well-functioning, effective and successful on-reserve housing program. They include:

• the Canadian public;
• other federal departments such as Health Canada and Human Resources and Skills Development Canada;
• various other organizations who act as advisors or suppliers to the on-reserve housing program. These include banks, which lend capital, suppliers of various kinds in the building trades sector, building trades associations, which provide expertise, training institutions, which provide training to First Nations to help build capacity in housing corporations where the major shareholder is an Indian/Innu/Inuit First Nation or person such as the Ontario First Nations Technical Services;
• regional Health Authorities to which First Nations' are referred for health problems arising from poor housing, particularly from mould and other respiratory allergens;
• beneficiaries of the James Bay Agreement & Northern Quebec Agreement;
• beneficiaries of the North Eastern Quebec Agreement; and
• other individuals or institutions who/which are eligible for on-reserve related funding.

2.4 Program Resources

The Government of Canada invests approximately $272 million per year to assist First Nations in meeting on-reserve housing needs. INAC's CFM program receives $138 million of this funding; CMHC receives $134 million. In the 2005 federal budget, a further $295 million was approved to be spent over a five year period. Of this $295 million, $192 million was allocated to INAC for new construction, lot servicing and renovation. [Note 5] While Canada's Economic Action Plan is not part of this evaluation, it should be noted that an additional $400 million has been committed through the Action Plan for First Nations on-reserve housing. INAC has been allocated $150 million for lot servicing, renovations, new construction of high density multi unit dwellings and renovations to support the conversion of band-owned housing to private ownership. [Note 6] Table 2.2 shows the amount spent by INAC on housing in each of the fiscal years between 1996-2009 and includes additional allocation for on-reserve housing announced in Budget 2009 for the years 2009-10 and 2010-2011.

Table 2.2 Program Resources

Sources include:1996/97-2000/01 Departmental Performance Reports
2001/02-2008/09 Community Infrastructure Branch
2009/10-2010/11 Budget 2009

3. Evaluation Methodology

3.1 Evaluation Scope and Timing

This evaluation examined the impacts of INAC's support to on-reserve housing during the period 1996 to 2009/10. The Evaluation, Performance Measurement and Review Committee approved the Terms of Reference for this evaluation in April 25, 2008. Field research was carried out between November 2009 and May 2010.

In terms of scope, this evaluation addressed housing authorities from 1996 to 2010 as well as the accountability requirements attached to additional funding for on-reserve housing, which was allocated to INAC in 2005. Specifically, INAC was to evaluate new housing, renovations and lot servicing paid for through the minor capital allocation, the support given to tribal councils for the purpose of providing technical support for housing and capacity building to tribal council members, the impact of Shelter Allowance and MLGs on on-reserve housing [Note 8].

The evaluation was originally intended to be carried out jointly with CMHC as noted in the discussion in Chapter 1.0 and this is reflected in the original Terms of Reference, Appendix 1. After CMHC withdrew its participation, it was able to contribute considerable recent research to support various evaluation questions. [Note 9] In addition, in the course of conducting various key informant interviews, perceptions and observations were also gathered about CMHC's on-reserve programs.

3.2 Evaluation Issues and Questions

In accordance with the Terms of Reference, the evaluation focused on the following issues:

• Relevance
  
  
  • Whether there is a continued need to support on-reserve housing?
  • Are on-reserve housing initiatives aligned with federal priorities and INAC priorities?
  • Whether there is alignment with federal roles and responsibilities?
  • Have the ways in which on-reserve housing programs and housing related initiatives been implemented affected desired outcomes?
• Results and Impact
  
  
  • Has the First Nations' housing stock improved over time?
  • Have INAC policies and programs served to protect and extend the lifespan of homes on reserve?
  • Has there been an impact on occupants' quality of life?
  • Has governance impacted on-reserve housing program outcomes?
  • Have INAC's on-reserve housing policies and programs increased community capacity to manage and administer housing?
• Design and Delivery
  
  
  • Was the design of on-reserve housing programming consistent with First Nations housing needs? Could the design of the housing programs and housing related initiatives reasonably be expected to contribute meaningfully to the desired outcomes?
• Efficiency and Economy/cost-effectiveness
  
  
  • Have INAC's on-reserve housing policies, programs and initiatives been cost-effective?
  • Have INAC's administrative systems and operational practices allowed for the efficient delivery of on-reserve housing programs and initiatives?
  • Are there alternative approaches which could achieve program outcomes more effectively?
• Other Evaluation Issues
  
  
  • To what extent and in what ways does the Shelter Allowance Program contribute to on-reserve housing? What are the lessons learned?
  • To what extent and in what ways do the MLG contribute to on-reserve housing? What are the lessons learned?

3.3 Evaluation Methodology

The evaluation's findings and conclusions are based on the analysis and triangulation of the following multiple lines of evidence (See Appendix B)

3.3.1 Primary Data Sources

Key informant interviews

TK Gussman and Associates, in conjunction with DPRA, carried out 103 of a planned 175 key informant interviews. Seventeen percent were with senior officials at INAC, CMHC or Health Canada, 47 percent were with regional officials of the same federal departments, 18 percent were with Aboriginal national or regional leaders and are, hereafter, referred to as First Nation High Level, and 13 percent were with Aboriginal community members or the direct recipients of federal funding support and are, hereafter, referred to as First Nation Direct. The objective of the interviews was to provide in-depth commentary and analysis on the relevance and impacts of current housing initiatives, the changes that have occurred since 1996 and their impacts, and the current situation from each of the different stakeholder groups' perspectives.

The Advisory Committee for this evaluation guided the choice of potential interviewees. The Committee provided contacts for potential key informants who had specific and in-depth knowledge of on-reserve housing. Two hundred and sixty potential interviewees were identified and the expectation was that at least 175 interviews would be completed. There were difficulties in reaching many prospective key informants, others who were reached, declined to be interviewed and still others that did not attend their scheduled interview. A large number of prospective and potential interviewees who declined or did not attend their scheduled interview were from First Nations. In the end, 103 interviews were conducted.

The distribution of key informant interviews among the various stakeholder groups was as follows: 18 Headquarters-based government officials, 50 regionally-based government officials, 19 First Nations organisational representatives, hereafter, referred to as First Nations Direct, and 14 First Nations individuals directly linked to the delivery of housing on reserve.

Case studies

INAC contracted the firm of Donna Cona Inc., to conduct a small series of case studies in a selection of 10 First Nations communities across Canada. [Note 10]INAC also contracted the AFN Housing and Infrastructure Division for technical support and expertise in case study development and analysis as well as to provide training to housing inspectors for a series of condition assessments, which would form one of three lines of evidence in each case study. The key objective of the case studies was to have an additional independent line of evidence that would provide a rigorous assessment of housing conditions in a selection of First Nation communities using recognized housing condition assessment tools. As well, the case studies were to capture end-user experience via a survey of the head of each of the ten households within the nine participating communities. Finally, the case studies were to provide further in-depth commentary and analysis on the relevance and impacts of current housing initiatives via key informant interviews with housing mangers or chiefs (the same key-informant interview guide as used by TK Gussman and Associates for First Nations Direct respondents). The case studies were also intended to pilot both the Condition Assessment tool and the occupant survey for potential future research on end-user experience and to identify possible improvements in the tools for validity, reliability and usability of the collected data. All the data collection, including the condition assessments, was carried out in March 2010.

At the conclusion of the physical condition survey, INAC turned the data over to A.J Doxtdator and Associates [Note 11] for a post hoc analysis. A technical summary of the data collected in the condition assessments of the selected houses, as well as Doxtdator's assessments of potential causes for deficiencies, was developed.

As a further means of broadening the types of houses selected for a condition assessment, the housing manager from each community identified three houses built between 1996 and 1999 (constructed under the Minor Capital Subsidy Policy), three built between 2000 and 2004 (constructed under the Minor Capital Subsidy Policy and three built between 2005 and present (constructed under the 2005 Housing Policy) and one house from the category containing the greatest proportion of each particular community's housing stock. In addition, the housing manager was asked to provide adequate representation of houses in good, fair and poor condition. It is important to note that the condition assessments, as part of the case studies, were not intended to be generalisable or representative of the larger population; rather they were intended to be illustrative.

Nine case studies, including nine key-informant interviews and 80 condition assessments and occupant surveys were completed. The case studies were carried out in seven provinces and included a case for both northern and southern Ontario and the northern interior of British Columbia as well as Vancouver Island.

The condition assessment tool was developed based on industry standards to gauge whether the houses in the study complied with the National Building Code and what repairs, if any, would be needed to bring the house up to compliance with the code, including estimates of the cost of doing so.

Evaluation of Shelter Allowance Program

KPMG undertook the implementation evaluation of the shelter allowance program across the country. Its purpose was to determine the extent to which the Shelter Allowance is contributing to broad on-reserve housing objectives. A document review, 40 key informant interviews (23 or 57 percent were interviews with INAC officials, five or 12 percent were with CMHC officials, nine or 22 percent were with provincial representatives and three or seven percent were with First Nations officials) and nine case studies were carried out in association with this evaluation. The purpose of the case studies was to illustrate the manner in which INAC regional offices administer the Shelter Allowance to First Nation communities. The communities selected for inclusion in the case studies reflect diversity in community size, location, housing profile and type of funding agreement. Interviews for the case studies included staff from the band's departments of housing, social assistance and finance and the chief and council.

Ministerial Loan Guarantees

KPMG undertook the evaluation of the utilization of MLG. Its purpose was to determine if the MLGs are meeting the primary policy objective of facilitating access to financing required for the construction, acquisition and/or renovation of reserve housing. The evaluation examined the relevance/rationale, design/delivery, success/impacts, and the cost –effectiveness of the MLGs. The evaluation also provided some analysis of the extent to which the MLGs are achieving a secondary objective, that of enabling and encouraging lending to individuals in support of home ownership opportunities on reserve. The evaluation research included a review of administrative data, 53 key informant interviews plus five case studies drawn from First Nations from different regions of the country which, in turn, included an additional 34 key informant interviews. Of the 53 key informant interviews, 18 or 34percent were with INAC managers, 11 or 21percent were with INAC policy and program staff, four or 7.5 percent were with CMHC mangers, three or 5.5 percent were with CMHC policy and program staff, five or nine percent were with financial institutions and 12 or 23 percent were with First Nations representatives, individuals and organizations. Data were also analysed from the INAC's Guaranteed Loan Management System regional reports. 3.3.2 Secondary Data Sources

Literature Review

The purpose of the literature review was to assess on-reserve housing literature in Canada with respect to a range of issues and to conduct a comparative review of literature from other western democracies, including New Zealand, Australia and the United States regarding the delivery of housing to Aboriginal peoples in a culturally sensitive, cost-effective manner. Academic and "grey" literature, government documents, including prior evaluations and commissioned studies were all reviewed.

The review first examined the characteristics of the sources – the nature of the research, researchers and the topics they cover. It then reviewed the literature among broad themes and then examined the characteristics of the literature on urban/native housing in Canada and provided a cross-national analysis with the research on Aboriginal housing in other western democracies, specifically, the United States, New Zealand and Australia. It concluded with a comparative analysis and an analysis of the gaps, which currently exist in the literature and point to opportunities for further research.

The broad themes which emerged from the literature included: treaty rights to housing rights and First Nations control, housing needs and current housing conditions, affordability, design and construction, the relationship between housing and health, on-reserve housing and homelessness, governance of housing and local control, the relationship between housing and economic development, education and training and the building of capacity to manage and build housing on reserve and varying cultural concepts around home ownership.

Review of Administrative Data

The administrative data assessed in this evaluation included the Housing and Infrastructure Assets Annual Report and the Changes in Capital Assets Annual Report; both of which are submitted by reporting First Nations to INAC by March 31 each year and stored in the Integrated Capital Management System (ICMS) database. [Note 12]INAC's Information Management Branch provided a customized extraction of raw data from the ICMS and EPMRB generated a database matching data from each First Nation community and conducted subsequent analysis using PASW statistical software. Note that the data in the ICMS database excludes Northwest Territories, Nunavut, and Inuit communities of Northern Quebec, as well as bands under the James Bay and Northern Quebec Agreement since 1984, and self-government bands in the Yukon.

Custom extracts from the Canadian Census Variables for Households and Dwellings from the last three census periods (1996, 2001 and 2006) were also reviewed. The specific variables requested included persons per household by age, frequency of major repairs required, economic family income, overcrowding rates, composition of children, couples and adults and age of house (whether it was built prior to 1991 or after), Aboriginal and non-Aboriginal, and on reserve versus off reserve (broken out by the variables of rural/urban).

3.3.3 Considerations, Strengths and Limitations

Considerations

INAC funds most First Nations communities through CFAs or through the DFNFAs. First Nations with CFAs must provide INAC with a report on how funding within the agreement was allocated. First Nations with DFNFA are generally not required to inform INAC how they have allocated funding under the agreement. These arrangements mean that all the data on number of houses built, repaired or the numbers of lots which have been serviced are data which are self-reported by First Nations and there is no independent verification of what is reported.

Participation in the 1996 Housing Policy did carry with it the obligation for First Nations communities to develop housing plans. However, the current evaluation did not seek to review or verify the existence of these community housing plans and they were never referred to in the key informant interviews or in any discussions about capacity building requirement. These plans are collected regionally and are not systematically mined by INAC in a way that would make the information extractable or analysable. Thus, while the plans are required from First Nations to receive funding via the INAC regional offices, an analysis of their contents would have required a manual analysis of thousands of reports over the period of study. INAC's 2008 Evaluation of the On-Reserve Housing Policy, however, notes that "according to the questionnaire responses and interviews with housing officials, the situation in the regions with regard to community housing plans varies considerably. In some regions, plans are not being submitted to the regional office, not being updated or not being implemented. " [Note 13]

Strengths

An overarching strength of the evaluation methodology is that there were multiple lines of evidence used, and therefore some of the limitations that occurred in obtaining data on one line were, at least partially, compensated for in other lines of evidence. For example, although there were fewer key informant interviews obtained than hoped for – 103 instead of 175, – there were additional key informant interviews carried out for the case studies, as well as more in the evaluations of the MLG and Shelter Allowance Program. These entailed different interview guides but sought to inform the same substantive evaluation issues.

Similarly, case studies were used in the general on-reserve housing evaluation as well as for the evaluation of the MLG.

From the point of view of ensuring the participation of First Nations in the evaluation process, there were clearly many opportunities for Aboriginal leadership and community members to provide their views and their expertise through the Advisory Committee and Working Group and key-informant interviews and case studies.

The study adhered to INAC's Sustainable Development Strategy [Note 14]as it relates to program evaluation.

Limitations

General

The fact that the original evaluation was intended to be a joint evaluation with CMHC, and ultimately was not, was a limitation to this evaluation in that it resulted in a more narrow scope. A joint evaluation may have: shed greater light on areas of overlap and duplication; pointed to ways to clarify roles and responsibilities; identified gaps in the programs and services of both INAC and CMHC; and provided further insight on the concerns raised by the Auditor-General in her 2003 Report (see Section 4.1.3) about a lack of clarity on roles and responsibilities of the On-Reserve Housing Program, beyond the update of the 2006 progress report. [Note 15]

The evaluation did draw on CMHC's considerable body of on-reserve housing research and interviewed CMHC Headquarters and regional officials amongst key informants so some of their knowledge, experience and perspectives were captured.

Cost-effectiveness, and to a large extent, efficiency, were very difficult to ascertain because of the limitations around reporting which exist for First Nations who manage their housing under either a CFA or DFNFA (specifically, because these funding arrangements do not allow for INAC to systematically monitor how funds are spent; see Section 7.1). As a result of this, and because of other data limitations, it was not possible to empirically measure the cost of a house or renovation on-reserve.

The main limitations of the key-informant interviews were that:

• the lowest response rate for interviews was from First Nations Direct respondents. Notwithstanding the reasons for this, this may have inadvertently skewed the analysis of the findings from this category of key informants in favour of the views of other categories of interview respondents;
• there was no formal pre-testing of the interviews guides;
• there was no differentiation in the weighting of interview responses according to the varying levels of expertise amongst the key informants; and
• there were no measures to control for unknown interviewer or interviewee bias. The high response rate of government interviewees versus the relatively low response rate of First Nations participants could have been a function of interviewee bias and/or that for many First Nations individuals who declined to be interviewed, the timing was inconvenient or that they had other priorities.

The main limitations of the case studies were that:

• there was some challenge to finding qualified inspectors to do the condition assessments in the necessary time frame;
• a scheduled visit to a community was refused at the last minute;
• there was a considerable amount of data retrieved for each community, which was manually gathered and then entered into a database. Under these circumstances, there is always the possibility of errors occurring in the data entry process. As well, missing data had an impact on the integrity and analysis of the information collected;
• Given the sensitivity of the subject matter, that there could be potential language barriers or hesitations on the part of those responding to interview questions for fear of being personally identified with a point of view; and
• The survey, by its very nature, has two built in response biases: the risk that problems will be over-emphasized in the hopes of having concerns addressed; and the reverse, that problems were under-emphasized for fear that individual could be identified by their particular responses.

The limitations of the post hoc analysis of the condition assessments were that: the consultant, A.J. Doxtdator, was asked to analyse data which he did not personally collect or supervise the collection of; and, the selection of houses for which condition assessments were carried out was not statistically valid and not necessarily representative.

The limitations of the literature review were that the parameters for the review may have been too narrow. Research on the housing circumstances of the Scandinavian Sami were not included nor were there any reference made to Aboriginal/Native housing in Alaska, two geographic locations which bear some resemblance to the physical circumstances in which much of Canada's on-reserve housing is located.

One specific omission is related to the federal Homelessness Partnership Strategy (HPS), formerly the National Homelessness Initiative, bears comment. This national initiative represents a ten year investment by the federal government, partnering with provinces, the private sector and municipal leaders from over 80 cities, to reduce homelessness by creating more emergency shelters and transitional housing, providing supports to help the homeless break the cycle of their homelessness and by building capacity within communities to generate affordable housing. During all three phases of this initiative, a high percentage of funds went to Aboriginal peoples' housing issues. Accelerating on-reserve housing needs and accelerating homelessness in urban centres are linked; many First Nation leaders said that they are pressured by band members who would like to return to their communities from the cities. A review of any HPS evaluation findings, particularly around best practices may have been illuminating, particularly with respect to the management of on-reserve population growth and capacity issues around developing community housing plans.

Generally, the current quantity and quality of literature on on-reserve housing issues is limited and lacks depth. Given that it is difficult to make comparisons and other linkages within the present literature, little can be said about the transferability of conclusions drawn from the literature. What the literature search did establish, however, is that this is an emerging field for research both in Canada and elsewhere.

As census and administrative data regarding First Nations housing are self-reported data, there is an inherent margin of error which has to do with errors or omissions in the course of the self-reporting and with the fact that not all of the data can be independently verified. There is also always the possibility of errors with respect to coverage, processing and sampling. Additionally, there are no reliable statistics available on the proportion of First Nations completing the recipient reports relative to the number required to do so. With First Nations on reserve, these issues are compounded by even lower response rates, language barriers and cases where entire communities choose not to participate in the census. As with all the other streams of evidence, there is always the possibility that data collection may be limited or compromised by poor comprehension of the questions being asked. The census by its very nature produces data at five year intervals and much of this evaluation has relied on 2006 data, the latest year for which data are available.

With respect to the composite scores that form the Community Well-being Index (CWB) (see Glossary of Selected Terms), there is a high degree of inter-correlation between each of the four composites and a limited ability to disentangle them individually. Plus, with respect to the housing composite indicator specifically, the score only includes crowding and the need for major repairs, which do not comprise all aspects of well-being with respect to housing.

Gender-based Analysis

There was no gender based analysis carried out as part of the evaluation. A future evaluation may wish to explore the differential impact that the condition and availability of housing has on women and men in the same community.

3.4 Roles, Responsibilities and Quality Assurance

• EPMRB was the Project Authority for this evaluation. EPMRB drafted the Terms of Reference, integrated the data from the multiple lines of evidence, managed the various research contracts, prepared the final draft and transmitted it to the Advisory Committee, addressed comments/questions and prepared the evaluation for consideration by the department's Evaluation, Performance Measurement and Review Committee.
• Two different consultant associates of the consulting firm of Donna Cona undertook a literature review and case studies. T.K Gussman Associates Inc., in association with the consulting firm DPRA, undertook key informant interviews. The consulting firm of KPMG provided evaluations of the MLG and the Shelter Allowance Program as it relates to on-reserve housing. The firm of A.J. Doxtdator and Associates provided a post hoc analysis of the condition assessments. CMHC contributed various recent research relevant to the evaluation questions.
• The quality assurance measures which were applied to this evaluation included an Evaluation Advisory Committee compromised of members from the Assembly of First Nations, CMHC, a representative of the INAC Housing Program and Health Canada. The report was reviewed by the Advisory Committee and peer-reviewed by a senior manager in EPMRB not responsible for evaluations in this area. Their comments and questions were also considered when the report was in draft form.

4. Evaluation Findings - Relevance

4.1 Key findings

There remains a strong, continuing need for support from the Government of Canada to facilitate the building of new housing on reserve and the renovation and repair of much of the existing housing stock.

There is a clear demonstration of alignment between on-reserve housing initiatives and federal government and INAC priorities. Given INAC's fiduciary responsibility for the well-being of First Nations, there is also no question that supporting on-reserve housing is an appropriate role for the federal government.

4.1.1 Is there a continued need to support on-reserve housing?

Finding: There is a clearly demonstrated need for continued support from the Government of Canada for the provision of on-reserve housing programs.

The continued need for on-reserve housing support can be demonstrated by examining the relationship between current and forecasted population growth, the rate of new housing construction, the rate of repairs to existing housing stock and the extent of overcrowding on-reserve.

