Evaluation of the On-Reserve Housing Program

Relevance

The evaluation finds a continued need for the ORH program and its alignment with ISC and Government of Canada priorities; however, the magnitude of existing and future demands of housing far exceeds the funding available. A few intensifying or emerging factors, including population growth on-reserve, impacts of climate change and COVID-19 and the growing needs of diverse segments of the communities have placed additional pressure on already limited resources. While the ORH program is deemed as relevant in addressing some needs, insufficient funding for housing on-reserve has exacerbated gaps in relation to meeting health and safety standards, impacts of climate change, and housing gaps are increasing for marginalized and diverse members of the community including youth, single individuals, single parents, seniors, and those with disabilities or special needs. There is a lack of sufficient space or land, serviced lots and public infrastructure to support new housing development.

Effectiveness

The evaluation examined the extent to which the ORH program has been effective in supporting First Nation communities to construct or acquire housing in their communities, develop the capacity to manage their housing, and have the information they need to allocate resources to manage their ISC-funded housing within established health and safety standards. The evaluation also looked at the effectiveness of the funding approach, oversight and support of program delivery, including the First Nations Infrastructure Investment Plan (FNIIP) process. The evaluation finds that the ORH program supported numerous projects in First Nation communities which helped meet some needs and address community infrastructure gaps on-reserve; however, the reliability and sustainability of these housing units could not always be ensured due to funding constraints and program design. Moreover, the CFMP's overarching objectives of maximizing the lifecycle of assets, mitigating health and safety risks and ensuring assets meet applicable codes and standards were not fully achieved. The availability and reliability of performance data continue to be an issue as identified by the evaluation. In reporting on the achievement of the program, there is a lack of performance data and the department mostly uses data at the output level as specified in the program Logic Model (Annex A); alternative performance measurement approaches were proposed to measure the success of the infrastructure investment on reserve more effectively by integrating a wellbeing or human rights centered lens.

The evaluation also looked at the effectiveness of the funding approach, oversight and support of program delivery, including funding formulas and the FNIIP process. First Nations indicated that the ORH program funding model is constraining, and not always reflective of the current costs of housing construction and maintenance and relies on time-limited funds through budget announcements, which is not predictable and sustainable. The current approach does not support strategic long-term planning and the asset management principles; also the prioritization criteria used in the FNIIP process does not sufficiently consider emerging key factors identified by the communities such as public health, climate change and accessibility. Issues identified in accessing ORH program funds included the timing of funds, application criteria and rationale for the approval of proposal-based funds and community capacity. Further, a lack of regular maintenance due to funding availability and backlogs, compounded by worsened weather conditions and lesser quality of materials, resulted in the lifespans of housing on reserves shorter than elsewhere in Canada.

While challenges, including funding insufficiency, continue to create more barriers in meeting the expected outcomes of the program, the evaluation did find that the ORH program provided increased employment and training opportunities as well as social and economic impacts within the community.

Efficiency

The evaluation assessed the extent to which the ORH program demonstrated efficiency and economy. The findings suggested that opportunities exist in improving cost-efficiency and generating more value for money through more integrated planning based on lifecycle asset management principles, applying a whole-of-community approach based on the unique needs and realities of the communities and taking more proactive and preventative measures in repairs and maintenance of investments.

The evaluation finds that the ORH program is mostly delivered in silo within ISC, the planning and approval of housing projects did not sufficiently take into consideration infrastructure investments in other sub-assets under the CFMP, which had resulted in instances where housing units were built without proper enabling features such as connecting roads, sidewalks, street lighting, and fencing to protect from wildlife. The delivery of infrastructure funding in asset-based silos made it difficult to align processes and deadlines, hindering the coordination of funding sources.

Further, cost-efficiencies in the ORH program were not fully achieved as a result of insufficient maintenance and repair, and that project approval decisions tend to opt for the lower-costs options rather than based on long-term asset management planning. Moreover, the evaluation noted a lack of a cohesive approach towards capacity building for asset management, which inhibits the efficiency in delivering community housing outcomes. Related to capacity issues, there was a high turnover of staff, both ISC and First Nation communities, which resulted in inefficiencies due to loss of capacity and additional efforts by First Nations. First Nation respondents cited the lack of trained staff as the main reason inhibiting the reform of their housing programs and in turn making their programs less efficient. First Nation and government respondents called for a cohesive approach and investment towards staff capacity building on housing and asset management.

Crosscutting Findings

The evaluation of the ORH program was conducted simultaneously with the evaluations of the OCI program and EF program. These evaluations revealed that ISC's infrastructure programs share many similarities when it comes to the challenges being faced, from funding insufficiency, program design and delivery, capacity and staff turnover, to data and results measurement. Moreover, the findings point out the interlinkages among the programs that are integral to take into consideration in closing the infrastructure gaps on reserve. More specifically, the asset-based approach through time-limited investments and siloed programming means communities with differing priorities are challenged to adequately plan ahead or address their needs. This resulted in loss of efficiencies and missed opportunities to better meet communities' needs and achieve better health and safety.