Figure 4.1: Projections of Aboriginal Populations [Note 16]
On-Reserve by Age Group from 2010 to 2026 [Note 17]

Projected Aboriginal Population On-Reserve

This figure shows projections of aboriginal populations on-reserve by age groups 0-18, 19-64, and 65 and over, each represented by a separate line. The slope of the line for the age group 19-64 is roughly at a 15 degree angle. The slopes of the lines for the age group 0-18 and for the age group 65 and over are roughly 5 degrees. The projected aboriginal population on-reserve is indicated along the y-axis and the years are indicated along the x-axis.

The projected population for aboriginals aged 19-64 in 2010 is approximately 252, 000 in 2012; 260, 000 in 2014; 280, 000 in 2016; 290, 000 in 2018; 302, 000 in 2020; 320, 000 in 2022; 325, 000 in 2024; and 340, 000 in 2026. The projected population for aboriginals aged 0-18 is approximately175, 000 in 2012; 180, 000 in 2014; 190, 000 in 2016; 195, 000 in 2018;199, 000 in 2020; 200, 000 in 2022; 205, 000 in 2024; and 210, 000 in 2026. The projected population for aboriginals aged 65 and over is approximately 25, 000 in 2012; 30, 000 in 2014; 40, 000 in 2016; 45, 000 in 2018; 48, 000 in 2020; 49, 000 in 2022; 50, 000 in 2024; and 51, 000 in 2026.

Forecasted population growth rate from 2010 – 2026

Statistics Canada's projections for the population growth rates of First Nations on reserve lend compelling weight to any discussion of continued need. As Figure 4.1 shows, there is a forecasted increase, between 2010 and 2026, of 18.4 percent in the population of children ages 0-18, a 40 percent rise in the population of adults under 65 and a more than doubling of the population of seniors, age 65 and over.

It is also important to note that these estimates do not necessarily reflect the population growth of reserves that do not participate in the Canadian census.

Population growth of First Nations on-reserve from 1996-2009

According to data from the ICMS, the total on-reserve population among reporting reserves grew to 372,297 by 2008. This represents a 43,500 or 11.6 percent increase in the population size from 1996. These data likely under-represent the true population growth on-reserve because of two factors: not all First Nations report population data to INAC; and, many First Nations chiefs and councillors/housing managers who were interviewed as key informants said they know of community members living off reserve who would like to return to the community as soon as housing becomes available. However, this increase is also at least partially caused by an increase in the number of First Nation communities reporting figures to INAC between 1996 and 2008 (from 888 communities to 976).

There are approximately 615 First Nations and 977 First Nations communities [Note 18] providing reports to INAC. Figure 4.2 shows a mean population per First Nation community of 388 over the 13 year period. Therefore, while there has been some population growth, the average size of each community has not changed markedly; from an average of 366 in 1996 to a maximum of 404 in 2007. The average population growth per community between 1996 and 2008 was approximately 52 [Note 19].

Figure 4.2: Mean Population per Community from 1996-2008 [Note 20]

The figure illustrates the mean population per community per year from 1996-2008. The mean population is located on the y-axis and the year is located on the x-axis. There is one line on the graph with very little variation aside from a relatively large increase from 1996-1997 and a relatively large decrease from 2007-2008.

The mean population per community was approximately 359 in 1996; 385 in 1997; 360 in 1998; 380 in 1999; 385 in 2000; 386 in 2001; 386 in 2002; 390 in 2003; 398 in 2004; 400 in 2005; 402 in 2006; 403 in 2007; and 360 in 2008.

Rate of new housing construction

Figure 4.3 shows that total housing units have increased from an average of about 88 units per community in 1996 to an average of 105 in 2009, a 19 percent increase.

Figure 4.3: Mean Total Housing Units per Reserve from 1996-2009 [Note 21]

This figure illustrates the mean total housing units per community per year from 1996-2009. The mean of total housing units is located on the y-axis and the year is located on the x-axis. There is one line drawn on the graph that steadily increases throughout 1996-2009.

The mean of total housing units increases over time. It was approximately 88 in 1996; 90 in 1997; 91 in 1998; 92 in 1999; 94 in 2000; 94 in 2001; 96 in 2002; 97 in 2003; 98 in 2004; 100 in 2005; 100 in 2006; 102 in 2007; 104 in 2008; and 107 in 2009.

With respect to housing constructed on-reserve in the time frame 1996-2009, data drawn from ICMS and displayed in Figure 4.4 show that the average number of houses constructed annually per First Nation was about 2.3 but has been steadily declining over time. If First Nation communities each have an average population growth of 52 individuals and an average growth in new housing units of 2.3 per year, for each of the 13 years, the new housing construction should have been sufficient to accommodate the population growth. As discussed in Chapter 5 on Performance, this may not be the case and the issue may be considerably more complex.

Figure 4.4: Average Numbers of Houses Constructed per Community 1996-2009 [Note 22]

This figure illustrates the average numbers of houses constructed per community per year from 1996-2009. The mean number of houses constructed per community is located on the y-axis. The year is located on the x-axis. There is one line drawn in the graph that exhibits a high amount of variation but generally shows a gradual decrease over time.

The mean number of houses constructed per community was approximately 2.7 in 1996; 2.72 in 1997; 3.1 in 1998; 2.8 in 1999; 2.4 in 2000; 2.2 in 2001; 2 in 2002; 2 in 2003; 2.2 in 2004; 2 in 2005; 1.6 in 2006; 2.2 in 2007; 2.3 in 2008; and 1.7 in 2009.

Rate of repairs to existing housing stock

Figure 4.5 shows that the average number of homes per community, which were identified as needing major repairs has risen 10 percent in the years 1996-2009.

Figure 4.5: Average Number of Homes per Community Identifying Major Repairs Required Over Time from 1996 to 2009 [Note 23]

The figure illustrates the average number of homes per community per year identifying major repairs required over time from 1996-2009. The mean of major repairs required is located on the y-axis and the year is located on the x-axis. There is one line in the graph that generally increases slowly between 1996 and 2004 and then sharply between 2004 and 2009.

The mean of major repairs was approximately 13 in 1996; 13 in 1997; 14 in 1998; 15 in 1999; 13 in 2000; 14 in 2001; 15 in 2002; 16 in 2003; 17 in 2004; 22 in 2005; 22 in 2006; 23 in 2007; 24 in 2008; and 25 in 2009.

Figure 4.6 shows a somewhat erratic picture of the total number of renovations' completed amongst all First Nations communities in the same 13 year period. There could be many explanations for the peaks and troughs indicated in this Figure, including that higher levels of activity correspond to the occasional infusion of time-limited supplemental funding for on reserve housing such as occurred as a result of Budget 2005.

Figure 4.6: Total Number of Renovations Completed from 1996 to 2009 [Note 24]

This figure illustrates the total number of renovations completed by year from 1996 to 2009. The sum number of renovations is located on the y-axis and the year is located on the x-axis. There is one line drawn in the graph that exhibits a high amount of variation at different points in time.

The sum number of renovations was approximately 3200 in 1996; 4200 in 1997; 2900 in 1998; 2900 in 1999; 3200 in 2000; 3200 in 2001; 4200 in 2002; 4200 in 2003; 3800 in 2004; 1900 in 2005; 2400 in 2006; 2500 in 2007; 3100 in 2008; and 2700 in 2009.

According to 2006 census data on the age of homes in Canada, 45 percent of on-reserve houses have been built within the last 15 years compared to 22 percent for non-Aboriginal houses and 17 percent for Aboriginal houses off reserve. These data suggest that there is a large amount of new house construction on-reserve, relative to off reserve. The 2006 housing related census data also show that the proportion of houses in need of major repair had decreased markedly for both non-Aboriginal households (-5.8 percent) and Aboriginal households off-reserve (-7.5 percent). However, the proportion of houses in need of major repair increased for First Nation households on-reserve housing by almost four percent. Given that housing stock off reserve tends to be older than on reserve, this is a notable finding. What it means is the housing built on reserve is not lasting as long as it should and needs replacing sooner than can be afforded.

Yet another strong indicator that there is a continued need for support comes from a comparison of the proportion of houses needing major repairs amongst non-Aboriginal Canadians, off reserve Aboriginal people and on-reserve First Nations (Figure 4.7). While the proportion of houses needing major repairs for non-Aboriginal Canadians and Aboriginal people off reserve has been steadily decreasing, the proportion of housing on reserve in need of major repairs has increased from about 37 percent in 1996 to just over 40 percent in 2006.

Figure 4.7: Comparison of non-Aboriginal households and Aboriginal households on and off reserve with respect to proportions of Houses Requiring Major Repairs for three census periods 2006 [Note 25]

This figure illustrates in a bar graph the proportion of houses requiring major repairs comparing non-aboriginal households and aboriginal households both on and off reserve in each of the years 1996, 2001, and 2006. The proportion, in percentages, of houses needing major repairs is located on the y-axis. The census periods are located on the x-axis.

Each census year is represented by a cluster of bars, with non-aboriginal households, aboriginal households on-reserve, and aboriginal households off-reserve each represented by a separate bar. The proportion of houses requiring major repairs in 1996 was approximately 13% for non-aboriginal households; 37.5% for aboriginal households on-reserve; and 21.5% for aboriginal households off-reserve. The proportion of houses requiring major repairs in 2001 was approximately 8% for non-aboriginal households; 36% for aboriginal households on-reserve; and 16% for aboriginal households off-reserve. The proportion of houses requiring major repairs in 2006 was approximately 7% for non-aboriginal households; 41.5% for aboriginal households on-reserve; and 14.5% for aboriginal households off-reserve.

Figure 4.8 demonstrates clearly the widening of the gap between the number of housing units identified as needing major repairs and the number of repairs and renovations completed. By 2009, the gap was at about 20,000 houses where a major repair was required and had not yet been done. [Note 26] A major repair includes defective plumbing, electrical wiring, structural matters related to walls, floors and ceiling. Delays in attending to these repairs not only work a significant hardship on the occupants, often to the detriment of their health and well-being, but likely intensify the seriousness of the repair and its cost when the repair can finally be done.

Figure 4.8: Total Number of Homes Renovated in each Year Relative to the Total Number Identified as Requiring Major Repair the Previous Year from 1997 to 2009 [Note 27]

Total Houses

This figure illustrates the total number of homes renovated each year relative to the total number identified as requiring major repair in the previous year from 1997 to 2009. The total number of homes is located on the y-axis. The year is located on the x-axis. The graph contains two lines. One line indicates the major repair identified in the previous year and gradually increases between 1997 and 2005 and then sharply increases from 2005 to 2009. The other line indicates the number of houses renovated and shows a general slow decrease but no marked change over time.

The number of houses that were identified as requiring major repair the previous year was approximately 12 500 in 1997; 12 700 in 1998; 13 000 in 1999; 14 000 in 2000; 13 500 in 2001; 14 000 in 2002; 14 800 in 2003; 16 000 in 2004; 17 000 in 2005; 21 500 in 2006; 22 000 in 2007; 22 100 in 2008; and 23 800 in 2009.

The number of homes renovated was approximately 4900 in 1997; 2700 in 1998; 2700 in 1999; 3000 in 2000; 3000 in 2001; 4800 in 2002; 4800 in 2003; 4700 in 2004; 2000 in 2005; 2400 in 2006; 2500 in 2007; 3000 in 2008; and 2500 in 2009.

Current extent of overcrowding on reserve

The data from Figure 4.9 show that First Nations on reserve have at least 1.5 times as many people per household as non-Aboriginal people. The figure shows that for non-Aboriginal Canadians, the average household size has remained quite steady over a 10 year period from 1996-2001 at 2.5 persons per household. For First Nations on reserve, the number has declined only very slightly from four persons per household in 1996 to about 3.75 persons per household.

Figure 4.9: Comparison of average household size (persons per home) among non Aboriginal Canadians and First Nations on and off reserve over three census periods [Note 28]

Average Household Size

The figure compares average household size (persons per home) among non-Aboriginal Canadians and First Nations on- and off-reserve over the three census periods of 1996, 2001, and 2006 by way of a bar graph. The average household size (persons per home) is located on the y-axis. The year is located on the x-axis. Each cluster of bars is represented by a census year, with non-aboriginal Canadians, First Nations on-reserve, and aboriginals off-reserve each represented by a bar.

The average household size (persons per home) in 1996 was approximately 2.6 for non-aboriginals; 4 for aboriginals on-reserve; and 3 for aboriginals off-reserve. In 2001 it was approximately 2.5 for non-aboriginals; 3.7 for aboriginals on-reserve; and 2.9 for aboriginals off-reserve. In 2006 it was approximately 2.5 for non-aboriginals; 3.7 for aboriginals on-reserve; and 2.7 for aboriginals off-reserve.

Figure 4.10 shows the proportion of houses for non-Aboriginal Canadians which are overcrowded compared to those for off-reserve Aboriginal peoples and on-reserve First Nations. In 1996, the proportion of overcrowded households on reserve was about nine times greater than for non-Aboriginal Canadians. In 2006, households on reserve were six times more overcrowded. While this is a noticeable improvement, it is important to note that most of this improvement occurred between 1996 and 2001 and the rates of overcrowding had only decreased by about 1.5 percent between 2001 and 2006.

Figure 4.10: Comparison of proportion of homes crowded amongst Non-Aboriginal Canadians and Aboriginal Peoples on and off Reserve over three census periods [Note 29]

Proportion (%) Crowded

This figure compares the proportion of crowded homes amongst non-aboriginal Canadians, aboriginal peoples on-reserve, and aboriginal peoples off-reserve over the three census periods of 1996, 2001, and 2006 by way of a bar graph. The proportion of crowded homes (in percentages) is located on the y-axis and the year is located on the x-axis and non-aboriginals, aboriginals on-reserve, or aboriginals off-reserve each represented by a bar.

The proportion of crowded homes (in percentages) in 1996 was approximately 1.9% for non-aboriginals; 18.1% for aboriginals on-reserve; and 4.2% for aboriginals off-reserve. The proportion of crowded homes (in percentages) in 2001 was approximately 1.6% for non-aboriginals; 13.9% for aboriginals on-reserve; and 2.3% for aboriginals off-reserve. The proportion of crowded homes (in percentages) in 2006 was approximately 1.7% for non-aboriginals; 12.1% for aboriginals on-reserve; and 2.1% for aboriginals off-reserve.

Regional dimension to continued need for housing support

As a matter of operating practice, the allocation of housing funds and any incremental investments in on-reserve housing approved by Cabinet are normally distributed by INACHQs amongst the regions based on a formula weighted to that region's on-reserve population.

There are limited data to describe how different the circumstances are around housing on reserve across regions. The 2008 Evaluation of the 1996 On-Reserve Housing Policy noted that, "the percentage of First Nations living in crowded dwellings on-reserve had decreased over the past decade from 33 percent to 26 percent. Improvement in on-reserve conditions was observed in all provinces and territories but was more pronounced in Ontario and Quebec than in the Prairie Provinces. In Manitoba, about 37 percent of on-reserve First Nations people lived in a home with more than one person per room, 36 percent in Saskatchewan and 31 percent in Alberta. In Quebec, the proportion was 23 percent and in Ontario, 19 percent." [Note 30] The 2008 evaluation report also stated that, "by 2006, [while] 44 percent of First Nations housing on reserve needed major repairs, the proportion was considerably higher in the three Prairie provinces – 54 percent in Saskatchewan, 53 percent in Manitoba and 52 percent in Alberta. The proportion was lower in Ontario, at 41 percent and British Columbia, 39 percent." [Note 31] These data are far from conclusive about the differential impacts of the policy and programs in regions but they do point to an area for further examination.

With respect to the decisions of First Nations in British Columbia and parts of Ontario to opt out of the 1996 On-Reserve Housing Policy, there is no clear evidence that this has had an effect for better or worse. This is primarily because of the unique circumstance of British Columbia, where there are many more First Nation communities with smaller populations and thus a valid comparison is difficult. In examining data recorded in ICMS, however, all regions except British Columbia have shown marked increases in the numbers of homes needing major repair and requiring replacement and decreases in the numbers of homes built and renovated over time. These reported numbers in most communities in British Columbia have remained unchanged over this time period.

Findings from literature review on issue of continued need

Finally, the literature review contributes some insights into the question of continued need. The review concludes that conditions across western democracies are not improving. Gains made in reducing overcrowding are lost to increased costs and loss of affordability. In these democracies, "high maintenance and low rents prevent any gains to improving housing stock. The need is still high but the consensus in the literature is that Aboriginal peoples must be part of developing their own housing." [Note 32]

Summary and conclusions about continued need

At the outset of the introduction of the 1996 On-Reserve Housing Policy, there was a consensus between the Government and First Nations that there was already a shortfall of adequate housing on reserve, although the precise dimensions of that shortfall were never documented. Since the introduction of the housing policy, the Government has given ongoing funding to on-reserve housing and supplemented those annual allocations with considerable additional funding. Despite ongoing construction of new housing on reserve, the shortfall still exists and appears to be growing rather than diminishing. A number of factors, which will be discussed later in this report explain why this is the case.

Overcrowding is very much a reality on reserve. Even though the proportion of houses which are "overcrowded" has been reduced by one third in the 13 year time frame, most of this reduction occurred between 1996 and 2001, and it is still six times as high as for non-Aboriginal Canadians. Overcrowding causes hardship for both the occupants and for the houses.

The question of whether there is a regional dimension to the shortfall and continuing need for housing support was not specifically addressed by this evaluation. The existing data are too limited to arrive at any conclusions. Future evaluations may wish to explore this question further.

With an existing backlog and a forecasted rise in population, there is a strong requirement for more adequate housing units in the future. New needs are being generated almost as quickly as the housing can be built. In considering the current resources for housing in conjunction with the sharp increase in the need for major repairs as well as the projected population growth, coupled with marked decreases in the numbers of homes being constructed and renovated, it is likely that the gap between the need for suitable housing and the actual suitable housing that is available will continue to widen.

4.1.2 Are on-reserve housing initiatives aligned with federal and INAC priorities?

Finding: There is a clear demonstration of alignment between on-reserve housing initiatives and federal government and INAC priorities.

Federal government and INAC priorities

Administrative data indicate that from 1996 onwards, the federal government has demonstrated evidence of on-reserve housing being both a government-wide and INAC-specific priority.

The 1996 announcements of the On-Reserve Housing Policy stated that the goals of the new policy would be to:

• Protect and extend the life of existing housing and ensure existing on-reserve housing meet national standards, through maintenance, insurance and renovation programs.
• Construct quality, affordable new housing designed to respond to the variety of housing needs within the community.
• Support individual pride and responsibility through increased involvement and home ownership as well as private market investment; and
• Link housing activities with job training, job creation and business development.

In 1998, in its response to RCAPGathering Strength, INAC internally re-allocated $20 million to on-reserve housing, including some funds for innovative housing technology and for training. There were also commitments to work on initiatives begun in 1998 to 1999 in partnership with the AFN and CMHC to explore approaches to private sector investment, alternative approaches for governance of First Nations housing, improved linkages with economic development, jobs and training and program options which responded to a variety of housing needs, including special purpose housing. Shortly after INAC submitted to Treasury Board a request to increase the authority for MLG, [Note 33] these commitments were followed by joint financial commitments to INAC and CMHC for on-reserve housing in 2005 of $295 million over five years from the Program Integrity and from Round 1 Rust Out initiatives.

In 2007, in his presentation to the Indian Affairs and Northern Development Standing Committee on Aboriginal Affairs and Northern Development, the Minister acknowledged that the Government knows the housing situation on many reserves is "Inadequate and contributes to poor economic and social outcomes." The Government also acknowledged that "Structural reform and innovation are required in order to transform the housing system on-reserve." The Government announced a $300 million First Nation Market Housing Fund with the intention of helping to create a housing market on reserve. The fund was intended to be an additional tool to help First Nations address their housing need. Through the fund, the Government expected up to 25,000 new housing units to be provided over the next ten years. [Note 34]

In 2008, INAC received additional funding to support investments in First Nations infrastructure and housing, amendments to the transfer payment terms and conditions for the CFM Program, which was $150 million for two years, 2009/10 and 2010/2011.

These commitments were followed by the government's agreement to increase the INAC MLG authority to $2.2 billion. According to key informants, the MLGs are relevant in that they support one of the key principles of the 1996 Policy, which is to access private capital. "With the consistent high level of take up, the need to increase authority has been steady [...]." [Note 35] "Analysis of progression of MLGs between 1996 and 2008 has shown a significant increase in usage with little sign of slowing down [...]." [Note 36]

Summary and conclusions about alignment

There is broad consensus among stakeholders that the current On-Reserve Housing Policy is in alignment with Government of Canada objectives and the objectives of INAC.

4.1.3 Is providing on-reserve housing a legitimate role for INAC?

After an audit of INAC's On-Reserve Housing Program and in her 2003 Report, the Auditor General called for greater clarity on the roles and responsibilities of the two federal entities and greater clarity from each as to the objectives of their interventions. [Note 37] She did not, however, raise any questions about the appropriateness of their roles in supporting on-reserve housing. In her 2006 update, the Auditor General commented that "we found that housing programs are now better integrated and many elements are now better managed by the responsible organization." (See Section 5.3.1 for discussion on further updates to the Auditor General's report and the 2010 Audit of Housing.)

With respect to on-reserve housing, she noted in her 2003 report that there is:

• little consensus among main parties (INAC, CMHC, First Nations, their organizations like tribal councils and the families that live in the houses ) as to what they believe their respective roles and responsibilities are in addressing the housing needs of people living on reserve; and
• that INAC and CMHC have not defined, jointly or separately, what the federal assistance is intended to achieve in terms of addressing the critical housing shortage, nor have they defined a time frame in which to achieve it. Further, the organizations are not always clear about their respective roles.

While the 2006 report states that a management control framework that defines respective roles and responsibilities for addressing housing shortages on reserves has been developed, key interviewees expressed ongoing confusion regarding roles and responsibilities; specifically that they are not clearly articulated, and as a result there is confusion primarily among First Nations.