Overview

• This Management Response and Action Plan was developed to address recommendations presented in the Evaluation of the On-Reserve Housing Program. It was developed by ISC-Regional Infrastructure Delivery Branch (RIDB) and ISC-Community Infrastructure Branch (CIB) in collaboration with the Evaluation Directorate.
• RIDB and CIB recognize the findings outlined in the evaluation regarding the performance and delivery of the On-Reserve Housing Program.
• The evaluation provides four recommendations to improve the delivery and effectiveness of the On-Reserve Housing program. All recommendations are accepted, and the attached Action Plan identifies specific activities to move towards meeting these recommendations. The program would like to note that the department's ability to provide long-term predictable and sustainable funding for community infrastructure depends primarily on decisions by the Government and direction from central agencies. We concur with the recommendations related to funding in principle and continue to seek funding through the avenues available.

Assurance

• The Action Plan presents appropriate and realistic measures to address the evaluation's recommendations, as well as timelines for initiating and completing the actions. Over the next two years, the department will proceed with a phased response to analyse, develop and implement operational and policy improvements to the On-Reserve Housing program, in consideration of our departmental priorities and ongoing initiatives to modernize the delivery of on-reserve community infrastructure programs and services.
• Many action items involve engagement with partners and relevant stakeholders, with changes to be implemented following these discussions. A status update on this Management Response and Action Plan will be conducted by the Evaluation Directorate regularly and presented to the Departmental Performance Measurement Evaluation Committee to monitor progress and activities.
• The phased approach recognizes program complexities and provides time to engage First Nations and other partners in a meaningful development process.

Capital Facilities and Maintenance Program

According to the 2016 CFMP Program Manual, the CFMP invests in the planning, design, construction, renovation, acquisition and operations and maintenance of community infrastructure that supports First Nations to build healthy, safe and prosperous communities and enables engagement in the economy. Through the CFMP, more than $2 billion per year is invested in four program areas, including housing, education facilities, water and wastewater systems, and other community infrastructure. Program activities are governed by the terms and conditions of the Contributions to support the construction and maintenance of community infrastructure Transfer Payment Program Authority.

ISC allocates funding for the construction and the maintenance of community infrastructure to First Nations at a regional level through formula, proposal-based project funding or as a combination of both. Formula-based funding includes operation and maintenance funding, formula-based minor capital funding, and housing funds, while proposal-based funding, including all targeted funds, covers acquisition, construction, renovation, or repair projects, whether they are major or minor projects.

Funded under three streams, i.e. operations and maintenance, minor capital (for projects under $1.5 million), and major capital (for projects over $1.5 million), the intended objectives of the CFMP are to make investments that:

• Maximize the lifecycle of physical assets;
• Mitigate health and safety risks;
• Ensure assets meet applicable codes and standards; and
• Ensure assets are managed in a cost-effective and efficient manner.

Contributions to eligible recipients under the CFMP provide financial assistance to plan, construct and/or acquire and operate and maintain community capital facilities and services (infrastructure, including schools) and housing (residential) consistent with approved policies and standards. This assistance is provided to First Nations on reserves, as well as First Nations and other eligible recipients on Crown land or recognized Indian land.

On-Reserve Housing Program

The ORH program falls under the core responsibility of governance and community development services in ISC's 2022-23 Departmental Results Framework and contributes to the departmental result of "Indigenous people have reliable and sustainable infrastructure".

Administered under the CFMP, the ORH program funding is provided to First Nations on-reserve and to First Nations and other eligible recipients on Crown land or recognized Indian land to:

• Plan and manage housing needs;
• Design, construct, and acquire new housing units; and
• Renovate existing housing units.

Under the 1996 On-Reserve Housing Policy, ISC provides annual funding to First Nations in most of Canada primarily through a formula-based allocation, which considers, among other factors, population and community remoteness to address a range of housing infrastructure needs (including construction, renovations, maintenance, and governance support). In British Columbia, where the First Nations communities did not opt into the Policy, support for housing on-reserve is provided through the Housing Support Program^{Footnote 8} which provides funds through project-based initiatives.

From 2016-17 to 2020-21 (evaluated period), ISC provided an average of annual base (A-base) funding of $150 million to support on-reserve housing. In addition to construction, renovation and maintenance costs, First Nations can use these funds to contribute towards insurance, debt servicing and the planning and management of their housing portfolios. During the evaluated period, the ORH program also received time-limited targeted (B-base) funding through Budget 2016 and Budget 2018 announcements for a total of more than $1 billion over five years:

• Budget 2016: $417 million over two years (2016-17 to 2017-18) to cover new builds, renovations, additions, and lot servicing, as well as capacity development and innovation;
• Budget 2018: $600 million over three years (2018-19 to 2020-21) to continue addressing the significant infrastructure gap on a proposal basis towards the construction, renovations/additions, lot servicing, as well as capacity development and innovation.

These investments are expected to contribute to increasing the number of units on reserve, address much needed renovations, and prepare lots for future construction. Further, these investments are expected to contribute to increased capacity on-reserve, leveraging innovative practices as well as advancing a co-developed 10-year Housing Strategy with First Nation Partners.

In addition to the authority under the CFMP, as part of related programming to support the ORH program, ISC also provides Ministerial Loan Guarantees for community members who need to obtain a loan to purchase an existing home or financing to fund the construction, acquisition or renovation of on-reserve housing. The ministerial loan guarantees are designed to provide financial security to the lender given that under the terms set out in Section 89(1) of the Indian Act, real property on a reserve cannot be seized by non-Indian and most financial institutions in case of default. The current authority level is set at $3.0 billion.