Key respondents agree that INAC and CMHC are the appropriate federal entities to fund on-reserve housing. Each has several programs and mechanisms which contribute to on-reserve housing policy outcomes. However, Headquarters key informants acknowledge some confusion about roles within First Nations. In the words of one Headquarters key informant, "there is a perception that there are two departments with related mandates providing funding and that there is a duplication of administrative effort." At the regional level, government key informants expressed general agreement that the federal government has a role in on-reserve housing. On balance, they saw INAC as responsible for funding new housing, repairs and for building capacity amongst First Nations. They identified CMHC as the entity which provided subsidies for construction and operating costs for Section 95 social housing, loan insurance, loan guarantees, RRAP and some capacity building initiatives. First Nations key informants, both High Level and Direct, suggested that they are at least occasionally confused about what the role and responsibilities of each entity are.

In terms of how stakeholders see the federal role for on-reserve housing, 80 percent of government key informants from both Headquarters and regions stated that INAC's key role is that of a funder. About 45 percent of First Nations high level respondents stated they saw the federal role as funder. An additional 25 percent of these respondents stated that the federal government should provide administrative support and capacity development for housing as well. Sixty-two percent of First Nation direct respondents stated that the key federal role should be as funder.

The views of respondents in the case studies about what the federal role in on-reserve housing should be are quite prescriptive and ranging. Samplings of responses include the following. "They have historical obligations to us." "Housing should be first priority to feds." "Feds should support private ownership concept." "INAC should have a bigger role and perform a review on a regional basis." "Feds need to address the backlog." "We have no funding to upgrade homes and not enough housing for all members." "The federal government has a fiduciary obligation to First Nations. It is important, however, that our own members take responsibility for themselves as well. With the federal government fulfilling its obligations and empowerment of members through education and training, we will be on the right track. I believe the federal government should be guiding us on anything to deal with housing. I said 'guide' not lead."

Summary and conclusions about federal role

All those interviewed agreed that the federal government should have a key role in the support of on-reserve housing as a funder, among other things.

The specific roles and responsibilities of each of INAC and CMHC are not well-articulated to stakeholders, and key informants highlighted the need for the organizations to bring greater clarity to their working arrangements and communicate it to First Nations. First Nations key informants expressed confusion and frustration because it was not always clear to them which entity should be supporting them for certain aspects of housing management.

5. Evaluation Findings - Performance (Results/Success)

This chapter, divided into four parts, describes the results of housing programming and suggests some possible impediments to more positive results. The first section discusses performance around housing stock, examining the relationship between new unit production, the servicing of lots, and the affordability of new construction as factors which determine whether quantity and quality of First Nations housing stock has improved over time. The second section looks at performance with respect to repair and renovation. The third section considers performance regarding governance and the last section examines performance with respect to capacity-building.

5.1 Has First Nations housing stock improved over time?

Findings: While housing stock has increased steadily since 1996 through construction of new units and repairs to damaged units, the results have not kept pace with housing needs.

5.1.1 New unit production

The need for new units exists because of the current shortfall in adequate housing and because of the population growth projections for First Nations on-reserve. [Note 38] To compound the forecasted rise in population growth, First Nation high level respondents stated thatthere are community members now living off reserve who would return to the reserve as soon as housing becomes available. Additionally, as shown in Figure 4.1, the population over 65 is expected to double over the next 15 years, rising by about 25,000. Thus, there will also be an increased need for a diversity of housing designs to accommodate more elderly and disabled persons.

New unit production is not, at present, keeping pace with growing need. Increased labour and material costs are key reasons. Funding for on-reserve housing allocations has been held constant as costs increased. This has meant that First Nations, in general, have built fewer houses than in previous times with the same level of funding. The earlier discussion in Section 4 (Relevance), detailedthe overall picture, that while housing stock overall has increased, the number of houses being built per year has been decreasing, new houses need major repairs sooner than anticipated and overcrowding rate, while having decreased noticeably between 1996 and 2001, had only decreased marginally between 2001 and 2006.

Under the auspices of Budget 2005, the Government gave INAC and CMHC an incremental $295 million, to be spent over five years for housing construction, renovation and the creation of serviced lots on reserve. The objective of this funding was to stabilise the housing situation on reserve by constructing 6,400 new units, renovating 1,500 existing units and creating 5,400 service lots so as to stem the growing shortage of housing units and begin to eliminate it. INAC was to introduce some new program elements and CMHC was to build on their current programs. Two hundred million dollars was to be spent by both organisations within the first two years. Table 5.1 shows the breakout by organization for each category of expenditure.

Table 5.1: Budget 2005 expected outcomes from $295 million investment in on-reserve housing

Table 5.2 shows INAC's actual achievements against its specific targets in each category of activity.

Table 5.2: INAC's targeted and actual performance against 2005 Budget obligations

Source: INAC Community Infrastructure Branch

Despite solid efforts and demonstrable progress by INAC to use its share of the $295 million to achieve more adequate housing, the backlog continued to grow to between 20,000-35,000 housing units, 16,900 housing units in need of major repair and 5,200 housing units in need of replacement (although First Nations representatives suggested their estimates of these numbers to be much higher). This growing backlog is of particular concern, especially given the rate of deterioration of existing stock, coupled with the aging population and projected population growth as discussed in Section 4.1.1.

5.1.2 Impact of lot servicing on creating new housing stock

Having serviced lots available is the cornerstone for First Nations being able to build new housing. A serviced lot is generally understood to be one in which there is the provision for piped water and sewer services from the lot line to the house. Servicing a lot may also include putting in individual wells and septic systems where housing densities are not sufficient to warrant piped systems. A lot must be serviced to be eligible for CMHC Section 95 funding.

As Figure 5.1 shows, between 90-92 percent of houses on reserves that report infrastructure and assets to INAC have been built on serviced lots. The largest gains in percentage of houses built on serviced lots has been in Ontario and Manitoba where the percent increase in houses built on serviced lots went from 83 percent in 1996 to 94 percent in 2009 and 81 percent to 95 percent respectively. Data from the Community Infrastructure Branch show that 5,119 lots were serviced at an approximate cost of $25,000 per lot, as a result of Budget 2005 investments. Some First Nations key informants mentioned that they would like to be able to maintain a short term supply of serviced lots, at the ready, for future new house construction. That way having a serviced lot would never be an impediment to moving forward.

Figure 5.1: Mean Proportion of Houses on Serviced Lots

Source: INAC's Infrastructure and Assets Annual Report, using the ICMS database

The figure illustrates the mean proportion of houses on serviced lots. The mean proportion of houses on services lots is located on the y-axis. The year is located on the x-axis. There is one line drawn on the graph that generally maintains a steady horizontal slope at a proportion of about 0.92 with very little variation at different points in time.

The mean was approximately 0.91 in 1996; 0.92 in 1997; 0.92 in 1998; 0.925 in 1999; 0.93 in 2000; 0.925 in 2001; 0.92 in 2002; 0.925 in 2003; 0.93 in 2004; 0.93 in 2005; 0.93 in 2006; 0.935 in 2007; 0.90 in 2008; and 0.91 in 2009.

5.1.3 Affordability of New Construction

The affordability of new construction influences decisions on whether on-reserve housing funds are used for new unit production or for other housing related needs. Every First Nation leader interviewed suggested that insufficient funds are allocated to address all current housing needs. On a daily basis, leaders are forced to make hard choices: use funds to build houses so as to add to the community's assets and reduce overcrowding; or use the funds to repair units so that existing occupants are safer and can enjoy better health; or take a forward-looking view by making sure the community is ready for opportunities with serviced lots. It would appear that in the views of First Nations key informants,a decision about whether new construction is affordable is often a function of the specific circumstances within a specific First Nation at a specific time.

Summary and conclusions about housing stock

The number of units built and repaired relative to targets for spending Budget 2005 funds has been very positive and housing stock has been continually rising. There have also been absolute gains in the numbers of lots which are serviced and "shovel ready." However, the rates of population growth and rising demand for housing is outstripping the speed with which new housing units can be produced and existing ones repaired. There has also been limited success with respect to absolute gains in housing stock relative to need. One First Nation key informant expressed the circular nature of the issue in this way, "Communities are always playing "catch up" regarding need; the demand always exceeds the supply – it is like a wheel moving backwards, a problem that will never be solved because the goal of sufficient housing retreats further and further away."

5.2 Have INAC policies and programs protected and extended the lifespan of homes on-reserve? Has there been an impact on occupants' quality of life?

Findings: The existing housing stock in many First Nations communities is not being well-maintained. Much of the existing housing stock is deteriorating more quickly than should be the case. As a consequence, the lifespan or utility for many housing units is much shorter than had been forecast and much of the housing stock will need replacement sooner than expected.

Insufficient funding for maintenance and repairs and a lack of capacity and knowledge about home maintenance were key factors cited by key informants. Case study analysis suggests that the rapid deterioration is also a function of poor design for site and local environmental conditions, substandard construction materials, poor construction practices and overcrowding.

The costs associated with poorly maintained housing are borne in two ways: the houses need to be replaced sooner than planned so construction costs are increased, and the state of poor maintenance negatively impacts on the quality of life and health of its occupants. Treating the health issues which arise from inadequate housing also generates costs.

Additionally, as Doxtdator observed in his post hoc analysis of the condition assessment data, a complete unit, once constructed will not be sustainable if one or more of the components are deficient or completely deteriorated. A deteriorated house is a burden to a First Nation community and more importantly, the unit is no longer healthy for the occupants. See a summary of the condition assessment data with Doxtdator's analysis here.

5.2.1 Protecting and Maintaining On-Reserve Housing Units

Considerable funding has been targeted to repair and renovation of housing in First Nations communities since 1996. [Note 39]

Notwithstanding that INAC exceeded its targets by 272 percent for repair and renovations associated with the time-limited supplemental funding through Budget 2005, it appears the rate at which repairs can be addressed on reserve lags behind need. While half of First Nations respondents indicated that the current federal government's repair and renovation programs positively affect the quality of life, health and safety, more than half the First Nations' respondents said that less than 30 percent of the need for repairs is being met. Many First Nations high level respondents indicated that they did not know how to access repair and renovation funds.

While not intended to be drawn from a statistically valid or representative sample, the condition assessments suggest that despite any influxes of funding targeted to repair and renovations, there are still substantial needs for major repairs. The assessments illustrated how challenging it is to protect and extend the lifespan of on-reserve housing units. The data from the condition assessments showed that nearly every one of the 80 houses examined required some form of a major repair. The estimated costs to carry out the repairs identified by the home inspectors were $1,565,836.

In further commentary to INAC, Doxtdator explained how a house is a series of interrelated systems. An unattended breakdown in one system will have a deleterious impact on other systems within the house. In his analysis, he noted that regarding condition assessments of First Nations housing "Considering that a number of individuals and professionals are involved in the process, it is difficult to understand how 80 houses could accumulate a total of $1,565, 836 in deficiencies since 1995." He urged that "adequate resources be given to capacity development, greater operational control provided to First Nations communities, support for the development of housing authorities, the promotion of partnerships amongst communities in close proximity on matters related to housing, that there be a gap analysis conducted collaboratively by INAC, CMHC and every First Nation to identify necessary action items to deal with repair and maintenance challenges."

There is a belief, reflected in the comments of some First Nations high level and direct informants that construction on their reserves was not always carried out to the standard of the National Building Code. A few of their comments capture their views. "There are many safety issues related to electrical set ups in houses. Codes and standards have not been met in this community." "Housing inspections should be done to ensure fire and safety measures are in place and that water and sewer infrastructure is maintained." "We are not sure if the National Building Code is used. It seems as though the inspector uses a different standard for us." Some key informants report that building inspectors would come and go [from their communities] and that there seemed to be no consequence to builders who cut corners.

The funding announced in Budget 2005 was meant to assist in the renovation of at least 389 housing units. As with CMHC's program, these funds were to be used for the renovation of houses that did not meet minimum health and safety standards. Once renovated, the house had to meet all minimum safety standards. Priority for funding was to be given to those First Nations who implemented a home ownership or rental regime on the renovated unit. First Nations were to deliver the program through their funding agreement with INAC but access to this source of funding was proposal-driven and subject to additional terms and conditions, including reporting requirements. If the cost of repair exceeded the funding available, First Nations, or individuals, had to identify sources of funds, including any private-sector financing and the ability to qualify for loan financing. Appendix C spells out the details of all the requirements.

Some key informants said that, with the kinds of conditions attached to the funding, the funds were essentially not accessible to them. One high level First Nations respondent stated "there are programs [like these] available at the federal level but if you've got nobody at the band office to figure out what kind of programs and to do the administrative support you need to implement the program, it doesn't get done... the biggest thing is the capacity issue at the local level." More will be discussed in Section 5.4, Capacity Building, about how not having all the required capacities has affected performance and delivery.

The number of houses renovated through the use of Budget 2005 funds is illustrated, by region, in Table 5.3.

Table 5.3: Renovations (Targets and Actual Completed), by Region, using funds from the INAC's portion of Budget 2005 funding

*2.72 times the original target of 389
Source: Community Infrastructure Branch

5.2.2 Affordability

The issue of whether the band or the occupant can afford to maintain the housing unit is not dissimilar to issues already explored around affordability to pay increasing costs for labour and materials for new constructions or to carry debt or pay reasonable rents. In reality, in many First Nations communities, according to case study data, there is little to no employment on reserve and neighbouring employment opportunities generate an average income of less than $25,000. [Note 40] Data from the 2006 Census further showed that the median total income on reserve was approximately $11,300 (average income was $16,160). First Nations community members may have sweat equity to offer towards maintaining a home but there is little cash for buying materials and supplies or pay for a contractor's expertise.

The CWB Index measures the way several factors ─ income, housing, education level among them ─ interrelate to produce an index of well-being within in a community.

Figure 5.2 shows the linear relationship between the CWB Index Housing Score for 2006 and average economic family income (see Glossary of Selected Terms for definition) for that year according to the Canadian Census for the participating reserves. What it shows is that the higher the general income of the community, the higher the CWB score on housing for that community. This suggests that if this linear relationship exists, the condition of the home is related to the owners' financial ability to maintain it. The figure shows that in communities in which there is a higher total economic family income, there is generally a higher mean CWB housing score.

Figure 5.2: Linear Relationships between CWB Housing Score and Average Economic Family Income [Note 41], [Note 42]

The figure illustrates the linear relationships between CWB housing score and median individual total income. Housing score is located on the y-axis and median total income is located on the x-axis. There is one line drawn through a cluster of points on the graph. The slope of the regression line is roughly 35 degrees and represents a regression score of R2 = 0.318.

5.2.3 Impact on Quality of Life and Health of Poorly Maintained Housing Units

Figure 5.3 provides the average CWB Housing Scores, by region over three census periods. The inescapable conclusion is that little has changed in terms First Nations' index of well-being over time with respect to housing. Only the Atlantic provinces and Yukon, for the 2006 Census, have scores which are higher than from previous census. For all the other provinces and territories, the scores have remained the same or are lower.

Figure 5.3: Average CWB Housing Scores by Region over Three Census Periods (1996, 2001, and 2006) [Note 43]

The figure illustrates the average CWB housing scores by region over the three census periods of 1996, 2001, and 2006. The mean housing score is located on the y-axis and the region code, corresponding to Canadian regions, is located on the x-axis. Each region contains a cluster of three bars, with each bar referring to one of the three years (1996, 2001, and 2006). There is some variation between regions but very little variation over time within each region.

In Quebec, the mean housing score was approximately 73.5 in 1996; 76 in 2001, and 73 in 2006. In Ontario, the mean housing score was approximately 70 in 1996; 72 in 2001, and 72.5 in 2006. In Manitoba, the mean housing score was approximately 60 in 1996; 62 in 2001, and 57 in 2006. In Saskatchewan, the mean housing score was approximately 61 in 1996; 62 in 2001, and 58 in 2006. In Alberta, the mean housing score was approximately 58 in 1996; 60 in 2001, and 59 in 2006. In British Colombia, the mean housing score was approximately 79 in 1996; 80 in 2001, and 78 in 2006. In the Yukon, the mean housing score was approximately 76 in 1996; 78 in 2001, and 81 in 2006. In the Northwest Territories, the mean housing score was approximately 71 in 1996; 75 in 2001, and 74 in 2006. In the Atlantic region, the mean housing score was approximately 76 in 1996; 76.5 in 2001, and 78 in 2006.

The CWB Index is a useful measure but it does not "speak" with the same authenticity as those most affected by the quality of housing.

Some First Nations key informants observed: "We have many medical requirements as many homes are not suitable for people with breathing problems." "Many young families have to live with their parents, which causes social problems." "We need more mould free homes. Our population is increasing. We had 30 new babies last year." "Houses are too small because many people are having babies and still living with their parents." "Houses are falling apart." "We had two fatalities in our community related to wiring and lack of heat. People were using a dryer to help heat a home." "With respect to quality of life, health and safety, if you don't have a home or you don't feel your home is as good as other Canadians and if you are on a reserve being viewed as something less anyways, then it all leads to social impacts." "If the federal government would give us a large contribution so we could finally catch up and address the needs which go back five to ten years, it would repay itself by avoiding the same issues we have now. The investment would be worthwhile versus this piecemeal and underfunding approach. It would also have a very positive impact on the community's health-physically and emotionally."

Summary and conclusions about repair and renovation
Housing units on reserve are not being well-maintained. Most First Nation leaders interviewed suggested that insufficient funding does not allow them to get ahead of the curve of need. As quickly as new units come on stream, they require aggressive maintenance because of the overcrowding and heavy "wear and tear" they take. There is not yet sufficient capacity within First Nation communities to do the maintenance and limited personal funds with which to afford household maintenance. The consequences are manifold: maintaining housing stock is costly, poorly maintained housing is unsafe and contributes to poor health, which in itself generates additional costs.

5.3 How has existing governance impacted on-reserve housing outcomes?

Findings: There is general consensus that the role of INAC and CMHC is, and should be, primarily that of a funder. However, First Nations also expect that both agencies will take a stronger role in helping them build the kind of capacity that ultimately will facilitate their complete control over the management of on-reserve housing along with the appropriate accountabilities.

There is a lack of consensus among all stakeholders as to what the concept of shared responsibility for on-reserve housing means. Until a consensus is achieved, First Nations' attempts to build local governance structures on reserve to manage housing may be compromised.

First Nations are increasingly gaining a solid understanding of their accountabilities for their housing funds.

5.3.1 "Shared Responsibility": a key tenet of the 1996 On-Reserve Housing Policy

The concept of shared responsibility for on-reserve housing is a key component of the 1996 Housing Policy. Although the 1996 policy does not expressly define it, the RCAP report states, "First Nations believe that the provision of housing and services is a treaty right but that the federal government disagrees." "Until Aboriginal nations can take over the [housing] field, Canadian governments have an obligation to ensure adequate shelter for all Aboriginal people." RCAP proposes that Aboriginal people and communities should help to meet their housing costs and suggests a two-thirds government, one-third Aboriginal split in the cost of on-reserve housing." [Note 44]

Generally, key informants contributed strong views on this question. Headquarters-based government respondents were evenly split on whether they believe shared responsibility had been achieved. Specifically, as described by a key informant in case studies, "INAC needs to be accountable for fulfilling responsibilities to First Nations, which, in turn, need to be accountable to their members for fairness and transparency in managing housing and to INAC for how funds are spent." A number of regional level government officials said that the concept is not clear. They felt, on balance, that there should be accountability on both sides and that today, there was only partial "shared responsibility." Twenty five percent of First Nations high level said that shared responsibility implied increased autonomy for First Nations: "ultimately the onus of control must be with the communities and this is not really happening because the communities cannot determine the level of funding they require to fix their housing problems." Seventy one percent of First Nations Direct respondents described shared responsibility in terms of a model where the federal government provides funding for housing and other forms of support and First Nations have the authority and capacity to deliver housing programs themselves. Nineteen percent of First Nations Direct respondents described a model where the federal government and First Nations are partners involved in sharing operations and maintenance of homes on reserve.

The interviewees from the case studies observed: "First Nations people want to be seen as stewards of the land; shared responsibility should reflect this and we should not have to fight for money." "Shared responsibility is not happening. The federal government just gives our band money without realizing the responsibility of the band to the community." "Shared responsibility was not part of the original agreement between the Crown and Elders. The chief and council take care of the Crown's administrative duties so when people don't get housing, they are blamed. There should be more contact between First Nations and the feds and we should be seen to be working together." "Feds have policies and we make sure our people respect them." "I see shared responsibility this way. The First Nation identifies the programs and needs of the community; they provide the structure through housing committees and the development of policies. We also continue the relationship with the feds. INAC should continue to provide the money as is their fiduciary responsibility. CMHC should deliver (and provide oversight for) the programs that First Nations have identified. This has not been achieved." "[Another meaning of] (...) shared responsibility is that the repairs and renovations that must be completed should be shared with homeowners and the housing department using federal monies." "INAC gave us contribution money [to build houses] but the houses were not up to par. Now with CMHC, we must pay mortgage. A portion comes from INAC and our shared responsibility is a community contribution to the mortgage."

If "shared responsibility" is one of the cornerstones of the 1996 Policy, it is easy to understand why the ongoing lack of consensus among stakeholders as to what it means could affect attitudes to governance and governance structures at every level and among all stakeholders. If partnerships are to grow from a commitment by all stakeholders to assume "shared responsibility," there will need to be more of what the Auditor General, in her 2003 April Report, refers to as "meaningful consultation with First Nations" on this issue.

The Auditor General made the above comment in the context of her concern that an ongoing lack of clarity of roles between INAC and CMHC was having a negative effect of program participation and the management of housing on reserves. "We expected that following the approval of a new housing policy in 1996, the Department and CMHC would have clearly defined their roles and responsibilities and expected results, both for themselves and for the First Nations governments and individuals involved. However, we found little consensus among the parties on what they believed their respective roles and responsibilities to be to address the housing needs of people living on reserve. We also found that the Department's and CMHC's programs and funding mechanisms to support on-reserve housing are complex and need to be streamlined." [Note 45] In her 2006 May Status Report, the Auditor General noted some progress although she tempered her praise by pointing out that the areas where there had been a lack of progress are those which are "most likely to improve the lives of First Nations peoples." [Note 46] She did indicate that "we found that housing programs are now better integrated and many elements are now better managed by the responsible organization." [Note 47]

A recently completed audit by INAC of its on-reserve housing program supports the Auditor General's observations about the impact of this ongoing lack of clarity around roles and responsibilities. [Note 48] The audit covers a wide-range of management issues and concludes that "although progress has been made, there remain significant gaps to provide assurance that governance, risk management and control frameworks are adequate to provide a reasonable expectation that funds are used for the intended purpose and that outcomes will be achieved."