Program Expenditure

The following table summarizes the ORH program expenses (both A-base and B-base) over the evaluation period. Overall, the ORH program disbursed approximately $1.8 billion over five years, which was split between seven regions, two territories and HQ. Across the regions and territories, Manitoba spent the most at $446 million followed by Ontario at $395 million and Saskatchewan at $248 million. The lowest expenditures were in the Northwest Territories at $1.2 million followed by the Yukon at $31 million.

First Nations Infrastructure Investment Plan

As indicated on ISC website^{Footnote 9}, the FNIIP is a planning tool to help ISC assess infrastructure needs and strategically plan infrastructure investments in First Nations communities across Canada. FNIIPs are how ISC manages CFMP funding and are developed in partnership with First Nations based on community-identified infrastructure needs, which covers all CFMP asset areas. The deadline for a First Nation to submit their infrastructure investment plan to a regional office is September 30 of each year. Investments are prioritized through the National Priority Ranking Framework (NPRF), a planning tool that helps direct funding to the highest priorities using a consistent and transparent process across all regions. Higher-ranked projects are placed in earlier years of the plan, while lower-ranked projects are placed in later years. The amount of money available to support projects identified in the FNIIP varies from year to year due to time-limited, targeted funding programs.

National Priority Ranking Framework

The prioritization of proposed projects is based on several factors covered under the NPRF, including:

• Protection of health and safety as well as assets (assets require upgrading or replacement to meet appropriate standards);
• Health and safety improvements (upgrades of existing assets, new construction/acquisition projects to mitigate an identified significant risk to health and safety);
• Recapitalization/major maintenance (extend the useful operating life of a facility or asset, or maintain the original service level of the asset); and
• Growth (anticipated community growth requiring new construction, expansion or procurement of assets to maintain the level of service standards).

What's not Covered in This Evaluation

While the CMHC receives funding to support housing on the reserves under their respective organizational mandate, this evaluation focuses exclusively on the ORH program delivered by ISC and it is not horizontal in nature, i.e. it does not cover the programs delivered or administered by the CMHC.^{Footnote 10} The focus of the evaluation is on the funded activities delivered under the CFMP by ISC's Regional Operations Sector.

The Ministerial Loan Guarantees were not assessed in this evaluation as part of related programming, given that they were examined by a 2016 Audit of On-Reserve Housing^{Footnote 11} and a 2010 Evaluation of Ministerial Loan Guarantees,^{Footnote 12} which indicated the continued need for them and associated low risks in implementation.

The Indigenous Homes Innovation Initiative of $40 million over five years (2018-19 to 2022-23) though Budget 2018 was not included in the evaluation due to the timing of its implementation, delay due to COVID-19, and limited evidence available during the evaluation period. With its funding allocated on a merit basis using the Impact Canada terms and conditions, the Indigenous Homes Innovation Initiative was launched to support the development of innovative housing approaches to inform systemic level transformation for housing on-reserve and off-reserve across all three Indigenous distinctions. Future evaluations of the Indigenous Homes Innovation Initiative could yield relevant insights to inform the ORH programming.

Crosscutting Issues with Other Infrastructure-related Evaluations

Two other evaluations were conducted during the same period as the ORH program on other infrastructure-related programs under the CFMP, i.e. EF program and the OCI program, which were subject to the same authority and requirements under the CFMP and involved overlapping regional contacts and First Nations partners across the three programs.

To reflect the similarities, independencies and other crosscutting issues across the three programs in delivering infrastructure programs and services to First Nations communities, the Evaluation team assessed these crosscutting aspects that are applicable to all three evaluations in order to provide a more holistic view to inform ISC's infrastructure program and service delivery beyond a single program.

Finding #1: The ORH program aligns with ISC and the Government of Canada priorities.

According to a report commissioned by the Assembly of First Nations and developed by the Institute for Fiscal Studies and Democracy (IFSD), 55,000 new homes are currently needed on reserves, along with 81,000 renovations to existing homes. It is expected that, with population growth and First Nations members moving back to their communities, the need for new housing will grow by a further 80,000 homes by 2040. The deficit is due in part to the remoteness of some communities, a range of socio-economic challenges, O&M policies, and decades of under-funding. In addition, current investments are not keeping pace with population growth, the rate of inflation, and the needs of First Nation communities^{Footnote 16}.

Activities under the ORH program are aligned with the Government of Canada's priorities to address infrastructure gaps on-reserve. The Prime Minister's 2021 Mandate Letter to the Minister of Indigenous Services indicated:

"To achieve equity, you will continue to collaborate with Indigenous partners by working together to close socio-economic gaps and improve access to high-quality services. This includes continuing work to eliminate all remaining long-term drinking water advisories, and closing the infrastructure gap by 2030, with a focus on building sustainable and affordable housing."^{Footnote 17}

The ORH program contributes to ISC's core responsibility of community and regional development and its mandate of improving the quality of services delivered to non-self-governing Indigenous communities through the following activities:

1. Provide funding and advice to eligible recipients under the CFMP;
2. Collect data self-reported by First Nations using data collection instruments;
3. Provide funding and support to First Nations for communities to operate and maintain their ISC-funded housing.

Working in partnership with First Nations, the ORH program seeks to increase the supply of safe housing to achieve better housing outcomes for on reserve residents with the ultimate goal of transferring the services to Indigenous peoples. These activities are aligned with the Government of Canada's priorities as indicated in the Prime Minister's 2021 Mandate Letter to the Minister of Indigenous Services to:

"collaborate with Indigenous partners—by working together to close socio-economic gaps and improve access to high-quality services. This includes continuing work to eliminate all remaining long-term drinking water advisories, and closing the infrastructure gap by 2030, with a focus on building sustainable and affordable housing."^{Footnote 18}

Finding #2: First Nation needs for housing units on-reserve are large and growing.

A 2020 study commissioned by the AFN about First Nations on-reserve housing estimated that 34,000 housing units would be required to meet the on-reserve housing needs by 2025.^{Footnote 19} ISC reported on progress between April 2016 and March 2021^{Footnote 20} that, in collaboration with CMHC, a total of over 22,498 housing units were being built, renovated or retrofitted using targeted funding.

Of the survey respondents, merely 4% agreed that their communities had sufficient housing units. However, the majority of survey respondents agreed that their community had the skills and experience to operate and maintain infrastructure projects (56%) and had sufficient land to support new infrastructure build (53%) (Figure 4.1). This suggests that more than half of First Nation communities have put themselves in a position that prepares them to be more proactive in addressing their housing needs when ORH program funding opportunities arise.

ISC Evaluation Survey 2022 (Question: To what extent do you agree with the following statements about your community? Respondents n=93.)

Text alternative for Figure 4.1: Agreement with Current Community Needs

Figure 4.1 "Agreement with Current Community Needs" outlines the responses to the question "To what extent do you agree with the following statements about your community" from the "ISC Evaluation Survey 2022". For each statement, the survey offered the response options "Agree/Strongly Agree", "Neither Agree nor Disagree", "Disagree/Strongly Disagree", and "Don't Know".

For the statement "The community has the skills and experience to operate and maintain infrastructure projects", out of a total of 93 respondents, 58% agree/strongly agree with the statement, 18% neither agree nor disagree, 24% disagree/strongly disagree, and 1% selected "Don't Know" as their response.

For the statement "There is sufficient land to support new infrastructure build", out of a total of 93 respondents, 53% agree/strongly agree with the statement, 8% neither agree nor disagree, 38% disagree/strongly disagree, and 2% selected "Don't Know" as their response.

For the statement "There is sufficient public infrastructure in the community to support new housing development", out of a total of 93 respondents, 20% agree/strongly agree with the statement, 11% neither agree nor disagree, and 69% disagree/strongly disagree with the statement.

For the statement "Sufficient workforce exists within the community", out of a total of 93 respondents, 17% agree/strongly agree with the statement, 14% neither agree nor disagree, 68% disagree/strongly disagree, and 2% selected "Don't Know" as their response.

For the statement "The community has sufficient revenues to meet its overall infrastructure needs", out of a total of 93 respondents, 7% agree/strongly agree with the statement, 8% neither agree nor disagree, 83% disagree/strongly disagree, and 3% selected "Don't Know" as their response.

For the statement "The community has sufficient housing units for residents", out of a total of 93 respondents, 4% agree/strongly agree with the statement, 3% neither agree nor disagree, 91% disagree/strongly disagree, and 1% selected "Don't Know" as their response.

There was unanimity among interview respondents about the magnitude of existing on-reserve housing needs. Many respondents stated that although First Nations housing issues have existed for decades, they have escalated in recent years to crisis levels. In addition to the growing population of those already living on reserve, respondents also cited the return of band members who were living in cities to their communities due to market rent increases in urban areas across Canada.

Focus group participants noted the need for more housing in their community to meet the needs of growing families.

"The young children, how many homes have young children, and they are just getting by with what they have? … They need to fix up these homes and get these young people and their children in houses. I am frustrated with the housing situation in our community, we have a lot of families and children living in camping trailers."

Finding #3: Many First Nation communities do not have sufficient space and/or appropriate land to build new housing.

Many First Nations indicated the amount of land they had available for housing was limited either because of lack of space to build or lack of suitable land to build on. While some First Nations noted they could acquire surrounding land, the addition to reserves process is lengthy and complicated, involving federal, provincial, and municipal governments. First Nation community respondents in BC, Ontario, and Atlantic provinces were particularly likely to indicate that the lack of appropriate land limited their ability to build new housing. Several respondents from these regions noted that the land upon which their reserve was located was unsuitable for construction (e.g. a flood plain, swampy) and required significant preparation to make them suitable to build.

The lack of space to build new homes is also impacted by dilapidated housing occupying suitable land. One ISC regional respondent said that it is important to build new housing on the site of existing housing because, not only does it make the community look better by removing boarded-up houses, but it also allows communities to build new housing on appropriate and available land. Although the ORH program does not cover demolition costs, if the abandoned buildings are on serviced lots, once demolished these lots would be shovel ready for communities to take advantage should funding become available.

Focus group participants indicated that there were many abandoned homes in their community and that this had been an ongoing issue for many years. Some were older homes that had become unlivable because the owners could not afford needed repairs. Others were new constructions that were abandoned before they had been completed.