5.3.2 Local Operational Control

The literature review underscores that "effective governance is the single greatest contributing factor to a community's socio-economic progress and overall well-being." The idea that Aboriginal peoples should control their own housing was the strongest theme throughout the literature reviewed. The work of the Aboriginal Housing Committee of British Columbia [Note 49] is referenced in the review. The committee examined several domestic and international models for the governance of locally controlled housing and then presented the findings to First Nations focus groups throughout British Columbia to get feedback on the feasibility of establishing Housing Authorities in the province. Their research indicated that the critical success factors were: Aboriginal control over housing; Housing Authorities placed at a regional or tribal council level; financial resources to operate authorities; increases to current human resource capacity to operate Authorities; education of and communication with communities; and partnerships between government agencies and First Nations to bring about authorities.

From elsewhere in the literature review, William Tilmouth, the Executive Director of Tangentyere Council in Australia states that "It is not good public policy to exclude people from any form of involvement in the management of their housing." He calls for a diverse, community-owned and managed affordable housing sector responsive to local needs. [Note 50]

CMHC research on the establishment of on-reserve housing authorities suggests that Housing Authorities may be very effective for on-reserve housing management. The research identifies four generic models of organizational structure and relationship with varying degrees of autonomy that would be helpful in designing housing authorities [Table 5.4]. [Note 51]

Table 5.4: Models and their characteristics of Housing Authorities

Source: CMHC Research

The 1996 On-Reserve Housing Policy encouraged the establishment of local housing administrative entities - Housing Authorities which were intended to operate as quasi-property managers, rental agencies, manage day to day operations and make recommendations to the chief and council on new or revised housing policies and programs and plans.

The overarching point, however, is that managing housing on reserve is complex enough, even for the smaller First Nations that each will need to consider carefully which administrative structure they put in place to manage the necessary functions. Under the current CFAs and DFNFAs, selecting an administrative structure is very much within the purview of individual First Nations.

5.3.3 Accountability

Government key informants identified managing accountabilities between two different departments, each of which had responsibility for similar but not identical aspects of on-reserve housing funding, to be challenging. One third of these respondents said that government should increase its accountability measures in order to better enforce housing standards and ensure that housing needs are met.

The concerns of these government informants were strongly echoed in a recent INAC audit of on-reserve housing: "...First Nations operating under the 1996 Policy (the majority of INAC funding) have flexibility in prioritizing the use of their INAC housing funds. Further flexibility is provided to the First Nations on five year agreements allowing for transfer of housing funds to other community priorities outside of housing. Furthermore, INAC's Band Based Minor Capital is not the only source of funding for on-reserve housing. CMHC provides funding that supports the construction and rehabilitation of housing on reserve and First Nations also contribute their own funding towards housing.

"Performance information that is collected and reported for the above noted performance indicators pertains to all on-reserve housing, and is not isolated to housing that is solely funded by INAC. The Department does not track First Nation on-reserve housing expenditure and performance information that can be solely linked to funding by INAC. Consequently, the Department is not able to specifically demonstrate the extent to which INAC funding contributes to performance and results related to on-reserve housing." [Note 52]

First Nations which have CFAs or DFNFAs as their funding mechanism are asked to report on their funding activities annually and have audited financial statements. In 2008, INAC increased accountability measures through the addition of an audit clause in its funding agreements. The clause ensures INAC's right to conduct audits of funding agreements to make certain that contributions are used for intended programs and services. Managed on a risk basis, these audits are expected to help guide new program and policy approaches, provide insight on improvements and support departmental accountability. [Note 53]

In 2009, INAC's Community Infrastructure Branch developed a performance measurement strategy for CFM, which included a component for housing. [Note 54] The strategy gives the outcomes against which INAC will be assessed with regard to its housing support, but it does not address the difficulty of managing accountabilities between the two entities. Nor does it address the fact that "Information related to performance indicators for housing is primarily obtained through the self-reporting of First Nations. First Nations submit Housing and Infrastructure Reports annually to the regions that include specified housing information. However, while the funding agreements can now be audited, performance measurement information is not subject to meaningful review and challenges by regions. There is risk that housing performance information being tracked and reported by the department is not accurate, complete and reliable." [Note 55]

Another aspect of accountability which arose through the 2008 evaluation of the 1996 On-Reserve Housing Policy was that INAC was not able to determine what proportion of First Nations had an adequate "inspection regime." According to the 2010 audit, it is likely that INAC's regional offices do not track inspections in a consistent way nor do they track what training occurs on reserves, or what the "take up" is from job creation or business development programs related to on-reserve housing.

Summary and conclusions about governance
The key informant interviews indicate that there is ongoing confusion about the roles and responsibilities of INAC and CMHC regarding on-reserve housing. Moreover, there is no shared understanding or acceptance of what shared responsibility means for the management of on–reserve housing. Shared responsibility remains a key tenet of the 1996 Policy. Until this confusion is addressed, it may be difficult for issues related to the governance of reserve housing to be addressed.

Notwithstanding the as-yet-unresolved issue around the meaning of shared responsibility, all stakeholders recognise that local control is a critical success factor for the future of on-reserve housing. First Nations continue to consider the most effective administrative structures to facilitate the management of their community's housing. INAC and CMHC are supporting these efforts by researching best practices.

Accountability mechanisms are an essential element in good governance. A recent audit of the on-reserve housing program identified opportunities to strengthen governance over housing in the areas of program design, performance management, risk management and guidance.

5.4 Have INAC's on–reserve housing policies and programs increased community capacity to manage and administer housing?

Finding: Although INAC and CMHC have independently offered capacity building support in a variety of ways over 13 years, they appear to have done so without a clear vision of what kinds of capacities are needed and by whom and without the benefit of a harmonized strategy, which could harness their joint efforts to obtain better results.

There is little evidence from this evaluation that INAC made the necessary strategic preparations to assist First Nations in building the necessary capacity so that they could take full advantage of what the policy was offering.

The key policy change introduced in the 1996 On-Reserve Housing Policy was to give First Nations the flexibility to use their housing allocations for construction and renovations and implement improvements to the way they delivered housing assistance in their communities. However, this new-found flexibility did not necessarily lead to substantial improvements in housing conditions. Hard choices have been required from First Nation leaders and not all of them were sufficiently prepared to understand the consequences of the choices.

The 2008 Evaluation of the 1996 On-Reserve Housing Policy states that, based on information gathered in interviews with chiefs and councillors, community members, housing owners and occupants, housing managers and building inspectors, "There was a clear consensus that building the capacity of all these stakeholders was still a critical need. INAC's capacity building activities are managed at the regional level with considerable variation." [Note 56] While First Nations may report on training initiatives as part of their annual reporting requirements, these data are not mined in a format extractable for meaningful analysis.

In the current evaluation, First Nations respondents expressed sentiments very in accord with one respondent who observed: "The primary fault of existing capacity building initiatives is that they are reactive, that there is no realistic assessment of what the community's capacity needs are. Most activities are one day workshops when longer training sessions are required, there is no overall training plan in place, when nothing is tailored to the needs of each First Nation and there is not enough funding."

Part of the issue seems to be that the competency and capacity requirements have not been well-articulated. However, from the document review, the key informant interviews and case studies, one could assume that capacity building in financial literacy, economic development, small business development, procurement, housing related trades training, and property management amongst others, are at a minimum, the areas in which First Nations still need support.

5.4.1 Key capacity: Financial literacy

Housing management for on-reserve housing requires a very unique kind of financial literacy. Understanding the strengths and limitations around the costs of promoting home ownership compared to establishing rental regimes is just one of many unique financial issues, which on-reserve housing managers would need to understand and be able to communicate with others.

A study examining First Nations Housing Management Training concluded that there are few training programs being utilized by First Nations Housing Managers. It presented a wide array of recommendations, including: developing a standardized national training and certification program for First Nations Housing Managers, reviewing pay scales for housing managers based on skills required, investigating mentoring as a mandatory requirement for certification and establishing a First Nations Housing Education Advisory board.

The requirement to help develop financial literacy around housing management should not be a difficult one to fulfill. There are impressive resources available, generated by banks, credit unions, community organizations, high schools, ethnic organizations and non-government organizations. There are equally impressive tools that could be quickly adapted to make the learning easy and the content culturally appropriate and useful. The lack of existing training programs specifically focused on the financial literacy requirements of on-reserve housing managers may suggest an opportunity for follow up.

5.4.2 Key capacity: Economic Development and Training linked to housing

Local administration of on-reserve housing has not created as much economic development and employment activity for First Nations as foreseen.

A reasonable expectation of the 1996 On-Reserve Housing Policy was that, with the funding increasingly in their hands, First Nations would find a way to create economic development and employment opportunities related to construction, maintenance and renovation. However, to make that expectation a reality, a great deal more capacity needed to be developed within most communities. INAC appeared to understand that need, but the ways in which it supported capacity development proved to be inefficient and frustrating to First Nations. Businesses do not start themselves, plumbers, electricians do not train themselves, and band housing managers do not necessarily understand without training how to create rental regimes or apply for support from CMHC. The element that was missing was a strategic "situation analysis", by which each First Nation could identify the competency gaps within its communities and begin the process of filling the gaps. The starting point should have emerged from the process of developing a community plan.

A 2006 CMHC study on the Economic Impact of Residential Construction On-Reserve stated that researchers did not observe a positive link between the level of economic development and the local economic impact of residential construction." [Note 57]

This is a regrettable finding and one which would suggest that there might be a missed opportunity. With 615 First Nations spread over close to 1,000 communities, each with an average of 105 housing units, First Nations housing is, in a sense, its own industry. Given the volume of construction materials purchased annually across the country by First Nations, it seems reasonable to imagine possibilities and benefits to developing partnerships with selected construction industry partners. A.J. Doxtdator suggested such possibilities for such partnerships in his analysis of the potential value of First Nations, nationally and regionally, working with an association like the Canadian Window and Door Association, to gain access to the kinds of expertise for First Nations which might impact the longevity of their housing investments in a very positive way.

Partnerships take time and energy to develop but could have significant payoffs for First Nations with respect to creating economic development opportunities close to their homes.

5.4.3 Key Capacity: Training

One of the four goals of the 1996 INAC Housing Policy was the development of First Nation expertise through enhanced capacity development, particularly training. The policy allows First Nations to dedicate resources to housing- related training and encourages First Nations communities to link training programs to their housing plans.

Both INAC and CMHC have offered considerable training and skills development support to assist First Nations in developing their housing expertise.

INAC initiated a Housing Training Fund under Gathering Strength, to assist First Nations in the development of community housing policies, programs and plans. This funding was time-limited, however and the training is no longer offered.

The development of First Nations housing expertise is further supported by INAC's Innovative Housing Project. Supplementary funding of $2 million annually (up to $75,000 per project on a cost-shared basis) is made available to First Nations to demonstrate an innovative approach to the construction, renovation or management of on-reserve housing.

First Nations Building Inspectors

The First Nations Building Officer's Association (FNBOA) has established a national occupational standard for the First Nations Building Officer and has established standards of practice and code of ethics. According to the 2008 evaluation of the 1996 Housing Policy, the First Nations National Housing Managers Association and FNBOA, both of which are designed to build capacity in First Nations, have been supported by INAC and CMHC, but do not receive core funding to ensure their success. INAC does, however, provide funding to tribal councils and First Nations technical services to provide technical support, including housing inspections.

A study on building strong technical organizations argues that as INAC continues to devolve responsibility to First Nations, there is a critical need for highly skilled First Nations people to take positions [within these organizations] but the lack of government commitment to core fund these organizations puts them at risk. According to a study commissioned by CMHC, they need stable long-term funding so they can hire professional staff and become legitimate entities in the eyes of communities. [Note 58]

Other Best Practices amongst First Nations

Some best practices related to training and capacity development come from the Mohawks of the Bay of Quinte who, in consultation with other First Nations across the country and government housing officials, have developed a community housing plan training package to assist other First Nations in developing and implementing their community-based housing policies and programs.

Ongoing insufficiency of training needs

Notwithstanding these efforts, there is consensus among key informants and from the document review, particularly of former evaluations,that the training has been insufficient to meet needs. The 2008 evaluation of the 1996 On-Reserve Housing Policy found that the skills and experience of housing staff vary widely between First Nations. It also found that First Nations representatives felt that that too much training was focused on leadership and that training directed to housing managers was very limited. There is known to be a high turnover in housing managers on reserve, and First Nations reported finding it difficult to retain a "trained" housing manager. [Note 59]

The 2008 Special Study on INAC's Funding Arrangements Final Report points to the need for training in highly skilled areas. It recommends that First Nations receive targeted capacity building and not just "capacity building components in a range of programs that are not coordinated or strategic." [Note 60]

The impact assessment of the 1996 On-Reserve Housing Policy confirms the shortage of staff on-reserve. [Note 61] Citing evidence obtained through site visits, the report finds that First Nations, and possibly even INAC offices, are understaffed in the housing area.

Interestingly, with all of the above, about three quarters of the First Nations interviewees when asked, did not identify capacity building programs.

Summary and conclusions

Thirteen years after the introduction of the policy, First Nations are still asking for help to build capacity. There is little evidence that the efforts of INAC have yielded positive results in this regard. This evaluation found no evidence of a strategic and coordinated approach to capacity building between INAC and CMHC.

6. Evaluation Findings - Design and Delivery

According to almost all key informants and several documents reviewed (as discussed below), the On-Reserve Housing Policy was poorly communicated to First Nations. More importantly, the evidence suggests that the design of the program does not reflect what First Nations would have wanted for their communities.

With respect to the delivery of programming, First Nations key informants suggested that there has been an assumption of homogeneity in community life for First Nations, which does not reflect their realities, and that the policy has a "one size fits all" dimension to it. Key informants suggested many potential ways to improve the delivery of the Housing Policy.

6.1 Was the design of on-reserve programming consistent with the First Nations housing needs? Could the design reasonably be expected to contribute meaningfully to the desired outcomes?

Finding: The design of housing programs stemming from the 1996 On-Reserve Housing Policy did not and does not yet adequately reflect the perspectives of First Nations. The lack of adequate support for capacity-building has meant that the design of the program was inherently flawed and thus may not have been able to contribute adequately to the desired outcomes.

With respect to the design of the 1996 Housing Policy, there was a high degree of consensus among key informants that the policy was based on an ambitious plan for the provision of on-reserve housing that had neither sufficient resources nor an adequate consideration of the many different kinds of capacity-building requirements that would ensue as First Nations were given greater local control over housing. As noted in the previous chapter, in moving from policy to program, there is no evidence that INAC, separately or together with CMHC, developed a strategic approach to capacity building. Despite several injections of supplementary funding over the period from 1996-2010, many interviewees suggested this lack of capacity-building is at least partially responsible for the gap between the objectives of the program and its actual results. Several reports, as discussed below, substantiate these observations.

6.1.1 Evolution of 1996 On-Reserve Housing Policy

There is little documentation available with respect to the process by which the 1996 Policy was developed. A document review of INAC archives, dating back to1990, yielded three documents that appear to have influenced the policy formation process.

In the 1960's, INAC introduced a housing program to assist in the construction and renovation of housing on reserves. The program provided subsidies for new residential construction and the renovation and rehabilitation of existing houses. In 1982, this subsidy program was evaluated and a position paper was written which further clarified the roles of First Nations and the federal government, stating that the government's role in the delivery of houses was, by then, "residual." A major evaluation of the program was undertaken and concluded that housing on reserve was seriously inadequate. [Note 62]

"Indian Housing On-Reserves: Towards a New Federal Policy and Approach," [Note 63] a paper produced in 1989 by an INAC Housing Review Working Group, acknowledged the limitations of the then-current approaches, including the limited support for maintenance, repair and renovation, unrealistic subsidy levels, an approach based on universality versus needs and ability to pay, limited First Nations control of policy and design, an absence of multi-year funding arrangements and overreliance on single unit housing. This paper proposed a federal policy which would, "(...) assist Indian people in gaining access to affordable, suitable and adequate shelter, consistent with basic Canadian standards in comparable circumstances (...)." [Note 64]

In the same year, another informal working group produced a document entitled On-Reserve Housing Policy: Summary of Recommendations, 1989, which was a synopsis of other documents drafted by INAC, the AFN, the Federation of Saskatchewan Indian Nations and the Dakota Ojibway Tribal Council. This synopsis called for:

• the establishment of comprehensive and adequately funded support programs to provide financial and technical assistance to enable Indians to maintain, repair and renovate homes;
• increased federal funding and encouragement of more responsibility for housing costs by individuals and families;
• a definition of on-reserve ownership and corresponding responsibility;
• expanded support to find ways, through training and development, to ensure exponential economic and employment benefits to First Nations through housing activity; and
• a series of options to be made available to First Nations and tribal councils so communities can determine what best suits their needs. [Note 65]

A 1990 INAC discussion paper "Laying the Foundations of a New On-Reserve Housing Program," notes the following problems with on-reserve housing: lack of First Nation control, inadequate housing supply, poor quality housing, high costs, rising band debt load, lack of security tenure and insufficient economic and employment benefits associated with on-reserve housing construction. This discussion paper calls for a partnership between government and First Nations based on the following three principles:

• That the provision of adequate housing must be understood as a shared responsibility between both government and First Nations;
• First Nations Authorities must assume control of programming so that it can adequately support and reflect First Nations; and
• there must be clear government roles and responsibilities regarding the provision of on-reserve housing." [Note 66]

This paper advocated an overarching federal policy governing on-reserve housing, as opposed to having several agencies/departments responsible for some portion of federal obligations for on-reserve housing.

When the actual 1996 On-Reserve Housing Policy was launched, while the core elements remained, there were some important differences between proposed policy approaches identified by internal working groups and the eventual policy. There was no provision in the 1996 Policy Guidelines for strengthening First Nation capacity (although capacity development is identified as one of the principles along with self sufficiency). It was silent on clarifying federal responsibilities and improving the delivery and coordination of federal programs but spoke at length about the need for First Nations to develop local housing policies, programs and multi-year housing plans (including work plans linked to an appropriately funded resource plan). The third component was to link the activities with training, job creation and business development initiatives. The initial discussion paper suggested multi-year funding to correspond with the multi-year housing plan but this did not translate into reality for most communities.

6.1.2 Communicating and Supporting the Policy

Given the evidence, particularly from all levels of key informants, there is no question that some of the concerns raised by First Nations' stakeholders in this evaluation about the extent to which the 1996 Policy reflects their perspective links directly back to their consistent view that the housing policy was never clearly communicated to them. While the Guidelines for the Development of First Nations Housing Proposals, a set of guidelines intended to accompany a statement of the policy and assist First Nations to understand how the policy was to be implemented was distributed, there was no document in which the entire policy was articulated.

Headquarters based government officials suggested that the policy provided more control and decision-making to First Nations and that there was incentive funding in the first few years. But they also indicated that: INAC cannot demonstrate accountability, presumably because the existing funding agreements did not oblige First Nations to inform INAC on how they spend housing funds (although funding agreements are now subject to audit review); the implementation of the policy required more highly complex local policy-making and planning capacity than existed on most First Nations communities; there was insufficient funding to build capacity; and the 1996 Policy assumed a homogeneity amongst First Nations.

Regional government officials suggested that expectations within the policy about First Nations' interest in home ownership and ability to achieve it needed to be adjusted. Some key informants and respondents in the case studies indicated that home ownership may be more suitable for "strong" [that is, solvent] First Nations but impossible for small remote ones. They wanted to see more collaboration among federal departments and the collective federal reporting requirements "interfaced" to lessen the reporting burden on First Nations.

Sixty-eight percent of First Nations high level respondents stated that the current federal programs are not the most effective and efficient way to meet new housing demands. Forty-seven percent said that the housing policy is neither well-defined nor well-communicated. Fifty-three percent said that the policy does not reflect First Nation's perspectives. Sixteen percent said sometimes the policy and program do reflect First Nations' perspectives such as home ownership being encouraged through an initiative like First Nations Market Housing Fund. Some respondents said that the policy was good but the follow up was weak and that there had been too many "regime" changes.They urged that the Government revisit the Kelowna Accord and the Housing Tables of 2004.

Sixty percent of First Nations Direct respondents claimed that the Housing Policy had not been communicated to them at all. Seventy-one percent said that they could not really support it. "They came to the community and made us aware of some of the programs and activities but in terms of implementing them, really nothing [...] just Q's and A's - a process where First Nations would ask questions on policies and procedures."

Findings from the August 2010 Audit of the On-Reserve Housing Program supports the comments made above. The audit found that "...national guidelines for the management of housing funded by Band Based Minor Capital are not in place. It is noted, however, that a National Housing Procedures Guide document had been initiated but was not completed. Regions are aware and have a consistent understanding of the general requirements related to the administration of housing funds. However, in the absence of national guidance, many regions have, to varying degrees, developed and implemented their own practices in administering housing funds. Consequently, a number of inconsistencies exist among regions with respect to management practices and reporting expectations related to housing." [Note 67]

6.1.3 Impact of lack of clarity in the roles and responsibilities between INAC and CMHC for on-reserve housing

Beyond the fact that the policy was poorly communicated, another factor which has likely compromised the design of housing programming was the lack of clarity amongst the stakeholders about the roles and responsibilities of INAC and CMHC for on-reserve housing.

Findings from Key informants interviewed for the case studies support the Auditor General's 2003 finding that First Nations organisations are not always clear about the respective roles of INAC and CMHC, suggesting that there remains some confusion at the grass roots level about which organisation does what to support on-reserve housing.