"I see nice-looking houses that could be fixed up. It makes me angry because someone could be living in that house. I have suggested to people to ask the owner if they are willing to rent out the house, but I do not know how they would get the funding to fix it up. The house could probably be rented to a family, or seniors and elders."

Finding #4: Sufficient serviced lots and public infrastructure are needed to support new housing development.

Approximately 69% of survey respondents indicated that there was not sufficient public infrastructure in the community to support new housing development. Almost all First Nation community respondents noted challenges with providing serviced lots to build houses. According to some First Nations interviewees, funding received for housing does not always cover the associated services homes need. For example, while funding is provided to connect housing to existing water and wastewater services, it may not cover the costs to bring the water and wastewater piping to the building lot. Funding also does not cover any upgrades needed for water and wastewater plants to support additional housing on reserve. In other cases, First Nation representatives indicated that they also needed to build roads and sidewalks to access the housing lots. The interviewees shared their experiences that the funding for associated services requires a separate application process that is not coordinated with the funding for housing. While some respondents said their communities were able to overcome these gaps by funding these services through other means, a few respondents noted that they have built homes only to have them sit empty until the services can be added.

The lack of serviced lots and the importance of having serviced lots be "shovel ready" when funding for housing becomes available was discussed by most regional ISC respondents and by the AFN. One regional staff said this region has decided to systematically prioritize lot servicing over construction and renovations to ensure when additional funding for construction and renovation is secured, whether it is from ISC or CMHC, the community is ready to build. This example contrasts with the experience of some other regions that expressed disappointment in not being ready for the funding made available through CMHC's Rapid Housing Initiative,^{Footnote 21} which required that units be built within a year and thus in practice, required that lots be already serviced.

Finding #5: There is a need for varying types and sizes of units along a housing continuum as First Nation communities struggle to meet the needs of diverse members of their communities, most notably youth, single individuals, single parents, seniors, and those with disabilities or special needs.

With the changing population profile on reserve, there is a need for more diverse types and sizes of housing units, as compared to the bungalow homes with three to four bedrooms that have been predominantly built on reserve.

Some of the needs identified by respondents include:

• Multi-unit one-bedroom houses that would better serve First Nations youth, singles, single parents, seniors, and those with disabilities or special needs;
• Larger homes for multi-generation families;
• Transitional housing to support community individuals in treatment, isolation, and rehabilitation; and
• Transient housing for professionals working in the communities.

While First Nations decide how and what kind of housing is built in their own communities, respondents from ISC, CMHC, and Indigenous organizations noted that the lack of housing combined with the lack of diversity in size, types, and tenures of housing, with the exception of families (mono-families or multigeneration families), is reinforcing the housing crisis. Some respondents noted that the lack of housing and diversity of housing encourages some people to leave their communities, moving off-reserve. A subsequent outcome of this may be that some will become homeless in cities.

Half of survey respondents indicated they struggled to provide adequate housing to diverse segments of the population in their community. The most frequently mentioned groups not being adequately supported were people living with disabilities, people with mental health issues, and seniors. Other mentions included single adults, people with low income, and homeless individuals (Figure 4.2).

ISC Evaluation Survey 2022 (Question: Which of the following housing needs are not being addressed by the On-reserve Housing program? Asked of those who disagreed or strongly disagreed OHR program serves diverse segments of the community's population. Multiple responses are permitted. Respondents n=46.)

Text alternative for Figure 4.2: Groups Most Likely to Encounter Challenges Accessing On-Reserve Housing

The ISC Evaluation Survey 2022 posed the question "Which of the following housing needs are not being addressed by the On-reserve Housing program?" Of those who disagreed or strongly disagreed that the OHR program serves diverse segments of the community's population, the individuals were asked which groups are most likely to encounter challenges accessing on-reserve housing, with multiple options being permitted. Figure 4.2 "Groups Most Likely to Encounter Challenges Accessing On-Reserve Housing" outlines the responses to this question. Out of a total of 46 respondents, 74% of survey respondents selected "People living with disabilities" as a group most likely to encounter challenges accessing on-reserve housing. Additionally, 74% of survey respondents selected "People with mental health issues", as well as "seniors" as groups most likely to encounter challenges accessing on-reserve housing.

On the other hand, 63% of survey respondents selected "Single parents" as a group most likely to encounter challenges accessing on-reserve housing, while 61% of respondents selected "Multi-generational families". Lastly, 48% of respondents selected "Women" as a group most likely to encounter challenges accessing on-reserve housing, while 48% of respondents selected "Two-spirited, gay, lesbian, bisexual, transgender, queer, and questioning community", and 24% of respondents selected "Other".

Others noted that the lack of housing also impacts the ability to attract and retain young professionals to settle in First Nation communities. It has been observed that it is difficult to hire new First Nations graduates who would like to come back to their community to work and hire or retain other professionals. This, in turn, means that there could be some existing capacity lost from the communities due to a lack of proper housing.

Other First Nation respondents were looking to find on reserve solutions to homelessness and safe accommodation for those escaping violence instead of having them leave the reserve.

Finding #6: Despite the evident need to build more types of housing units, some factors contributed to the lack of diverse housing being built on-reserve.

A few ISC respondents said that although the need for building different types of housing other than the current prevailing three-bedroom bungalow is evident, the decision to build certain types of housing lies with each band. First Nation organizations observed that some communities may be reluctant or are not fully aware that they can build more diverse types of housing because they have only ever received funding to build bungalows. Other ISC and First Nation respondents indicated that many First Nation communities have waiting lists and the households that are prioritized are families with children for which the bungalow remains the preferred option.

Other government respondents and First Nation organizations note that the decision on what type of housing to build comes down to the amount of money and timing of the funds— it is easier, cheaper, and quicker to build using known models or off-the-shelf housing designs than to go with innovative or different types of housing. Some First Nation respondents acknowledged that they often have to rely on off-the-shelf housing designs that are not suited to address the specific needs and challenges faced by some community members. Some First Nation respondents indicated that they use the same or similar housing designs from previously funded projects as a means of ensuring their projects will be approved for funding.

Other First Nation respondents noted that it is challenging to get approval for multi-unit one-bedroom homes that would better serve some groups, both from within their band leadership and through ORH program funding. While some reasons for the lack of band leadership support are not directly related to the ORH program such as the belief that multi-unit single-type dwellings detract from the cohesion of the community and their cultural values of togetherness, other reasons connected to the ORH program are the lack of resources to develop targeted housing plans and strategies, thus resulting in more reactive housing management that focuses on urgent issues and does not address the housing needs of all community members.

First Nation community respondents also commented on challenges to retrofitting existing homes to make them more accessible for seniors and those with disabilities or special needs. While some noted that they can access other sources to help fund such retrofits, this presents its own challenges as many funding streams such as those that support health, addiction, and family integration are not aligned with the ORH program. For example, funding may be available to install a lift, but there is no funding for the maintenance of that equipment.

Finding #7: Health and safety standards were identified as a top issue in housing on reserves.

Health and safety standards were the most frequently mentioned needs not addressed for housing on-reserve (58% of survey respondents), followed by climate change and resilience (54%), and environmental building standards (46%). Under the Other Category (11% of respondents), there were mentions of needs not met by the program including poor quality of living conditions, building code requirements, homeownership, and the needs of diverse segments of the community (Figure 4.3).

The issue of health and safety standards not being met could be related to overcrowding situations and their link with the transmission of respiratory illnesses, absence of safe drinking water, lack of proper heating and cooling, and fire protection. Many First Nation respondents noted that the inability to address needed repairs in a timely manner exacerbated health and mental health concerns and increased safety issues including fire hazards.^{Footnote 23} Others noted that living in overcrowded homes can lead to increased incidents of violence and sexual assault. Several respondents spoke of the challenges of separating social issues from housing issues and noted that more needs to be done to find integrated solutions to address these issues as a system.

ISC Evaluation Survey 2022 (Question: Which of the following housing needs are not being addressed by the On-reserve Housing program? Asked of those who disagreed or strongly disagreed On-Reserve Housing program addressed communities' housing needs. Multiple responses are permitted. Respondents n=57.)

Text alternative for Figure 4.3: Housing Needs Identified by First Nation

Of First Nations respondents who disagreed or strongly disagreed that the On-Reserve Housing Program addressed communities' housing needs, The ISC Evaluation Survey 2022 posed the question "Which of the following housing needs are not being addressed by the On-reserve Housing program?", with multiple responses being permitted. Figure 4.3 "Housing Needs Identified by First Nation" outlines the responses to this question. Out of a total of 57 respondents, 58% selected "Health and safety standards" as a housing need that is not being addressed by the On-Reserve Housing program, while 54% of respondents selected "Climate change and resilience".

Additionally, 46% of respondents selected "Environmental building standards", 16% selected "Overcrowding/insufficient housing", while 9% selected "Funding in general". While 7% of respondents selected "Funds for building efficient homes" as a housing need not being addressed by the On-Reserve Housing program, 5% of respondents selected "Funds for maintenance of houses", and 5% selected "Community infrastructure".

Additionally, 5% of respondents selected "Social issues" as a housing need not being addressed by the program, while 4% of respondents selected "Homes for disabled or assisted needs living", and 4% selected "Costs of materials for construction". Lastly, while 11% of respondents selected "Other", 4% of respondents selected "Prefer not to say".

Focus group participants cited increased health risks due to reoccurring mould issues in their homes which required costly repairs. In addition, the need to be temporarily displaced while the issue was being resolved caused increased stress and anxiety. Another focus group participant experienced difficulty adapting their home to accommodate family members' physical disabilities and other health issues as they did not have the funds to complete needed retrofits, did not qualify for any funding program, and struggled to secure a loan.

Finding #8: The ORH program funding has not been sufficient in meeting First Nation housing needs for many years.

While a more detailed discussion with regards to the effectiveness of ORH program funding is discussed later under Effectiveness (Section 5.1), the issue of funding is discussed here more generally as it pertains to the lack of funding for housing as being a challenge for many First Nations.

The amount of government funding available for housing on-reserve is viewed as insufficient by both internal and external stakeholders and First Nation communities. The AFN in partnership with the Institute of Fiscal Studies and Democracy has estimated a need for $59.4 billion in on-reserve housing to close the housing gap on-reserve by 2040. A subsequent 2022 AFN study further identified the need to be $135.1 billion. Respondents acknowledge that no one source of funding for First Nation housing, or even numerous sources combined, can sufficiently address the housing needs of First Nation communities.