6.1.4 Community housing plans: an essential element in the design of the housing program

A practical guide was published to assist First Nations in developing these policies, programs and plans. The multiyear plans were to allow First Nations to:

• Protect and extend the life of existing houses and ensure that housing meets minimum national standards, through maintenance, insurance and renovation programs;
• Construct quality affordable new housing designed to respond to the variety of housing needs within the community;
• Support individual pride and responsibility through community involvement, home ownership incentives and private market investment ; and
• Link housing activities to training, job creation and business development.

These multi-year plans were the main tools for achieving the policy goals. The initial incentive for developing the plans was the additional capital funding that First Nations were being offered. The incentive over the longer term was the more flexible funding arrangement.

The 2008 evaluation posed specific questions to key informants, and concluded that the situation in the regions with regard to community housing plans varies considerably. In some regions, plans are not being submitted to the regional office, are not being updated or not being implemented.

In her 2006 Status Report, the Auditor General notes that "...to help facilitate the implementation of the Department's housing policy, CMHC worked with participating First Nations to develop community housing plans that link housing funds and programs with training, job creation, work opportunity programs and economic development activities. In 2003, these plans were not being used as intended and their implementation was not being monitored. In this audit, INAC and CMHC are now using community housing plans to identify the housing stock and as a tool to make decisions on new units to be built or units to be renovated. While this represents considerable progress, serious problems, notably mould contamination, remain." [Note 68]

Although the Auditor General observed progress, key informants in this study made virtually no reference to developing, having or using community plans related to housing. On the contrary, a lack of capacity in First Nations was cited by regional officials as the main reason for communities not preparing or updating community housing plans and insufficient staff in INAC's regional offices was cited as the main reason for not following up on reporting. Some regional offices also cited their own lack of capacity to follow-up on the plans. In other regions, regional offices are following up on the submission of plans and the majority of those First Nations are considered to take implementation of their plans seriously. [Note 69]

6.1.5 Home ownership versus rental regimes: options within the current program design

Is INAC's objective of promoting home ownership widely-shared amongst all First Nations?

The literature review contributes some interesting perspectives to the question of home ownership for First Nations. Alcantra argues that many First Nations are hesitant to pursue home ownership because they feel that it compromises a claim to a treaty right. Alcantra further argues that a Certificate of Possession system would result in greater productivity and higher standards of living. [Note 70] Brant underscores that many First Nations people are unsure about the tenure of the house they occupy. [Note 71] Flanagan states that "lacking pride in ownership, tenants neglect maintenance. Without incentive of ownership, there is chronic under-investment in housing. Private funds are not mobilized and the band never seems to have enough to meet its needs." [Note 72] All the literature reviewed comes down on the side that insecurity of tenure hinders members from accepting increased responsibility and investing in their homes; a point echoed by A.J. Doxtdator in his analysis of the condition assessments.

While many First Nation key informants would like to increase the level of home ownership, there are others who feel that home ownership is neither practical, affordable, nor possible for their circumstances; and prefer focussing on rental regimes.

First Nation members who wish to pursue home ownership appear to be able to gain access to debt financing more easily than in previous years. In 2007, 80 percent of First Nations (490/615) reserves had accessed a MLG for on-reserve housing. The total contingent liability has been steadily increased and now stands at $2.2 billion. There is an historical default rate of less than one percent (...)." [Note 73]

Key informants in the MLGs evaluation stated that MLGs can contribute to both quantity of affordable housing through loans for new housing units and quality by providing loans for renovations. [Note 74] Two-thirds of INAC key informants stated that the MLGs contribute to the objectives of the 1996 Housing Policy and that they provide for more flexibility and more options for private capital. First Nations key informants felt that the lack of skills and continuity slow the process for communities wanting to utilize MLGs for housing purposes. "A significant number of First Nations lack basic understandings of the use of loan financing within housing development plans, and factors, such as high turnover rates, workload levels and knowledge gaps currently pose a significant risk to effective management of MLGs." [Note 75]

Case study informants for the MLG evaluation felt that there can be a difficulty created for First Nations in maintaining positive cash flow. If they have no rental income, it can be difficult for First Nations to stay out of arrears. Those with their own source revenue have an easier time directing revenue back to community housing. Those that rely on government transfers find that the cash to pay back loans comes at the expense of other community needs." [Note 76]

Doxtdator's analysis suggests that impetus has been placed on the idea of the "pride of home ownership," suggesting that the concept is admirable and is actually feasible in some communities. It is noted that in First Nations communities, like in any other community, needs are varied and reflect the demographics of the geographic area. Providing a homeowner access to capital would instil the true intent of the "pride of home ownership" and that it is difficult to gain the intended pride when resources are delivered through a social program.

The alternative for a First Nation to promoting home ownership (and bearing the risk of the homeowner defaulting on his/her loan) is for a band to build housing units, rent them to band members and establish a rental regime. Anyone who is on income assistance on reserve is eligible for a shelter allowance but must produce proof of their shelter costs, usually in the form of a formal rental agreement with the band, to receive the shelter allowance. If they do not receive the shelter allowance, they have no means to pay for their accommodation or utilities and the band would not receive any income for their occupancy of the housing unit. However, establishing and managing a rental regime requires certain kinds of capacity and many First Nations and other key informants say that it is a skill that is not always present within the community.

Summary and conclusion regarding the design of programming stemming from the 1996 On-Reserve Housing Policy

The design of the 1996 On-Reserve Housing Policy and its resultant programs did not adequately incorporate a First Nations' perspective. The policy was poorly communicated to First Nations. There was no consensus in 1996, and none exists yet amongst stakeholders, as to the meaning of the key tenet of the policy – shared responsibility. Moreover, the ensuing lack of support for adequate capacity-building has meant that the design was inherently flawed. There has not yet been a strategic, coordinated, plan between the INAC and CMHC, with First Nations, as to how to build capacity. Ongoing confusion for First Nations concerning the roles and responsibilities of INAC and CMHC further detracts from the effectiveness of the design. First Nations who wish to consider home ownership appear able to access the MLGs, which are often a pre-condition for purchase of a home. For other First Nations, home ownership is not an immediate priority and their challenge is to establish a fair and effective rental regime.

6.2 Has the implementation of the On-reserve Housing Program led to the anticipated and desired outcomes?

Finding: The successful implementation of the On-Reserve Housing programming was compromised by: the lack of a clear and widely-disseminated policy; operational guidelines that were flexible enough to support the policy in a variety of situations; effective communication from INAC to First Nations about the Housing Policy; and a lack of follow- up on INAC's part when problems surfaced with aspects of the policy. A lack of capacity within Government and First Nations' communities also hampered effective implementation of the policy.

6.2.1 Impact of the structure of funding agreements on implementation

The structure of funding arrangements affected delivery. The policy called for multiyear housing plans, which set up an expectation that there could/would be multiyear funding; however, neither the multiyear plans nor the funding occurred. Several key stakeholders – both government officials and First Nations leaders and community members – indicated that multiyear funding for housing would have helped create more favourable circumstances to reach the objectives of the Housing Policy.

6.2.2 Operational issues which affected the delivery of the housing program

The First Nations high level and direct key informants provided some illustrative, but not exhaustive, examples of operational issues, which, in their views, compromised the effectiveness of the program. They included that:

• the amounts permitted for housing repairs are insufficient and that both INAC and CMHC fund repairs but their programs have different ceiling amounts;
• housing policy guidelines state that INAC projects must be completed within a year, which prevents long-term planning;
• often there is a delay for First Nation communities in receiving their annual funding allocation, which means that "the shovel only hits the ground" in October, and in many First Nations communities, that is too late in the season to build;
• there can be substantial delays in the mobilization process, particularly in the delivery of building materials;
• the policy decision to provide employment to the unemployed, rather than to improve the skills of already employed persons, means that there are no provisions for taking employable students past the first year of trades training; and
• provincial rates and eligibility criteria for shelter allowances should not always have to be followed on reserve. Key informants argue that the First Nations "shelter allowance" funding envelope is not usually large enough to implement the rates set by provinces.

They key informants argue that allowing more flexibility in the delivery of the program could improve its effectiveness.

7. Evaluation Findings - Cost-Effectiveness and Efficiency

7.1 Have INAC's on-reserve housing policies, programs and initiatives been cost-effective?

Finding: The design of the funding structure for INAC's On-Reserve Housing programming does not allow for a comprehensive or empirical analysis of cost-effectiveness. However, the belief held by key informants in this study is that the current approach to funding and otherwise supporting on-reserve housing in Canada is ineffective from both financial and social perspective.

Cost-effectiveness considers whether the most appropriate and efficient means are being used to achieve certain objectives and whether alternative approaches would be less costly and/or more successful. Its application to this evaluation would have to take into account whether an acceptable number of new housing units were created, damaged houses repaired and lots serviced relative to the funds spent. It would also have to take into account whether and how the investments in housing had improved the quality of life for First Nations on reserve.

Assessing cost-effectiveness from a financial perspective ─ the more conventional way ─ is difficult because of the way in which the funding arrangements work between INAC and most First Nations. Funds are transferred to First Nations on an annual basis as part of the Comprehensive Funding Agreement or through five year DFNFA's. It is only in the case of British Columbia First Nations and 20 percent of the communities in Ontario that INAC can verify how funds are spent. With the CFAs and DFNFAs, and as part of local control, First Nations can determine where the money goes based on their community's priorities. Housing funds can be used for new construction, repairs or renovations, maintenance or servicing lots. First Nations communities can also request and receive funding for specific projects from a variety of CMHC programs, some of which can supplement INAC funds. INAC does not receive information about CMHC investments. The overall situation ─ limited information from First Nations on their housing-related spending; no access to information about CMHC expenditures ─ means that INAC cannot establish, as a baseline what a specific housing "intervention" costs and thus, it is close to impossible to measure cost-effectiveness in any conventional way.

Given that CMHC was not jointly involved in the evaluation, it was beyond the scope of this evaluation to analyse thoroughly where there is any overlap and duplication between INAC and CMHC. Federal key informants did speak about their experiences in which they felt there was a duplication of efforts between INAC and CMHC; most had also observed that there was a burden placed on First Nations who often had to duplicate paperwork to obtain funds from both INAC and CMHC. Many felt that the information requirements between the two could be better harmonized. Several stakeholders broached the question of whether there should be two federal agencies, each with such substantial responsibilities for on-reserve housing or whether one entity would ultimately be more cost-effective.

How can we measure cost-effectiveness of funding for on-reserve housing from a social perspective? On-site observations, housing condition assessments and all key informant interviews would point to significant negative outcomes regarding quality of life issues: large numbers of on-reserve First Nations families live in substandard housing; the most significant health issues, which result from substandard housing ─ respiratory illnesses and accidents ─ cost incalculable amounts of physical hardships to children and others; overcrowding leads to strained family relations and mental health issues; and the year-to-year nature of the funding does not give rise to a sense of hopefulness about change. There are no data to show that the outcomes have improved over time or with the supplemental funding given several times in the thirteen year time frame. To the contrary, the literature review, administrative data and census information, case studies and key informant interviews found that conditions were not improving. Gains made in reducing overcrowding have been lost to increased costs and loss of affordability.

As First Nations take increasing control of managing housing, they too will have an interest in being able to measure cost-effectiveness. Being able to measure cost-effectiveness is an area that warrants further discussion and consideration so that, in advance of future evaluations, there can be some agreement between First Nations and INAC about what information is of mutual benefit to help measure cost-effectiveness.

7.2 Have INAC's administrative systems and operational practices allowed for the efficient delivery of on-reserve housing programs and initiatives?

Finding: There are no general findings about efficiency because of data limitations. There are some findings which speak to inefficiencies related to operational matters.

There is a flaw in program accountability, as INACHQ does not have in place appropriate operational systems to receive and approve FN housing community plans starting in 1997. The Regions are responsible for managing these reports, but they are not systematically recorded and managed in a database. This may have exacerbated difficulties in implementing the 1996 policy. Furthermore, all key informants made references to what they perceived to be inefficiencies related to timing. For example, the timing of the funding cycle runs counter to when construction decisions need to be made and acted upon. Budgets are allocated to departments on April 1st of each fiscal year. INAC's funds are then internally re-allocated to the regions, which in turn permits the regions to enter into agreements with First Nations and tribal councils. Once this process is completed, construction contractors can be hired. Often it is well into summer before all these activities take place and construction can begin. For First Nations, this can mean that "the shovel hits the ground in October." For a northern First Nation, most construction cannot go ahead between the end of October up until the end of March due to the effect of the cold on construction.

7.3 Are there alternative approaches which could achieve program outcomes more effectively?

Finding: There are many alternative approaches which are consistent with the objectives of the housing policy that may be able to contribute towards better housing outcomes. Community size and remoteness of some communities impact the viability of some of these options.

Critical success factors
According to the literature review, the experiences of communities which have successfully introduced alternative models to manage their housing suggest some critical success factors [Note 77]:

• the community took control of their situation;
• they worked with residents in their communities to determine what would work given their unique circumstances; and
• they had the support and investment from Government and often the private sector.

When these critical success factors are all present, the results include higher rates of home ownership, increased construction, more renovation and spin off benefits with respect to economic development. In addition, there is a sense of individual and community pride.

Alternative Financing Instruments to achieve home ownership

Among the existing alternatives to using MLGs to finance housing on reserve are the following:

• On-reserve Homeownership Loan Insurance Pilot Product without Ministerial Loan Guarantee (CMHC program): The First Nation sets up a trust (minimum $150,000) to provide security on the loan. The pilot program has been operating for five or six years, in fewer than five communities.
• First Nation Market Housing Fund: This fund replicates off-reserve lending and requires mortgage insurance. Bands need to qualify for the fund. To date, only six First Nations are participating [Note 78]. This fund is run by an independent entity, made up of nine trustees of government, lenders, and First Nations. CMHC manages the day-to-day activities of the fund.
• CMHC mortgage insurance (same as for off reserve). Cost would vary by community, and in some cases, the premium could be prohibitive.
• Grants for social housing: To have any effect, this would involve a large amount of capital funding which may not be practical.
• Revolving loan funds: This is currently being successfully implemented in a few communities but a stream of revenue, such as rental income, is required to make it viable.
• Conventional lending: Institutions, such as the Royal Bank of Canada, Bank of Montreal Organization and Caisse Populaire, are active in lending to First Nations for housing loans with First Nations with which they have good working relationships.
• Establishing a housing loan system could contribute to the economic growth of a community through its provision of increased capital within the local economy. The common feature is occupant contribution and use of financing instruments. [Note 79] Examples of communities that have successfully implemented this approach include the Mohawks of the Bay of Quinte, and Lac la Ronge First Nation.  In the case of the Mohawks of the Bay of Quinte, their housing policy states that residents cannot finance their own housing. This community used Government of Canada funding to initially set up a small revolving loan fund and became it became its own lending institution for home ownership, using certificates of possession as collateral. Over the years, the loan fund has increased through the repayment of loans and interest as well as through investment by a national bank. The result is over 80 percent home ownership on the reserve, increased construction standards incorporating energy efficiency, training of members as skilled workers in construction trades and the creation of local businesses that are competitive in surrounding communities. [Note 80]
• Public Private Partnership (P3). The definition embraced by The Canadian Council for Public-Private Partnerships is: a cooperative venture between the public and private sectors, built on the expertise of each partner, which best meets clearly defined public needs through the appropriate allocation of resources, risks and rewards. [Note 81] By its very definition, this type of arrangement could not be used for housing. However, it may be possible to leverage funds and expertise from the private sector for things such as roads, bridges and health centers, which could free up available capital to redirect towards housing.
• From the literature review, there is the innovative example to consider of how change was introduced on a large scale in response to an overwhelming national housing crisis is the Building Centers Movement in India. Building Centers at a grass-roots level function as guiding and counselling information centers to the general public as well as providing services to government/private institutions, non-government organizations and individuals. Building Centers provide training, production of building materials, distribution of materials, information and extension, research and development, consultancy and guidance and construction. Today, the movement is a nationwide network consisting of over 1000 centers throughout India and elsewhere in the world. The movement is strongly rooted in the local strengths and community action and trains and utilizes local artisans for building.

Improvements to housing design

Almost all key informants and especially First Nations key informants made some reference to housing designs which were poorly thought out for the locales in which the houses were to be built. There are two dimensions to what appears to have made the designs unacceptable: structurally, they did not take into account the environmental stresses; and, culturally, they were inappropriate in many ways. Canada is a member of several circumpolar organizations; that membership could potentially be a conduit for research generated by other member countries into housing designs suitable for harsh northern climates.

Improvements to planning processes

Many First Nations respondents indicated that they would welcome help building capacity to manage a planning process around housing. Through Human Resources and Skills Development Canada's (HRSDC) Homelessness Partnering Strategy, there are over 80 communities in Canada which each have 10 years' experience with creating community plans with community input, adjusting those plans to realities, identifying competency gaps and moving to fill the gaps. The publicly available evaluation reports of this initiative could be informative as to lessons learned and best practices. In addition to the expertise of the HRSDC's Homelessness Partnering Strategy Secretariat, there are many community leaders among the 80 communities which received funds who could be approached to assist First Nations communities with planning.

Improvements to levels of economic development and employment generated through housing activity

It is clear from First Nation key respondents that they would like to leverage housing funds to improve economic development and employment. It could be helpful to these First Nations' aspirations if there was support by way of capacity development for generating models and examples of how small businesses and/or supplier arrangements could be developed.

Improvements to communications and knowledge transfer

Another area of concern repeated many times and by many different First Nation informants, had to do with First Nations feeling that there has been too little effective communication to them from the Government about managing housing. The current fragmented communications approaches appear not to be working. Statistics collected in the case studies indicated that a high percentage of houses on reserve have some access to a computer and the internet. Upon further exploration, this could open up new avenues for consideration about how to communicate with communities on issues such as best practices for home maintenance.

8. Evaluation Findings - Other Evaluation Issues

8.1 To what extent and in what ways does Shelter Allowance contribute to on-reserve housing? What are the lessons learned?

The objective of the evaluation is to determine whether the Shelter Allowance, as it relates to on-reserve housing, obtains value for money, whether the program is being delivered in a cost-effective manner and whether this component has achieved housing, particularly social housing objectives.

Findings:

Impact

Shelter Allowance funds are an important source for First Nations to pay for costs related to CMHC's Section 95 housing. In this way, they are used to help increase the overall housing stock. Key informants and information from case studies indicated that Shelter Allowance funding is typically prioritised in the following order: to pay for utility and fuel costs, mortgages under Section 95, and maintenance and repairs.

While key informants from INAC, CMHC and the provinces are consistent in their definition of the objective of Shelter Allowance to provide financial assistance for shelter to those in need, First Nations key informants were less clear on the objectives of the Shelter Allowance. While INAC stakeholders understood that the rates and eligibility criteria for Shelter Allowances are set by the province, about half of them believed that this is understood and well-communicated to First Nations communities.

Program Input

Findings from stakeholder interviews, case studies and the document review all noted that the rates for Shelter Allowances are not adequate to meet the needs of First Nations communities. Regardless of the community, the rates for Shelter Allowance do not adequately cover the rent and/or mortgage payments, fuel and utility costs and repairs and maintenance.

Design and Delivery

INAC regional offices administer the Shelter Allowance in compliance with the eligibility criteria set by the provinces. Shelter Allowance is provided as a component of Income Assistance and, in most provinces, is administered directly to the band which is both the service provider and the landlord. Recipients must qualify for Income Assistance in order to receive Shelter Allowance. A universal rental regime, that is one in which the community collects rent from both social assistance and non-social assistance recipients, is required for communities to receive Shelter Allowance. Case studies indicated that this was not always enforced. INAC and CMHC key informants noted that improvements to the delivery could be made.

8.2. To what extent and in what ways do MLGs contribute to on-reserve housing? What are the lessons learned?

Relevance

MLG objectives are consistent with government priorities for housing in First Nations communities. Access to MLGs has allowed communities to produce approximately 26,000 new housing units between 1996/97 and 2007/08. Interview respondents estimated that existing alternatives to MLGs are accessible to approximately 15 percent of First Nations. The conclusions drawn from the document and policy review is that the absence of MLGs would leave most First Nation communities with no alternative financing for housing on reserve. [Note 82] INAC does not currently measure whether MLG objectives are being achieved, nor has it set any performance targets or goals for MLGs. However, INAC interview respondents indicated that the Department monitors usage of the MLG authority, in addition to collecting information and tracking performances measures relevant to housing outcomes. According to a review of statistics and trends, MLGs are relied upon by First Nation communities to ensure access to financing for housing projects on reserve. Figure 8.1 shows the progression in the growth of MLGs given and their purposes over the period 1996-2009.

Figure 8.1: Progression in the growth and varied uses of MLGs between 1996 and 2008

This figure illustrates the progression in the growth of MLGs between 1996 and 2008 by borrower. The graph contains a line corresponding to Section 95, a line corresponding to band projects and a line corresponding to members. The graph also contains bars referring to the number of units and average loan value per unit. The fiscal years are located on the x-axis and the average loan value per unit and the number of units is located on the y-axes.

For the fiscal year 1996/1997, the bar section of the graph illustrates that the average loan value per unit was approximately $50,000 and the number of units was approximately 1800. For Section 95, the average loan value per unit was approximately $32,500 and the number of units was approximately 1150. For other band projects, the average loan value per unit was approximately $12,000 and the number of units was approximately 400. For members, the average loan value per unit was approximately $500 and the number of units was approximately 10.

For the fiscal year 1997/1998, the bar section of the graph illustrates that the average loan value per unit was approximately $54,000 and the number of units was approximately 1900. For Section 95, the average loan value per unit was approximately the average loan value per unit was approximately $36,000 and the number of units was approximately 1300. For other band projects, the average loan value per unit was approximately the average loan value per unit was approximately $16,000 and the number of units was approximately 700. For members, the average loan value per unit was approximately $650 and the number of units was approximately 20.

For the fiscal year 1998/1999, the bar section of the graph illustrates that the average loan value per unit was approximately $59,000 and the number of units was approximately 2200. For Section 95, the average loan value per unit was approximately $37,500 and the number of units was approximately 1400. For other band projects, the average loan value per unit was approximately $14,500 and the number of units was approximately 550. For members, the average loan value per unit was approximately $2500 and the number of units was approximately 80.

For the fiscal year 1999/2000, the bar section of the graph illustrates that the average loan value per unit was approximately $58,000 and the number of units was approximately 2050. For Section 95, the average loan value per unit was approximately $28,000 and the number of units was approximately 900. For other band projects, the average loan value per unit was approximately $17,000 and the number of units was approximately 700. For members, the average loan value per unit was approximately $5000 and the number of units was approximately 250.

For the fiscal year 2000/2001, the bar section of the graph illustrates that the average loan value per unit was approximately $64,000 and the number of units was approximately 2250. For Section 95, the average loan value per unit was approximately $32,500 and the number of units was approximately 1200. For other band projects, the average loan value per unit was approximately $14,000 and the number of units was approximately 450. For members, the average loan value per unit was approximately $4000 and the number of units was approximately 200.

For the fiscal year 2001/2002, the bar section of the graph illustrates that the average loan value per unit was approximately $65,500 and the number of units was approximately 2350. For Section 95, the average loan value per unit was approximately $28,500 and the number of units was approximately 1000. For other band projects, the average loan value per unit was approximately $6000 and the number of units was approximately 300. For members, the average loan value per unit was approximately $4200 and the number of units was approximately 225.

For the fiscal year 2002/2003, the bar section of the graph illustrates that the average loan value per unit was approximately $75,000 and the number of units was approximately 2650. For Section 95, the average loan value per unit was approximately $30,000 and the number of units was approximately 1500. For other band projects, the average loan value per unit was approximately $7000 and the number of units was approximately 350. For members, the average loan value per unit was approximately $4200 and the number of units was approximately 225.

For the fiscal year 2003/2004, the bar section of the graph illustrates that the average loan value per unit was approximately $78,000 and the number of units was approximately 2800. For Section 95, the average loan value per unit was approximately $29,000 and the number of units was approximately 1100. For other band projects, the average loan value per unit was approximately $10,000 and the number of units was approximately 400. For members, the average loan value per unit was approximately $4000 and the number of units was approximately 200.

For the fiscal year 2004/2005, the bar section of the graph illustrates that the average loan value per unit was approximately $76,000 and the number of units was approximately 2750. For Section 95, the average loan value per unit was approximately $26,000 and the number of units was approximately 800. For other band projects, the average loan value per unit was approximately $6000 and the number of units was approximately 300. For members, the average loan value per unit was approximately $5000 and the number of units was approximately 250.

For the fiscal year 2005/2006, the bar section of the graph illustrates that the average loan value per unit was approximately $80,000 and the number of units was approximately 2850. For Section 95, the average loan value per unit was approximately $30,000 and the number of units was approximately 1500. For other band projects, the average loan value per unit was approximately $14,500 and the number of units was approximately 475. For members, the average loan value per unit was approximately $6000 and the number of units was approximately 300.

For the fiscal year 2006/2007, the bar section of the graph illustrates that the average loan value per unit was approximately $83,500 and the number of units was approximately 2950. For Section 95, the average loan value per unit rose dramatically to approximately $95,000 and the number of units was approximately 3300. For other band projects, the average loan value per unit was approximately $4000 and the number of units was approximately 200. For members, the average loan value per unit was approximately $4000 and the number of units was approximately 200.

For the fiscal year 2007/2008, the bar section of the graph illustrates that the average loan value per unit was approximately the average loan value per unit was approximately $89,500 and the number of units was approximately 3200. For Section 95, the average loan value per unit declined to approximately $62,000 and the number of units was approximately 2200. For other band projects, the average loan value per unit was approximately $6000 and the number of units was approximately 300. For members, the average loan value per unit was approximately $3000 and the number of units was approximately 150.

Design and Delivery

The scope, objectives, and eligibility criteria for MLGs are generally clear in policy documents. While the overall process to obtain MLGs is consistent across Canada, there are slight regional variations. These variations are currently being addressed, notably with the creation of a new operational guide. The roles and responsibilities in the delivery of MLGs are documented [Note 83] and are generally understood and respected. Regions will be allocated a portion of the MLG authority to manage. Overall usage of the authority will be tracked in the new Guaranteed Loan Management Module. The risk exposure for the Government of Canada appears to be low, as interview respondents revealed loan defaults were unlikely, and historical default rates have been very low (approximately 0.6 percent for MLG backed financing, compared to a national average of 0.5 percent, according to research by DBRS). [Note 84]

Cost-Effectiveness

The evidence obtained from an analysis of the progression of MLGs between 1996 and 2008 and key informant interviews shows that MLGs have facilitated the construction of approximately 26,000 new housing units between 1996/97 and 2007/08. This outcome has come at a cost of less than $2 million per year in defaults, plus administrative costs.

Results

MLGs appear to be meeting their stated objectives of providing the necessary loan security to obtain financing and providing access to private funding for housing. According to interview respondents, MLGs allow for better housing results as opposed to capital grants, because the amount of grants is unlikely to equal or surpass that of the MLG authority. The usage of MLGs appears to be heavily weighted on housing quantity outcomes with the vast majority of MLGs being used to support CMHC's Section 95 housing. There is some interview evidence to suggest that building more housing units using MLGs has contributed negatively through the creation of cash flow problems as a result of higher debt loads in some First Nations communities, and positively through increased economic development activity in other communities. There is little evidence to suggest that MLG defaults are a significant contributor to a community being placed in third party management or co-management. The historical default rate for MLGs over a 42-year history is less than one percent.

9. Future Research Considerations

A number of potential areas for further research and analysis have emerged based on the findings from this evaluation. This research could help to better inform decisions related to on-reserve housing and to fully implement the recommendations in section 10.

The key areas for future research seem to centre on understanding the costs of building and maintaining homes on-reserve and understand the financial implications in order to significantly improve housing conditions, and ultimately meet current and projected housing needs.

Potential areas for further research and analysis include:

1. Identifying ways to improve the quality and availability of housing related performance information, including, financial information, and the costs of building and maintaining homes on-reserve. Without improvements in reporting, neither government nor First Nations will know what kinds of interventions work best and are cost-effective. Of key importance is the need for further research on developing a reliable way to assess the conditions of housing units in a robust and empirical manner. The annual reports used in this study provide some good information when coupled with census and other empirical data; however a much more complete assessment could be drawn if future research included conducting condition assessments on a valid sample of First Nation houses nationally. Additionally, this research should include an assessment of the impact of housing design on asset life, taking into consideration environmental variables across reserves. Without improvements in this area, on-reserve housing will continue to require major repairs much sooner than housing for Aboriginal people off reserve. Finally, it would be important to understand these variables in the context of growing need relative to the existing resources.
2. Conducting a comprehensive assessment of capacity building needs, in order to identify gaps as well as best practices. Without a strategic approach to capacity building it is unlikely that FNs will develop the expertise needed to manage on-reserve housing.
   
   The assessment should also include gaining a thorough understanding of the types of capacity and conditions that are in place in communities whose housing situations are strong. This could provide some additional insight into future policy discussions.
3. Developing a better understanding of how to manage accountabilities, including the concepts of shared responsibility, local operational control, and ownership. Until a consensus is achieved, it may be difficult for issues related to the governance of on-reserve housing to be addressed. Partners and stakeholders need to better understand these concepts moving forward in order to fully understand their implications in future program and policy development.

10. Conclusions and Recommendations

10.1 Conclusions

Relevance

This evaluation has confirmed that there is a continued need for federal support to on-reserve housing. The commitment to fund on-reserve housing aligns well to broad government commitments and to the priorities of INAC. At issue still is a continuing lack of clarity and understanding amongst stakeholders as to the respective roles and responsibilities of INAC and CMHC and whether they could be more effectively harmonized. The concept of "shared responsibility" is also not well-understood amongst government and First Nations. Clarifying the definition of shared responsibilities could improve results.

Performance

Housing Stock

New unit production

While there have been some improvements to rates of new units built, lots serviced, and units repaired, the existing housing stock on-reserve is deteriorating far more quickly than housing off reserve and rates of overcrowding, while having been reduced from nine times greater than that of other Canadians off-reserve, was still six times greater as of 2006. On-reserve housing needs remain very high and quality of housing on-reserve is far from comparable to those of non-Aboriginal Canadians. Hard choices have to be made on reserves, such as using the available funds to construct houses to meet immediate needs or to renovate existing stock so that the families are safer and the housing units last longer.

Repair and renovation

INAC did generate considerably more housing units from its share of Budget 2005 $295 million investments in housing. Notwithstanding that, INAC exceeded its targets for repair and renovation of housing units by about 270 percent, new housing stock on reserve has needed major repair much sooner than housing for Aboriginal people off reserve, likely because of a failure to account for environmental realities on reserve in the design of the houses, poor construction and poor maintenance. The poor maintenance may be a function of two interconnected realities: there is little personal income available among First Nations to invest in repairs and renovations and often, there is also a lack of a sense of ownership and, in turn, pride in one's housing. Overall, there were small gains with respect to the housing shortfall. It may take a focused effort even greater than the support in the 2005 Budget to have on-reserve housing catch up to need.

Governance

A common understanding about the meaning of "shared responsibility" should form the basis of the structure and execution of governance of on-reserve housing. Until that understanding is negotiated, INAC and First Nations are left trying to achieve the objectives of the housing policy through murky waters.

Some First Nations now have some variation of local control over housing management: that is, they to make their own decisions about where to spend housing funds and to report to INAC, only in the most global terms, on the results of those decisions. In terms of governance, First Nations seem to be developing the models to help them manage their housing responsibilities that suit them best. Some variation on a housing authority is a frequently used model.

Accountability is a key underpinning of any decision by the government to devolved responsibility for the management of First Nations affairs to First Nations. A recent audit of the housing program found significant opportunities for both INAC and First Nations to improve their accountability and particularly concerning was how limited the data are that verify the results of housing expenditures. Without some greater precision to the reporting, neither government nor First Nations will know what kinds of interventions work best and are cost-effective.

Capacity building

According to much of the evidence gathered for this evaluation, much remains to be done by all partners to build the range of capacities First Nations need to manage their housing regimes effectively. INAC has contributed a significant amount of support over 13 years to the capacity-building requirements but it has done so without a clear vision, and strategy as to where it should all lead.

Design and Delivery

The design of the 1996 On-Reserve Housing Policy did not adequately incorporate a First Nations perspective. The meaning of its key tenet of the policy – shared responsibility – remains inconsistently understood by all stakeholders. For thirteen years, INAC has supported some forms of capacity building with weak results. In the future, they may wish to work more closely together, and with First Nations, to develop a more strategic approach. A lack of capacity is a key impediment to First Nations achieving the desired results.

All key informants contributed ideas about how to remove irritants from the operational delivery practices. In general, the irritants spoken of could be resolved by a change to administrative practices or guidelines with greater coordination and harmonization between INAC and CMHC, good will and greater flexibility at the regional level.

Cost-Effectiveness and Efficiency

With very limited performance data, it is next to impossible to determine the cost-effectiveness of the housing program using conventional measures. The recent audit of the On-Reserve Housing Program leaves no doubt that much of the data associated with cost, have not been verified. As First Nations take increasing control of managing their housing, they, too, will have a greater interest in being able to measure cost-effectiveness. How to achieve a true analysis of cost-effectiveness is an issue which warrants considerable attention well in advance of when another evaluation of the program is undertaken.

Other

Ministerial Loan Guarantees

There is a strong interest amongst First Nations in exploring home ownership. MLGs have been well-used by a very large percentage of First Nations as one instrument that has enabled the construction of approximately 26,000 houses between 1996 and 2007. While the default rate is very low, the continued rise in the contingent liability has the potential to create cash flow problems and future borrowing limitations. The usage of MLGs appears to be heavily weighted on housing quantity outcomes with the vast majority of MLGs being used to support CMHC's Section 95 housing.

Shelter Allowances

Shelter Allowance funds are an important funding source for First Nation communities to pay for costs related to Section 95 housing, which comprise a significant portion of recent housing developments. Shelter Allowance funds are used to grow the overall housing stock but are not used towards repairs or maintenance. Stakeholder interviews, case study findings and historical trends indicate that Shelter Allowance is not enough to cover the rent and/or mortgage payments, as well as fuel and utility costs and repairs and maintenance. Shelter Allowance has not been able to leverage any additional funding for housing on-reserve other than the Section 95 subsidy.

10.2 Recommendations

It is recommended that INAC, working with First Nations and seeking the active involvement of CMHC and other key stakeholders:

1. Develop a policy statement building on the 1996 Policy and other On-Reserve Housing Initiatives. The policy statement should lay out clear objectives and be flexible enough in its application to ensure it meets the different types of needs in First Nation communities.
2. Support and work with First Nations to clarify and strengthen accountability and governance structures, including roles and responsibilities, performance measurement, financial management, and community housing plans.
3. Develop a strategic approach to advance capacity building initiatives in order to:
   
   
   • better manage and monitor housing stock (where possible, INAC should work with other government departments to leverage resources for First Nation capacity development);
   • advance local operational control; and
   • achieve the minimum standards of the National Building Code (e.g., quality construction, repairs and maintenance) to ensure long-lasting and environmentally sustainable units.
4. Support and work with First Nations to ensure houses are built to address overcrowding and deterioration and to maximise the use of resources bearing in mind current and future pressures on housing stock.
5. Undertake research, in partnership with First Nations and CMHC, to identify:
   
   
   • cost-effective design options for on-reserve housing construction and renovation;
   • the impact of demographic trends on the needs for on-reserve housing;
   • options for effective management of on-reserve housing portfolios; and
   • options for effective governance of on-reserve housing.

Appendix A - Terms of Reference

Terms of Reference for the Evaluation of the Government of Canada Polixy for On-Reserve Housing

Disclaimer: The original terms of reference refer to CMHC as a joint partner in the evaluation. However, as aforementioned, CMHC did not participate in the evaluation, and thus these terms of reference are outdated, but are included for protocol purposes.

Introduction

These are the terms of reference for a joint INAC-CMHC summative evaluation of the on-reserve housing programs, policies and activities. This evaluation is planned to provide evidence-based conclusions regarding the relevance, success, and cost-effectiveness of INAC and CMHC's overall approach to First Nations housing and to inform its renewal.

Evaluation requirement

The Government of Canada is taking a long-term approach to achieving a fundamental transformation of the housing mechanisms on-reserve. This is in recognition of the fact that the housing situation on many reserves is inadequate and that it can contribute to poor economic and social outcomes and contributes to the gap in quality of life experienced by First Nations peoples. The Government also recognizes that simply putting more money into existing programs and services is not the solution to address the housing challenges on-reserve. Clearly, structural reform and innovation are required in order to transform the housing system on-reserve. By dealing with root causes and structural issues, and by implementing strong accountability and governance structures, concrete improvements in outcomes can be achieved.

The goal of this evaluation is to have a comprehensive review of all the programs, policies and processes that impact and affect housing on-reserve. This, in turn, will inform the development of new, innovative and community-based approaches to on-reserve housing that will bring about significant improvements in housing outcomes, such as greater quality of housing, longer term durability of the housing stock, and improvements in the overall adequacy of housing on-reserve. The evaluation will also provide a clearer understanding of roles, responsibilities and actions of each party involved.

In 2005, Indian and Northern Affairs Canada and the Canada Mortgage and Housing Corporation received authority to spend $295 million to address urgent housing issues on-reserve. All of the funding was to be spent in the first three years. In their joint submission to Treasury Board, the two federal institutions committed to an evaluation on the impact of this funding and to report on whether their targets and objectives were being met in 2008-2009.

In 2005, CMHC developed a draft evaluation plan that included the option of an interdepartmental evaluation of all housing programs of CMHC and INAC against departmental responsibilities, program objectives, and 1996 Policy objectives. This plan was to allow for the collection and analysis of data as a contribution to the review of the policy by the government in 2006.

However, certain factors affected CMHC's plan to evaluate its on-reserve activities. The Office of the Auditor General and Audit and Evaluation Services of CMHC (CMHC AES) released audits of on-reserve housing programs in 2003. Both audits pointed to areas of inadequate management controls, suggesting that program outcomes are not as intended. Further, CMHC has not evaluated the non-profit rental part of its on-reserve housing programs since 1987. CMHC revised the non-profit rental program in 1996; therefore, in addition to the simple elapse of time, program changes are an additional rationale for an evaluation.

Since 1996, INAC has conducted three partial evaluations focusing on the implementation of the 1996 On-Reserve Housing Policy. The last evaluation, conducted in 2008, concluded that there was no solid demonstration that the new features introduced in 1996 have had any observable impact, and that a more comprehensive evaluation of the relevance, impact and cost-effectiveness of the overall approach of the Government of Canada was required.

The Government of Canada is pursuing new directions in housing and this evaluation provides an opportunity to review and improve the existing system. There needs to be recognition of the fact that there is a continuum of First Nations capacity with respect to housing and that INAC's primary role is to improve housing support to those in greatest need through band owned housing.

This evaluation will inform the renewal of INAC's Capital Facilities and Maintenance (CFM) authorities in 2010.

Evaluation scope

This evaluation will cover the following:

Accountability requirements as stated in Treasury Board Submission for additional funding in 2005.

All current INAC housing programs activity and policy since 1996 including:

• Housing program (includes new housing, renovations and lot servicing) through minor capital allocation
• Support for tribal councils to provide technical support in housing and capacity building
• Shelter Allowance*
• Ministerial Loan Guarantees (MLGs)
• All questions in the recommendations and action plan of the Evaluation of the 1996 On-Reserve Housing Policy (February 2008)

A comparison between the Housing Subsidy Program, the 1996 On-reserve Housing Policy and the approach undertaken to implement Budget 2005 funds.

CMHC on-reserve housing programs, which include:

• On-reserve Non-profit Housing Program ( Section 95)
• Residential Rehabilitation Assistance Program (RRAP)
• Residential Rehabilitation Assistance Program for Persons with Disabilities (RRAP-D)
• Aboriginal Capacity Building

Excluded from this evaluation is the First Nations Market Housing Fund announced in Budget 2007. This program is currently not up and running and therefore no data is available. Information on the development, criteria and intent of this program will be incorporated into the evaluation report and will inform recommendations and future directions.

* Shelter Allowance is a component of income assistance that falls under basic needs. It will be evaluated with the rest of the Income Assistance components and the results will be incorporated into the overall housing evaluation report to meet accountability and reporting requirements. Should the scope of that evaluation not include links to housing, it will be incorporated into this evaluation.

The objective will be to inform the renewal of the whole approach towards on-reserve housing.

Program profiles

In 1996, the Government of Canada redefined its policy to help First Nations with housing issues on-reserve. The 1996 Policy objectives are the following:

• Protection and extension of dwelling life;
• Construction of affordable new housing;
• Promotion of individual pride and responsibility; and
• Linkage of housing activity to training, job creation, and socio-economic development.

These policy objectives are shared between INAC and CMHC who both are responsible for delivering programs to assist First Nations in addressing their on-reserve housing needs. These policy objectives will form the basis of the evaluation.

INAC On-Reserve Housing Investment

INAC supports First Nations on-reserve housing through its housing program, the Ministerial Loan Guarantee and the shelter allowance policy.

INAC Housing Assistance and Policy

In the 1960s, INAC introduced a housing program to assist in the construction and renovation of housing on-reserves. The program provided subsidies for new residential construction and the renovation and rehabilitation of existing houses.

In 1996, the On-Reserve Housing Policy was introduced in order to provide greater flexibility and more control to First Nations over their housing policies or programs. The policy is based on four elements:

• First Nations control (community-based housing programs);
• First Nations expertise (capacity development);
• shared responsibility (shelter charges and ownership options); and
• better access to private capital (debt financing).

First Nations were given the choice of opting into the 1996 policy or not. If they opt in, they are given the flexibility to use INAC's housing funds in support of the implementation of their community-based housing plans, which may include elements such as maintenance and insurance, debt charges, training, management and supports to establish housing authorities. In the first five years after the introduction of the Policy, an estimated $160 million in additional funds was also provided to those First Nations that opted into the policy.

To be eligible for the more flexible 1996 funding arrangement, First Nations were required to establish a set of housing policies, housing programs and a multiyear housing plan. The housing plan was required to have three components: a work plan covering maintenance, insurance, renovation, building, and management; a resource plan; and links between housing activities and training, job creation and business development initiatives. A practical guide was published to assist First Nations in developing these policies, programs and plans (Guidelines, 1996) According to the guidelines, multiyear housing plans will allow First Nations to meet the objective of the Policy. The initial incentive for developing the plans was the additional capital funding. The incentive over the longer-term was the more flexible funding arrangement.

If First Nations choose not to opt into the policy, they continue to operate under the provisions of the housing subsidy program; their housing capital funding can only be used for construction, rehabilitation or renovation and the funds are released on a project by project basis rather than as a lump sum. Other funding may also be available to these communities for advisory services and program support related to housing management, housing planning, technical assistance, training, housing inspections, maintenance management and fire safety. The additional funding provided when the 1996 Policy was introduced is no longer available to these First Nations should they decide to opt in.

INAC funding for the plans and their implementation is provided through its capital program. First Nations implement and manage housing activities in their communities, in part by administering these government funds, and by identifying and obtaining additional funding from other sources, such as financial institutions, to support these needs.

Additional funding made available in 2005, was administered under its' own management control framework and was proposal driven. Reporting on these funds was separate from reporting on other housing revenue received through the Housing Subsidy Program or the 1996 On-Reserve Housing Policy.

Ministerial Loan Guarantee (MLG)

On-reserve housing loan guarantees have been in existence since 1966. A ministerial loan guarantee is necessary for most First Nations to obtain loan financing for housing, given the nature of land tenure and federal legislation. On November 4, 1999, the Governor in Council approved the revised terms and conditions. DIAND has developed detailed procedures for managing the loan guarantee authority within these revised terms and conditions.