For example, the annual amount of funding provided by the minor capital allocation has not been indexed for many years – if the full annual amount is divided by the number of communities that receive it, the money available per community amounts to approximately $250,000 per year which is not enough to build a single new home. While other government departments such as CMHC also provide funding for on-reserve housing, their budgets are also limited. Although some First Nations supplement government housing funding through own-source revenues and leveraging funds from other sources, many First Nations do not have such revenue streams and/or lack the capacity to access other funding for various reasons which will be discussed throughout this report.

Finding #9: Capacity continues to be a challenge, especially in regard to the housing manager's role, which tends to be over-burdened and without appropriate support.

Many First Nation respondents cited the lack of trained staff and governance issues within their community as the main reasons inhibiting the reform of their housing programs. The need for skilled housing managers, in particular, was mentioned in every group of interview respondents. Too often housing managers are overburdened (which was exacerbated during COVID), low-paid, untrained, and subject to the directive of chief and council. Others cited the lack of tenant relation officers, repair crews and support staff to help administer housing.

Few communities had individuals specifically tasked to develop long-term planning and housing strategies. Respondents were often the only or one of few people responsible for the housing portfolio in their community; many relied on external consultants, tribal councils, and First Nation technical service organizations for support in preparing proposals, reports, and needs assessments, and in hiring inspectors to ensure buildings met construction standards.

Among First Nation respondents indicating their community's ability to successfully reform and manage their housing, the most mentioned reasons for their success were their ability to develop long-term housing strategies and having the capacity and resources to implement these strategies. Several government respondents indicated that having the capacity to manage housing on reserve is closely tied to the position of housing manager. These respondents explained that the complexities associated with housing management require individuals who are well-prepared and well-trained to meet the demands of the position.

Most respondents indicated that the ORH program should pay for training housing managers and provide for competitive salaries, suggesting that as long as salaries are not competitive, housing managers will continue to leave to work in nearby municipalities which pay better. The FNHPA explained that training for housing managers is money well spent as the training not only prepares an individual for that specific job but also for any "public service" job on reserve. Funded by ISC, the FNHPA has developed a rigorous training program and provides certification for housing managers. The Manitoba region has a pilot program that uses ISC housing funding to pay for the salary of housing managers on reserve, which has been well received.

Finding #10: Other challenges include increased construction costs, lack of skilled labor within the community, and collaboration with federal, and/or provincial/ territorial partners.

Increased construction costs was the challenge that had the greatest impact on communities. A total of 86% of survey respondents noted increased costs of construction impacted their community to a great extent, and an additional 12% said increased cost of construction somewhat impacted their community (Figure 4.4). Another impactful community challenge was the shortage of skilled labor or experienced contractors within the community (41% of survey respondents said their community was impacted by the shortage to a great extent and 44% indicated they were somewhat impacted by the shortage). Mentions of other community challenges echoed challenges mentioned by interviewees across all categories including lack of funding, lack of suitable land, lack of housing, lack of training facilities, and lack of resources. The degree to which such challenges inhibit communities varies depending on their capacity to manage current housing and plan for sustainable housing over the long-term.

ISC Evaluation Survey 2022 (Question: To what extent does each of the following present challenges in your community? Respondents n=93.)

Text alternative for Figure 4.4: Extent Challenges Impact Community

Figure 4.4 "Extent Challenges Impact Community" outlines the responses to the ISC Evaluation Survey 2022 question "To what extent does each of the following present challenges in your community?". For each challenge, the survey offered the response options "To a great extent", "Somewhat", "Very little", "Not at all", "Don't know".

For the challenge "Increased construction costs", out of a total of 93 respondents, 86% selected "To a great extent", while 12% selected "Somewhat", and 2% selected "Very little".

For the challenge "Availability of skilled labor or experienced contractors to operate in the community", out of a total of 93 respondents, 41% selected "To a great extent", 44% selected somewhat, 14% selected "Very Little", and 1% selected "Not at all".

For the challenge "Collaboration with federal/provincial/territorial partners", out of a total of 93 respondents, 36% selected "To a great extent", 44% selected "Somewhat", 14% selected "Very little", 3% selected "Not at all", and 3% selected "Don't know".

For the challenge "Harsh climate and/or catastrophic weather events in recent years", out of a total of 93 respondents, 24% selected "To a great extent", 43% selected "Somewhat", 26% selected "Very little", and 8% selected "Not at all".

For the challenge "Remoteness of the community", out of a total of 93 respondents, 19% selected "To a great extent", 39% selected "Somewhat", 13% selected "Very little", 27% selected "Not at all", and 2% selected "Don't know".

Lastly, in terms of "other" challenges impacting the community, out of a total of 93 respondents, 65% selected "To a great extent", 20% selected "Somewhat", 10% selected "Very little", and 5% selected "Don't know".

Finding #11: Overcrowding and poorly built homes increase the need for repairs and significantly reduce the lifecycle of dwellings on-reserve when compared with those off-reserve.