The guarantee process begins with an expression of interest by a buyer (and a lender) to his or her band council. The council makes an application to the Minister. The Minister will not guarantee a housing loan for an amortization period of more than twenty-five (25) years. The Minister will not provide loan guarantees on designated lands eligible for lease-hold mortgages except in cases where Band members can provide written verification that they have been denied a mortgage and/or loan insurance based on Section 89(1) of the Indian Act. To ensure that the risk of a loan default is minimized and to prevent undue pressures on Indian Bands as well as fiscal pressures on the federal government, each request for a housing loan guarantee will be assessed and approved against criteria such as the viability of the project and the Band capacity to manage the project. In cases where the loan guarantee is being provided on a housing project which involves CMHC as lender, insurer or provider of housing subsidies (i.e. Section 95 On- reserve Housing Program), CMHC has to confirm the eligibility of the loan/project.

The delegation of authority to guarantee loans for housing applicants, on lands as defined, has been transferred by the Minister to designated regional representatives. All regions are responsible for establishing and maintaining mechanisms for managing and administering their housing loan guarantee portfolio. In the event of a default on a mortgage loan, the Minister attempts to recover the guarantee funds from future payments to the Band and the Band acquires the house. If the value of the house is less than the loan balance outstanding, the community would pay for at least some portion of the insurance claim. Mortgage insurance premiums are not charged and the liability for claims losses is shared between the Minister of INAC and Band councils. Mortgage insurance is thus more of a facilitating instrument for housing purchases than a program that can actively stimulate or retard housing expenditures.

The MLG process will be looked at in the context of whether or not it impacts on housing outcomes.

Shelter Allowances

Shelter allowances are paid by INAC to income assistance recipients based on financial benefit rates and eligibility criteria set by the provinces. Maximum shelter rates are based on family unit size and include rent, utilities and other allowable shelter costs. Provincial/Territorial legislation generally requires individuals on income assistance to have rental agreements to be eligible for the shelter allowance component. This includes evidence of actual costs in the form of receipts, billings, or rental agreements; the community must customarily collect rent for the house; and the amount of rent must be reasonable in terms of household needs, size, the condition of housing, and prevailing community rental practice. These criteria effectively mean that the First Nation must establish a rental regime in order to qualify for shelter allowances.

The Auditor General (2003) noted that there is inconsistent application of shelter allowance across regions and provinces and that some regions could not pay shelter allowances to all individuals who were potentially eligible for assistance because of insufficient funds. Shelter Allowance was evaluated as part of income assistance in 2007. The evaluation found that full payment of the Income Assistance shelter component occurs in British Columbia, Ontario, Quebec and the Yukon. The Prairie and Atlantic regions pay shelter allowance only in communities which have implemented rental regimes and to individuals who pay rent.

Income Assistance will be re-evaluated in 2008-09; the results of the shelter allowance component will be incorporated into the housing evaluation.

CMHC on-reserve program profiles

CMHC provides funding in support of the construction, acquisition, rehabilitation and renovation of social housing on-reserve through the On-Reserve Non-profit Rental Housing Program (Section 95). CMHC also provides funding to repair existing homes through the Residential Rehabilitation Assistance Program (RRAP), minor home modification for seniors through the Home Adaptations for Seniors' Independence Program, and renovation or construction/acquisition for shelters for victims of family violence under the Shelter Enhancement Program. First Nation capacity building and other housing related activities are also supported by CMHC. Since 1997, the Section 95 program provides full subsidies to cover the difference between eligible project costs and project revenues. Direct lending is offered to all existing Section 95 projects to help reduce loan costs.

CMHC programs included in this evaluation are the Rental Housing Program, RRAP, non-profit rental and residential rehabilitation programs, Aboriginal Capacity Development, and the National Housing Act (NHA) loan insurance.

On-reserve Non-profit Rental Housing Program

The 1997 Rental Housing Program (known as Section 95) helps First Nations provide quality low-rent housing to low-income households living on-reserves. Housing projects are expected to have improved financial viability, as compared with the 1997 program, and to promote individual pride and responsibility in housing.

INAC advises CMHC about the regional allocation of the annual program budget. Procedures for allocating regional budgets to individual First Nations vary across regions and may involve entitlements, competitive proposal calls, allocation by need, or any combination of such criteria. After subsidy of a project has been committed, First Nations (either bands or tribal councils) are responsible for the development of planning, financing, construction, rental, and project administration. Proposals may be developed using loans from the proposed Development Fund, which are repaid from construction loan advances. Financing is usually provided by CMHC direct lending but Bands may borrow from approved lenders if they offer competitive interest rates. Mortgage loans are usually insured by CMHC and guaranteed by the Minister of INAC.

The cost of the residential portion of projects that is eligible for subsidy must be within the Maximum Unit Price (MUP) established by CMHC by region and geographical area. Construction is expected to meet the standards of the National Building Code of Canada. The MUP contains an allowance for construction of accessibility features to aid disabled occupants. Section 95 has been used primarily to subsidize new construction although it permits renovations. The First Nation and CMHC enter into a Project Operating agreement that governs many aspects of project management including client selection and counselling, subsidy payment, reserve fund, financial reporting, and portfolio monitoring. The agreement does not give details for client selection criteria, but the change in the subsidy mechanism was introduced to allow more effective low-income targeting and increased project viability.

Project subsidies are paid during the period of loan amortization, which may be from 15 to 25 years. The subsidy amount is the loan repayment plus approved operating costs less the minimum revenue contribution. Operating costs and the minimum revenue contribution are constant for the period of the operating agreement. Revenues may come from rents paid by occupants or any other Band resources. Surplus revenues may be retained in operating reserve funds to defray later costs such as maintenance, inflation of general operating costs, or tenant counselling for any part of the post-1996 Section 95 portfolio. Revenue contributions are set as part of community shelter charge regimes. Commitments are made in terms of subsidy costs over the lifetime of the loan amortization and this limits CMHC expenditure, meaning that the number of units produced is variable depending on the contributions by First Nations of equity to reduce capital costs, and on project rental revenues.

On-reserve Residential Rehabilitation Assistance Program (RRAP, RRAP-D)

The on-reserve RRAP objective is to assist in the repair or improvement of existing substandard housing to a minimum level of health and safety. A separate program, RRAP for Persons with Disabilities, funds the modification of dwellings to improve accessibility of the dwelling for persons with disabilities. RRAP and RRAP-D benefits may be stacked providing the applicant meets all eligibility criteria.

Both programs provide forgivable loans to eligible applicants for eligible repairs or addition. The maximum loan amounts are $16,000 in southern areas, $19,000 in northern areas, and $24,000 in far northern or Arctic areas. Loan forgiveness is earned by occupancy of the dwelling for up to five years and by adherence to the terms of the loan commitment.

Applicants may be Bands that rent band-owned housing to member households or may be households that hold Certificates of Possession or similar authority for permanent occupancy of a housing unit. The income of the household occupying the unit must be below the established Forgiveness Income Limit (FIL) for the geographic area.

Properties eligible for the rehabilitation program must be substandard or deficient and require major repair of a key system or must pose a health or safety hazard to occupants. Overcrowded properties are eligible for loans for additions. If a property qualifies because it is substandard, all major deficiencies must be repaired. Repairs are expected to permit an extension of useful dwelling life of at least 15 years. Costs of labour, materials, permits, drawings, and taxes are also eligible. Certain restrictions exist relating to property age and repeated RRAP loan approvals. Units receiving continuing subsidies under NHA housing programs, such as Section 95, are ineligible. To be eligible for the disability program, a property must need physical modifications to improve the accessibility of the dwelling for a disabled person. Modifications to remove mobility limitations are most common, but modifications related to visual, hearing, or other disabilities are eligible.

CMHC works in partnership with INAC to make regional allocations of the program budget. Tripartite committees consisting of First Nations, CMHC and INAC recommend budget allocations within regions. And councils determine program priorities within reserves. The program may be delivered by CMHC, agents of tribal councils or individual bands. The key delivery activities are program publicity, application review, recommendations for approval and inspections.

Aboriginal Capacity Development

The objective of CMHC Aboriginal Capacity Development activity is "to facilitate ... development of appropriate infrastructure and housing governance capability for Aboriginal peoples to run their own systems and ensure sustainability of the final product". Key initiatives are:

• Promoting the technical competence of housing industry professionals;
• Promoting the technical competence of First Nation managers and occupants;
• Developing and disseminating solutions to housing-related health problems;
• Delivering housing internships providing training opportunities for young people in housing occupations; and
• Research.

Support to industry professionals

Assisted Housing Division has committed a significant part of capacity building resource to the development of the Native Inspection Service. This has involved two tasks; the first was to develop a body of trained personnel capable of inspecting property and providing condition related information to owners and occupants. The second task was to develop policies and procedures for contracting technical service work required as part of social housing program administration to Native Inspectors. CMHC has contracted over $1million of RRAP and Section 95 on-reserve inspections through the service. A professional association of First Nations and Aboriginal inspectors has been formed.

With respect to the housing industry in general on-reserves, capacity activities include builders' workshops, demonstration projects on innovative construction techniques, and dissemination of research results. CMHC also collaborates in the delivery of courses on building trades, the use of local building materials, and the National Building Code, among other topics. In some regions there are courses aimed at training women for construction trades. The First Nations National Building Officials Association participates in many of these initiatives.

Support to First Nation housing administrators and occupants

First Nations endeavour to plan and administer their housing portfolios effectively. This entails preparation of community housing plans, policy development, project development, operations and reporting. Capacity development activities include training courses (e.g. Section 95 orientation, mortgage insurance), policy development, operations (e.g. client counselling, rental arrears management, wood fuel use), succession planning, communications and other topics. Courses for households include maintenance and home ownership. Other initiatives include liaison activity, newsletters, and provision of advice regarding management of revolving funds.

Healthy housing:
This activity is largely aimed at disseminating existing research findings on healthy housing and indoor air quality. Workshops are held in most regions on improvement of indoor air quality or mould remediation techniques. Previous projects included the development of the training materials that are currently being used.

Housing Internship Initiatives:
The Housing Internship Initiative has delivered part of the Youth Employment Program budget of HRSDC since 1997 to provide employment experience to unemployed youth resident on-reserves. Internships are intended to provide work experience in housing occupations and hence to help increase the supply of experienced workers. All occupations related to housing are eligible, including administration planning, policy development and construction but most First Nations use internships to subsidize construction jobs.

Information transfer:
CMHC conducts research and produces information and publications on many housing-related topics such as healthy housing, construction methods, infrastructure for remote housing, administrative practices etc. Some of these have been edited or produced explicitly for application to housing problems on-reserve territories. Promotion and presentation of such material is expected to contribute to improved knowledge of housing technology and administration, and as such is a capacity building activity.

National Housing Act (NHA) insurance and lending

In Canada, home ownership is most frequently achieved through private purchase of housing using mortgage financing. NHA mortgage insurance permits buyers to purchase housing by making down payments of as little as five % and borrowing up to 95% of the purchase price using an insured mortgage. The 1996 Policy directed CMHC and INAC to improve access to private funds by household residents on-reserves.

Insurance of loans under the National Housing Act is at present the most important means of reducing the barriers to access to private financing on-reserves and has been available since 1966. The Ministerial Loan Guarantee (MLG) indemnifies CMHC against default claims paid to lenders. Consequently, borrowers are not charged premiums, but pay application fees. Insurance based on the MLG continues to be available but CMHC has developed a new On-reserve Loan Insurance product that provides insurance without using the guarantee.

CMHC also supports home ownership on-reserve through the Homeownership Loan Insurance Pilot without Ministerial Loan Guarantee (MLG). This allows for the purchase, construction or renovation of a home on-reserve for qualifying First Nation communities. It will allow eligible First Nations to facilitate insured mortgage financing for qualifying band members without a MLG.

First Nations Market Housing Fund

In Budget 2007, the Government set aside $300 million for a First Nations Market Housing Fund. The Fund will serve as financial security for eligible First Nation members to obtain home ownership, rental and renovations loans, while leaving reserve land in communal ownership. First Nation communities will apply to the Fund and, if they meet the Fund access criteria, households living in these communities will be able to apply for loans from financial institutions.

The Fund will initially be administered by CMHC and directed by a board of nine Trustees drawn from a publicly advertised call for interest. Three Trustees will be drawn from First Nations communities and will be appointed by the Minister of INAC in consultation with the Minister of HRSD (the Minister responsible for CMHC), and the AFN. Of the remaining six Trustees, three will be drawn from the private sector finance community and three will be drawn from the federal government community, and appointed by the Minister of HRSD in consultation with the Minister of INAC.

First Nations will have to qualify in order to access the Fund's credit enhancement amount. The access criteria are currently being developed. According to CMHC, it has been suggested that the criteria may include:

• Community support for home ownership;
• Sufficient demand for home ownership;
• Strong First Nation housing management;
• First Nation financial capacity;
• Strong First Nation financial and loan management; and
• First Nation capacity to ensure that quality housing is constructed in the community.

For those First Nations that apply to the fund and are not able to meet all access criteria, supports will be considered to strengthen the way they manage housing so that they can qualify in the future. Access to capacity building, the level of funding for capacity building, and approaches to building capacity are still under development. The Fund is expected to be operational in 2008.

Funding

The profile of INAC's funding for housing from 1996/97 to 2007/08 is provided in the following chart. The chart reflects the increase in funding after the On-Reserve Housing Policy was introduced and the more substantial increase following Budget 2005.

Figure Appendix A 1: INAC Housing expenditures

Source: Figures provided by INAC's Housing Operations.

The figure illustrates INAC housing expenditures. The expenditures are located on the y-axis and the fiscal years are located on the x-axis. There is one line on the graph that has relatively little variation with the exception of a huge spike in expenditures beginning in 2005/2006 and peaking between 2006/2007 and dropping again in 2007/2008.

Between the periods 1996/1997 and 1997/1998, expenditures rose slightly from approximately $160 000 000 to $165 000 000. Between 1998/1999 and 1999/2000, expenditures rose to $200 000 000 and then decreased to about $170 000 000. From 2000/2001 to 2001/2002, expenditures fell to approximately $150 000 000. Between 2002/2003 and 2003/2004, they rose to approximately $160 000 000 and then fell to approximately $149 000 000. Between 2003/2004 and 2004/2005, expenditures stayed steady at approximately $149 000 000. From 2005/2006 and 2006/2007 they began to rise sharply to about $300 000 000. From 2006/2007 and 2007/2008, expenditures reached a peak of approximately $390 000 000, and dropped sharply to approximately $190 000 000.

CMHC provides $123 million per year (indexed annually) through its programs, capacity development and ongoing subsidies for the existing portfolio of assisted housing.

Evaluation issues

Evaluations of federal government programs and policy include consideration of program/policy relevance, success, and cost-effectiveness. Relevant programs are those that can be shown to fulfill a need for public action and are consistent with government policy relating to the subject area. Successful programs are those that have positive impacts on the intended clients and achieve their objectives. Cost-effective programs are those that that can be shown to produce their results as inexpensively as or less expensively than any alternative mechanisms.

Relevance

Evaluation of the relevance of INAC and CMHC housing programs will examine the consistency of the different approaches to housing (sometimes within programs) with the federal government housing policy on-reserve and the extent to which programs realistically address the existing needs.

Need for housing programs

Closing the gap

The rationale for Housing supply assistance programs, such as CMHC Section 95, RRAP, and the Housing Program of INAC within its Capital program, has long been based on inadequate housing and social conditions on-reserve as compared to Canadian society as a whole. New construction and rehabilitation programs are thought to be complementary since in principle they address housing needs generated both by population growth and unit deterioration. Whatever level of housing, there remains another issue as to whether the current level of production is high enough to overcome needs in the foreseeable future. This will require consideration of population and household growth forecasts, current housing production rates, and dwelling performance and deterioration rates.

Capacity development

The rationale for capacity development is based on shortages of trained staff in the areas of policy development, planning, construction, or administration or on observed weakness in administrative practice. Another element of capacity building has been added in 2005, which is the maintenance of the houses by staff and occupants, so that they serve the occupants well for a minimum of 25 years. Given the small size and remote locations of many First Nations, there is likely a shortage of personnel in many places. A CMHC evaluation of urban non-profit housing in 1998 showed that native non-profit housing sponsors were less likely than other non-profit sponsors to have certified property management staff and to employ staff with extensive experience.

INAC capacity building activities is an inherent aspect of all its programs. As such, it is difficult to separate it out as a discrete activity or program. Capacity building is managed at the regional level with considerable variation between regions.

Access to financing

Financing constraints exist for housing construction or renovation on-reserves because loans from financial institutions cannot be secured through mortgages or liens in favour of non-Indian lenders. This implies that purchases or renovations are probably made with more cash and less debt than the same transaction off reserve. The 2002 census shows that 34 % of housing on-reserve territories is privately owned which is just about what would be expected given the income distribution of First Nation households. This could indicate that the lack of loan security does not result in lower ownership rates. However, it is likely that houses are smaller in First Nations communities than in other communities, and, on average, they are certainly in inferior condition. This evaluation should clarify the extent and impacts of financing constraints faced by borrowers on-reserves.

Alignment with priorities

The evaluators will review government policy documents, budgets, speech from the Throne and other documents to establish the extent to which INAC and CMHC activities provide assistance to First Nations to improve housing outcomes on-reserves.

Measurement of Success

Program activities and resources in combination with non-program resources (such as Band administration, Band budgets, volunteer labour or client equity) are expected to contribute to the achievement of the objectives of the 1996 policy, and, in the longer term, have positive impacts on client households and on the wider society. The methods of measuring such impacts are described below.

Housing stock impact

INAC and CMHC on-reserve housing programs and activities contribute to new unit production including servicing of new building lots, rehabilitation of substandard units, and to improved industry capacity and administrative capacity. Such program activity is expected to be reflected in increased numbers of units, improved housing conditions, improved space standards, improved construction and inspection standards, cost-effective build-renovate decisions, and more effective stock management.

The analysis of impacts will include an attribution of impacts to INAC and CMHC programs. The analysis is complicated by the funding sources available to First Nations. The 1996 On-Reserve Housing Policy and guidelines encourage First Nations to contribute equity from whatever sources may be available. In doing so, they may reduce the required subsidy and build extra units, reduce the amortization period, fund minimum revenue contribution, and/or undertake larger renovation projects. Whatever the option, such contributions mean that the stock impacts cannot be attributed completely to CMHC and/or INAC. The evaluation will examine the equity contributions of First Nations, INAC, CMHC, and other agencies where possible to address this issue.

Condition impacts will be measured by inspecting samples of program and non-program housing in First Nation communities and by comparing the building standards employed and housing conditions as observed. This will involve using some variant of program evaluation inspection instruments or the CMHC Physical Condition Review procedures.

INAC and CMHC program guidelines specify that housing units built under their programs must conform to the National Building Code or to a higher standard if applicable. Units must be adequate to the needs of intended occupants, be consistent with community norms with respect to size, facilities and energy efficiency, and be durable. The program guidelines allow for a contribution to replacement reserves as one of the eligible operating costs. Replacement reserve holding will be compared with repair costs to assess the ability of communities to deal with condition problems.

The 1996 policy required First Nations to develop community housing policies as well as multiyear housing plans. The evaluation will determine to what extent the practices with respect to conformity to code, compliance with inspections, etc. are being implemented in community housing policy and plans.

In 2005, when receiving additional funding to address urgent housing needs on-reserve, INAC committed to use the additional funding to facilitate the construction of an estimated 2,000 new housing units; the servicing of an estimated 5,400 new building lots over three years; and the renovation of an estimated 389 existing housing units over two years. CMHC committed to use the additional funding to facilitate the construction of an estimated 4,400 new non-profit housing units over three years; and the renovation of an estimated 1,111 existing housing units over two years. Both organizations committed to have the houses built or renovated to standards which ensure that they are able to endure and function well for a minimum of 25 years.

In the 1996 Housing Policy Evaluation, First Nation respondents indicated that CMHC houses were built at a higher standard than INAC houses. The evaluation will examine the standards of houses built under the two different funding mechanisms and determine why there is any difference, if any.

Targeting and social housing objectives

This issue examines the extent to which occupant households have low incomes and other socio-economic characteristics. Since 1986, CMHC social housing programs have been available only to low income households (as defined using the core need methodology). While current Section 95 and RRAP program eligibility is not restricted to households in core housing need, the 1996 changes to the non-profit subsidy mechanism were made to allow better targeting to low-income households.

Shelter allowance falls under basic need benefits of the Income Assistance Program and is a supplemental financial assistance for rent, utilities and other allowable shelter costs which vary according to need and family size. Eligible recipients must have a demonstrated need for income assistance with no other source of funding.

In 2005, INAC and CMHC committed that the houses built or renovated be occupied by needy households, i.e. those with housing affordability, adequacy or suitability problems.

The evaluation will employ core need income threshold (along with other income measures employed in socio-economic analysis) as indicators of low-income status, not as eligibility indicators. This issue also includes an examination of household sizes and types that benefit from the programs.

The evaluation will also include a review of social and community housing delivery models being used in Canada and in other countries to determine their strengths and weaknesses as possible alternatives to current program models.

Occupant impacts

CMHC Section 95 and RRAP programs as well as INACCFMP and loan insurance activity result in production of new or renovated housing units, which are presumed to offer several benefits to occupant households. The impacts of new or improved housing are changes of some kind that can be attributed to the programs.

In 2005, INAC and CMHC committed to report on what has been done to make sure that housing occupants have the skills and knowledge to look after the houses so that they serve the occupants well for a minimum of 25 years.

An assessment of INAC's administration of housing supports as well as First Nation housing management of INAC's funding will be undertaken to determine if housing is being targeted to those in greatest need.

Capacity Development

Improvements in knowledge and skill could be measured using community level and event level data. The community perspective concentrates on measuring the level of local participation in capacity building events and relating this to housing outcomes. The event perspective concentrates on measuring the effectiveness of particular training initiatives increasing knowledge and skill of participants. These can be treated as parallel lines of evidence about the effectiveness of capacity building activity.

The evaluation research will be focused on measuring the contribution of knowledge and skill separately from the contributions of other factors. Census data on employment, income, and housing conditions can be related to participation rates in training events and measures of band administrative practices while holding background social and economic conditions constants.

Private capital and home ownership

If CMHC, DIAND and First Nations efforts to strengthen the non-program housing sector are succeeding, there should be some increase in the proportion of housing not owned by bands on-reserve territories. These numbers are available from the census. A decline in the proportion of band owned housing on-reserves indicates that the stock of housing owned by other entities is rising (and vice versa).

While conventional loan insurance in combination with the Ministerial Loan Guarantee (MLG) is the main means of access to private capital, the program operates only to implement an agreement between bands and DIAND. The initiative to use it rests with bands. The Mortgage Insurance Fund is indemnified against loss by DIAND and insurance is issued at its administrative cost. The extent of the use of the existing mortgage insurance product will be considered during the evaluation planning phase.

Canada Mortgage and Housing Corporation's Direct Lending Program provides financing and renewals for eligible social housing projects and offers the lowest average financing rate available. All loans that are financed or renewed at the same time and for the same term receive an identical rate regardless of the size of the loan or the location of the project. CMHC commenced Direct Lending to finance new commitments and renewals for social housing projects in order to reduce subsidy expenditures and make the best possible use of financial resources.

Economic development

The policy objective requires linking housing activity with training, job creation and economic development. The evaluation team interprets this to mean that training and job creation are intermediate outcomes resulting from specific administrative practices. These are expected to lead to sustained economic development in the longer term. Measuring efforts to link housing activity with training and job creation is fairly straightforward. Band housing staff and councils can be surveyed to reveal the procedures they have put into place to link housing with training and with local job creation. To the extent that these procedures are followed in the Section 95 and RRAP programs or can be shown to emanate from capacity building activity, they can be attributed to CMHC initiatives.

The final step in relating socio-economic development to housing activity requires a specialized economic study. The Research Division of CMHC has undertaken a number of studies that contribute to the economic impact of housing and other investments in reserve communities and will be included in the evaluation.

Cost-effectiveness

Measuring cost-effectiveness of programs involves identifying program costs and comparing them with alternative means of producing a standardized unit of program benefits. The cost-effectiveness analysis will only deal with program activity and will exclude capacity building and the development of private financing mechanisms.

Comparison between INAC and CMHC

INAC funding under the CFMP to First Nations would be compared to Section 95 and RRAP programs to finance new housing construction and renovation. Currently both INAC and CMHC implement mechanisms that provide housing on-reserve to those in need. What is the difference between the two agencies, their programs, criteria and administration? Is it cost-effective to have two different agencies promoting the same outcomes for the same population? Should all housing on-reserve be under one agency, if so, which one should it be?

Comparison between First Nation Communities

Some First Nation communities are operating under the Housing Subsidy Program while others are operating under the more flexible 1996 policy. To determine cost-effectiveness and efficiency, comparisons between communities operating under both regimes will be undertaken. In addition, housing policies, programs and plans (management practices) may differ greatly across the country for those First Nations operating under the 1996 policy. To determine best practices, a comparison of First Nation communities operating under the 1996 policy will also be undertaken

International studies

To determine whether or not Canada is taking the most cost-effective and relevant approach to on-reserve housing, comparisons will be made with housing provided for Native Americans on reservations in the United States, Aborigines in Australia and, if information is available, housing for the Maori in New Zealand.

Involvement of First Nations

The 1996 housing policy allows First Nations to have increased flexibility on how the funds are to be used. One of the key pillars that the approach was founded on was First Nation control.

The 2005 Treasury Board Submission asks if CMHC and INAC delivered the units with First Nations rather than to them.

Program delivery is being delivered in conjunction with Regional Housing Liaison Committees (RHLCs) which plan, review and coordinate funding for on-reserve housing and infrastructure, share information with First Nations communities and monitor results against targets.

Internal Control Mechanisms

Have CMHC and INAC been good stewards of taxpayer funds?

Evaluation approach

Lines of inquiry

To address the issues identified and provide empirical measurement of the indicators, evaluators will use the following lines of evidence:

• Review of published documentation, including international work and census data, housing need assessments and forecast, aboriginal research, etc.
• Review of INAC and CMHC performance data: management systems and databases will provide information to assess the impact of the programs on housing stock, in terms of units built, renovated and lots serviced.
• Household surveys: the household surveys will target occupant of housing unit attributable to CMHC and INAC programs and occupants of non-program units, privately owned houses, etc. Surveys will supply data on family characteristics, including income, changes in housing conditions, attitude to responsibilities of occupancy, impacts on family life and impact on health and safety conditions. Sampling design options will be examined including national random sampling, national sampling allowing for some form of geographical breakdown or cluster sampling (a method used in the 1987 on-reserve housing evaluation that first selects a limited number of First Nations communities randomly and then selects households within communities).
• Physical condition survey: samples of program and non-program units will be inspected to supply data on current conditions, construction standards, repair costs and unit life expectancy. CMHC has a number of inspection instruments and manuals used in previous housing surveys that could form the basis of a new protocol. The condition survey should have the same sample size as the occupant survey. It is assumed that half of the inspections would be contracted out and half would be undertaken by CMHC.
• Band survey: this survey will target Band housing authorities and staff. Band housing authorities would be asked to describe their management practices, including planning process and implementation, and to assess the availability of staff and other resources. Band staff will provide information on participation in capacity building events, impacts of such events and the implementation of housing programs and policies. Surveys will be conducted through interviews of housing officers in sampled communities and through supplemental telephone interviews.
• Industry survey: the industry survey will target members of the Native Inspection Service, construction companies and trades. Respondents would be asked about their knowledge of topics targeted by capacity building events and of more general construction practices, and about their experience in attracting and employing qualified staff. Surveys will be conducted through interviews of industry members in sampled communities and through supplemental telephone interviews. Regional offices will be the geographic bases for surveys of participants in capacity building events. The evaluation team will work with branch staff to select key events that have recently been completed and samples of participants will be invited to take part in the survey.
• CMHC and INAC staff survey/interviews: CMHC and INAC staff and senior officials in Ottawa and regional offices will be surveyed or interviewed to collect their perspective on programs design, delivery, and portfolio managements.
• Expert and peer review of draft documents: key reports produced during the course of the evaluation, including questionnaire drafts, report drafts, may be presented to professional or academic subject matter experts. Also, the evaluation team would likely seek advice on the validity of instruments for measuring building code compliance and on the reliability of compliance data collected. Econometric expertise may also be required.

Project management

Roles and responsibilities

Terms of Reference will be submitted to INAC Departmental Audit and Evaluation Committee and a jointly developed Evaluation Plan will be submitted to CMHC Management Committee. The final report will be tabled at both committees.

The evaluation project will be conducted under the lead of CMHC, as the subject matter expert, with the cooperation of INAC as the agency with primary responsibility for housing on-reserves.

The evaluation project team will be composed of senior evaluation staff from CMHC and INAC. Decisions will be made on consensus. The evaluation team will be responsible for project management, including the evaluation planning, the contracting process, and revision of deliverables and draft reports. The evaluation team will consult, when necessary, with representatives or program areas within each organization. Each department will be responsible to collect the input from its program areas to ensure the validity of factual information.

A steering committee, composed of the heads of evaluation from each organization will oversee the evaluation project.

An advisory committee composed of representatives from the Assembly of First Nations (AFN), INAC and CMHC (at a minimum) will be involved at all stages of the evaluation process, including but not limited to the development of the evaluation plan.

Data collection work and analysis will be conducted mostly by external consultants. The evaluation team may consider various contracting strategies (e.g. single or multiple contractors for data collection).

Deliverables

The evaluation will be conducted in three phases:

1. Phase 1 will include the development of an evaluation plan in conjunction with CMHC, and other preparation and planning activities such as :
   
   
   • The recruitment of appropriate external consultants
   • An assessment of the available information and potential success of the various lines of inquiry
   • The elaboration of a detailed evaluation plan, including a list of indicators, metrics and specific data sources.
   • Phase 1 will be finished when the detailed evaluation plan has been approved by the steering committee.
2. Phase 2 will include data collection activities and analysis such as:
   
   
   • Review and analysis of policy and program strategic documentation
   • Review and analysis of available published documentation, including census, need analysis and projection, etc.
   • Household survey
   • Physical condition survey
   • Band and Industry surveys
   • CMHC and INAC staff surveys
   • Phase 2 will be completed when the steering committee is presented with the results of the data collection process and preliminary conclusions regarding the evaluation issues. The steering committee may require that the deliverables be revised by external experts. The steering committee is also responsible to decide if the results and preliminary conclusion are to be presented to external stakeholders.
3. Phase 3 will include analysis and reporting activities such as:
   
   
   • An assessment of the relevance, impact and cost-effectiveness of the housing policy and programs
   • A draft report
   • A final report
   • Phase three is completed when the steering committee accepts the final report. The steering committee may require that the draft report be revised by external experts. The steering committee is also responsible to decide if the draft report is to be presented to external stakeholders. The same final report will be tabled at each department's evaluation committee.

Budget and timelines

The original anticipated budget for this evaluation was estimated at $1.2 million and was to be cost-shared 50-50 between INAC and CMHC. The cost of the evaluation was to be absorbed within existing reference levels.

Table Appendix A 1:

* A draft report will be completed in June/July.

These Terms of Reference were approved at the April 25, 2008 meeting of the Audit and Evaluation Committee (now the Evaluation, Performance Measurement and Review Committee).

Appendix B - Evaluation Matrix

Appendix C

Conditions to Be Met to Access Budget 2005 Funds:

• mortgage financing for the balance of the capital cost and the borrower having met the loan criteria of the lender;
• meet ministerial loan guarantee requirements (if required);
• mandatory occupant charges;
• houses built to the NBC and inspected accordingly; and
• the community having established policies for the collection of rents or other contractual obligations and having in place a viable maintenance program to ensure long-term preservation of the housing units.

The funding was allocated to those First Nations who met the following program criteria:

In the case of home ownership:

• band council resolution supporting the application of the individual;
• property description (Certificate of Possession, GPS co-ordinates etc);
• documentation from the lending institution in regard to loan approval;
• confirmation that serviced lots (including those with wells and septic systems) are available or will be available with new lot funding; and
• all other information normally required to support approvals (including evidence of compliance with the NBC).

In the case of rental housing:

• copy of rental regime approved by chief and council;
• documentation from the lending institution in regard to loan approval;
• confirmation that serviced lots (including those with wells and septic systems) are available; and
• all other information normally required to support approvals (including evidence of compliance with the NBC).

Footnotes:

1. Canada Mortgage and Housing Corporation (CMHC) On-Reserve Non-Profit Housing Program (section 95) (return to source paragraph)
2. Note that CMHC programs are the same for First Nations communities, whether or not they have opted into the 1996 Policy, and there is no flexibility in the use of CMHC funding for those First Nations which opt in. (return to source paragraph)
3. There are limited data which describe what level of need existed for on-reserve housing in 1996. INAC's February 2008 Evaluation of the 1996 On-Reserve Housing Policy does, however, indicate that in 1996, 36 percent of First Nations lived in dwellings in need of major repair and only 52.07 percent of the existing on-reserve houses were considered adequate, that is not in need of major renovation or replacement and with the basic plumbing facilities, page 12 (return to source paragraph)
4. Guidelines for the Development of First Nations Housing Proposals (return to source paragraph)
5. $103 million was given to CMHC for new construction and renovation, Budget 2005. (return to source paragraph)
6. CMHC has been allocated $250 million to be spent over two years: $125 million for the creation of new on-reserve housing and $125 million for the repair and renovation of existing federally assisted on-reserve social housing, Indian and Northern Affairs Canada. Canada's Economic Action Plan Housing Funding Overview (return to source paragraph)
7. Budget 2009 announced $150,000 for INAC on-reserve housing to be spent over two years. (return to source paragraph)
8. The activities and impacts of the First Nations Market Housing Fund, announced in Budget 2007, were excluded from this evaluation as the fund was only operationalized in 2008 and as of yet, there is too little experience with the fund to discern its impact on on-reserve housing. (return to source paragraph)
9. CMHC, June 2002 Establishing Strong First Nations Technical Services organizations: Framework Modeling; April 2000, Shelter Enhancement Program, Evaluation Plan; 2006," Establishing On-reserve Housing Authorities" Shelter Enhancement Program 2007, Enhancement plan; March 2003, Research Reports on native housing - bibliography; January 2001, Special Studies on 1996 Census Data: Housing conditions of Native Household: July 2005, Abstract: A Review of Training and Delivery Options Concerning Aboriginal Housing; October 2005, Abstract: Architecture for Elder Health in remote British Columbia. (return to source paragraph)
10. Ten communities drawn from all regions of the country were originally to participate in the case studies. Ultimately, no First Nations community in Alberta agreed to participate in the case study component of the evaluation. (return to source paragraph)
11. Mr. Doxtdator holds a civil engineering Diploma from Mohawk College, Hamilton and various certifications through NRCan in R2000 and Energuide as well as certification through HRAI in Heat Loss, Heat Gain, Ventilation Design and Ventilation Installation. He is also a certified engineering technician affiliated with the Ontario Association of Certified Technicians and Technologists. He was instrumental in the formation of First Nations Building Officials' Association of Ontario and National First Nations Housing Managers Association. (return to source paragraph)
12. For a copy of the recipient reporting guide. (return to source paragraph)
13. INAC. 2008 Evaluation of the 1996 On-Reserve Housing Policy Report, February, 2008, Evaluation, Performance Measurement and Review Branch, Audit and Evaluation Sector, page 19.(return to source paragraph)
14. INAC Sustainable Development (return to source paragraph)
15. 2003 April Report of the Auditor General of Canada; paragraph 6.32 (return to source paragraph)
16. Note that as with all census data, these projections do not include all First Nation communities as many do not opt to participate in the census. (return to source paragraph)
17. Statistics Canada projections as provided by INAC's Strategic Research and Development Division. (return to source paragraph)
18. Some First Nations have more than one physical site on their reserves where communities have been built. (return to source paragraph)
19. This figure is taken from population data of reporting communities that had reported populations from 1996 to 2008 and thus only 844 of the 977 reporting communities are included in this figure. (return to source paragraph)
20. Extracted from INAC's Infrastructure and Assets Annual Report using the ICMS database. (return to source paragraph)
21. Extracted from INAC's Infrastructure and Assets Annual Report using the ICMS database (return to source paragraph)
22. Extracted from INAC's Infrastructure and Assets Annual Report using the ICMS database. (return to source paragraph)
23. Ibid. (return to source paragraph)
24. Ibid. (return to source paragraph)
25. Extracted from Statistics Canada Canadian Census Household Characteristics Summaries. (return to source paragraph)
26. While there appears to be a growing gap over time between the number of houses needing major repairs and the number of houses renovated, what is unclear is whether this is due to an absolute increase in the rate of deterioration of houses or to an increase in reporting requirements such as occurred when at the time Budget 2005 funds were offered, or to some combination of both. (return to source paragraph)
27. Extracted from a custom query of the ICMS database (return to source paragraph)
28. Extracted from Statistics Canada Census Household Characteristics Summaries (return to source paragraph)
29. Ibid. (return to source paragraph)
30. INAC, Evaluation of the 1996 On-reserve Housing policy Report, February 2008, Project 07/050, page 11 (return to source paragraph)
31. Ibid, page 12. (return to source paragraph)
32. Literature review, pg 41 (return to source paragraph)
33. Gathering Strength: Canada's Aboriginal Action Plan, Feb 16, 2000 (return to source paragraph)
34. Government Response to the Seventh Report of the Standing Committee on Aboriginal Affairs and Northern Development, Aboriginal Housing, 2007. (return to source paragraph)
35. MLG, pg 14. (return to source paragraph)
36. MLG, pg 17. (return to source paragraph)
37. 2003 April Report of the Auditor General of Canada; paragraph 6.32. (return to source paragraph)
38. Please see Figure 4.1, in the Relevance section for details. (return to source paragraph)
39. INAC defines a major repair as one which fixes extensive structural faults, such as rotting or sagging foundations, extensive structure repairs to walls, floors , ceilings or roofs and the replacement and/or upgrading of defective plumbing and/electrical wiring. A minor repair constitutes something like repairing missing or loose floor tiles, bricks or shingles, defective steps, railings or siding. (return to source paragraph)
40. Data from occupants' survey carried out as part of case studies. (return to source paragraph)
41. Extracted from Canadian Census variables from Statistics Canada. (return to source paragraph)
42. R2 Adjusted Linear = 0.415; p = 0.000 for CWB Income and CWB Housing and R2 Adjusted Linear = 0.125; p = 0.000 for Average Economic Family Income and CWB Housing (return to source paragraph)
43. Extracted from the Community Well-being Index Database (return to source paragraph)
44. RCAP Royal Commission Report on Aboriginal Peoples (return to source paragraph)
45. 2003 April Report of the Auditor General of Canada; paragraph 6.32. (return to source paragraph)
46. Ibid, paragraph 5.13 (return to source paragraph)
47. Ibid, page 1. (return to source paragraph)
48. August 2010 INAC, Audit of On-Reserve Housing, Chief Audit and Evaluation Executive, Audit and Evaluation Sector, pg i (return to source paragraph)
49. Aboriginal Housing committee for British Columbia, "Bringing housing Home: Aboriginal Housing Authorities models and a Strategy for Implementation in British Columbia." Aboriginal Business Development Centre ( June 2005, cited in Literature Review (return to source paragraph)
50. Tilmouth, William, Working Together, Architecture Australia v.97, Issue. 5(Sept/Oct 2008): 87-89. (return to source paragraph)
51. Canada Mortgage Housing Corporation. Establishing On-reserve Housing Authorities. 2007. Page 19. (return to source paragraph)
52. Op cit, page 9. (return to source paragraph)
53. Canada. (2008). Announcement: Indian and Northern Affairs Canada Continues to Strengthen its Fiscal and Mangement Accountability. (return to source paragraph)
54. Indian and Northern Affairs Canada, Capital Facilities and Maintenance Program Performance Measurement Strategy, 2009, pg 15. (return to source paragraph)
55. INAC Audit of On-reserve housing, August, 2010, pg 9 (return to source paragraph)
56. INACEvaluation of the 1996 On-Reserve Housing Policy (return to source paragraph)
57. Canada Mortgage and Housing Corporation, Research Highlight. The Economic Impact of Residential Construction on-reserves, April, 2006, page 2. (return to source paragraph)
58. Canada Mortgage and Housing Corporation, June 2002. Establishing Strong First nations Technical Services Organizations: Framework Modeling (Romanow, Bear and Associates) (return to source paragraph)
59. 2008 INAC Evaluation of the 1996 On-Reserve Housing Policy, Evaluation, Performance Measurement and Review Branch pp 20-21) (return to source paragraph)
60. Canada (2008). Indian and Northern Affairs Canada. Special Study on INAC Funding Arrangements. Page 27 (return to source paragraph)
61. Norbert Koeck, 'On-Reserve Housing Policy Impact Assessment 1996-2000.' October 2000. (return to source paragraph)
62. Ekos Research Associates Inc., Technical Report of the Study of On-Reserve Housing Conditions, Ottawa, March, 1986, pg 4 as cited in INAC's 2008 February Evaluation of the 1996 On-reserve Housing Policy (return to source paragraph)
63. INAC Housing Review Working Group. Indian Housing On-reserves: Towards a new Federal Policy and Approach, Highlights of a Working Paper, 1989. (return to source paragraph)
64. Ibid, pg. 25. (return to source paragraph)
65. Ibid, no page. (return to source paragraph)
66. Canada. Indian and Northern Affairs, "Laying the Foundations of a New On-Reserve Housing Program," Internal discussion paper, 1990, page 11 (return to source paragraph)
67. 2010 Audit , pp 11-12 (return to source paragraph)
68. 2006 May Status Report of the Auditor General of Canada, paragraph 5.23, pg 6 (return to source paragraph)
69. 2008 Evaluation, op.cit. pp19-20 (return to source paragraph)
70. Alcantra, Christopher, "Certificates of Possession and First Nations housing: A Case Study of the Six Nations Housing Program." Canadian Journal of law and Society Vol 20 (2005): 183-205 (return to source paragraph)
71. Brant, Daniel. "Successful Housing in First Nations Communities: A Report on Community Case Studies." Unfinished paper, 2000, cited in Literature search, pg 29. (return to source paragraph)
72. Flanagan, Tom. First Nations? Second Thoughts. Montreal and Kingston: McGill-Queen's University Press. Pages 107-108 cited in Literature review, pg 30. (return to source paragraph)
73. MLG report, pg 41. (return to source paragraph)
74. MLG report, pg 34. (return to source paragraph)
75. Ibid, pg 36. (return to source paragraph)
76. Ibid, 37 (return to source paragraph)
77. Many of these factors are discussed by several authors. However, these factors are best summarized in CMHC's recent research on establishing On-Reserve Housing Authorities, cited on page 19 of the literature review. (return to source paragraph)
78. First Nations Market Housing Fund Participating First Nations (return to source paragraph)
79. National Aboriginal Capital Corporation Association. Policy Paper. May 2005, pg., 6. (return to source paragraph)
80. Canada Mortgage Housing Corporation. Project Profile: Mohawks of the Bay of Quinte housing policy. (return to source paragraph)
81. The Canadian Council for Pubic Private Partnerships. (return to source paragraph)
82. Canada. Treasury Board of Canada. 2008. (return to source paragraph)
83. Canada. Indian and Northern Affairs Canada, 2000. Corporate Systems Manual. Approval and Management of Ministerial Loan Guarantees for Housing. (return to source paragraph)
84. DBRS, Canadian Securitization Market Overview, September 2009. (return to source paragraph)