First Nation community respondents, particularly those in Saskatchewan, Manitoba, the Northwest Territories, Northern Ontario, and Atlantic Canada, noted that overcrowding is common among houses on reserve, with an average of around eight individuals per on reserve house. The overcrowding adds to the wear of houses and necessitates repairs. Interview respondents noted that houses on reserve do not last as long as houses built elsewhere in Canada due to overcrowding issues, and poorly built homes, which leads to homes having to be rebuilt every 15 years or so, which is far less than homes off-reserve. Many respondents also indicated that to build a home within the approved budget, they use materials that can be of lesser quality and/or materials that are less resistant to the harsh climate they experience (e.g., winter conditions, flooding, and extreme winds).

A 2016 report on housing needs on reserve noted the following indicators for the rate of change in the condition of on reserve housing:^{Footnote 26}

• The need for minor or major repairs was found to develop between 7 and 12 times more quickly on reserve than off reserve; major repair needs were found to develop about 26 times more quickly on reserve;
• The development of repair needs (minor and/or major) occurs about twice as quickly among band-managed housing, as opposed to rented housing on reserve;
• The data for 2016 suggests that problems with initial construction quality among reserve dwellings continue to be common; and
• There exists a large backlog of renovation needs among reserve dwellings in all provinces/regions.

The 2021 Census indicated that First Nations people living on reserve are more likely to live in crowded housing or a dwelling in need of major repairs:^{Footnote 27}

• Over one in five First Nations people (21.4%, or 224,280 people) lived in crowded housing in 2021, with 12.9% living in housing with a one-bedroom shortfall, 4.8% living in housing with a two-bedroom shortfall and 3.8% living in housing with a shortfall of three or more bedrooms;
• In 2021, almost one in five First Nations people (19.7%, or 206,845 people) were living in a dwelling in need of major repairs;
• Over one-third of First Nations people with Registered or Treaty Indian status living on reserve lived in a dwelling in need of major repairs (37.4%), almost three times the rate of their counterparts living off reserve (12.7%);
• Nationally, the share of First Nations people living in dwellings in need of major repairs was highest in the Northwest Territories (30.0%) and Manitoba (28.7%) and lowest in Newfoundland and Labrador (8.6%).

Finding #12: Challenges exist in establishing a variety of housing tenures such as rentals and private ownership on reserve, which could help address issues in relation to housing maintenance, repair and management.

Having a variety of housing tenure on reserve was seen by several respondents (government, First Nation organizations and communities) as a way to help address some of the housing issues connected with the need for maintenance and repairs and improve housing outcomes. Community members who can afford to own a home should also be able to do regular maintenance and minor repairs on their homes. Charging rent for band-managed homes means some portion of the rent can be set aside for repairs. Homeowners with extra space could take on tenants.

Interview respondents, notably from the First Nations Market Housing Fund and the Société d'épargne des autochtones du Canada, promoted private ownership and private rentals for First Nation residents who can afford it. Several First Nation respondents indicated that their community supported a variety of housing tenures such as social housing, rentals, and private ownership. They also encouraged homeowners and tenants to educate themselves on how to do regular maintenance and make basic repairs to their homes. One community offered one month of free rent each year if the renters maintained the property themselves.

However, First Nation and government respondents observed several challenges with homeownership and charging rent for band-managed housing that impede a wide-spread use of such housing tenure in many First Nation communities. In some communities, there is an expectation among their members that housing is due or free and therefore the leadership are reluctant to charge rent. Other communities are reluctant to set aside funds from social benefits for rent on social housing because individuals in receipt of such funds struggle to make ends meet. First Nation organizations and community respondents noted that progress has been made in this respect and many First Nation communities charge rent for band-provided housing. However, respondents acknowledged that the low incomes of many households on reserve put a real limit to what can be charged.

Respondents across all categories pointed to several challenges around home ownership on reserve including issues around obtaining insurance and the fact that existing housing cannot be used as collateral to obtain loans from a financial institution. Obtaining insurance, which is required for some government funding streams and bank loans is extremely difficult for First Nation homeowners. Many reserves do not have fire hydrants, which results in unfeasible insurance rates (upwards of $40,000) if they can get insured at all. As a result, the band must take on the loan, which creates more barriers to homeownership as not all bands are willing or have the capacity to carry the housing loans for their members.

Finding #13: Climate change is increasingly and negatively impacting housing on-reserve; however, there is currently no proactive and consistent approach in housing planning and design taking into consideration infrastructure resiliency to address and mitigate these impacts on communities.

The impact of climate change and resilience on housing were identified as another need for housing on-reserve (54% of survey respondents)^{Footnote 28}. Climate change has increasingly become a challenge for First Nation communities. Several First Nation community respondents reported that climate change was having an impact on the lifespan of their housing. Homes built with materials of lesser quality are less resistant to extreme weather conditions.

The level of awareness and experience of the effects of climate change varies across the country; with the more prominent effects observed in the western provinces and in remote, northern communities. Across the country, climate change effects experienced by First Nation communities and mentioned by interview respondents include forest fires, flooding, bank erosion, permafrost melting, heat waves and zoonotic changes (i.e. ticks and Lyme disease, mosquitoes and West Nile virus).

Not only does climate change decrease the lifecycle of housing, but climate change also impacts new construction. While building standards are changing to respond to climate change (to ensure climate resiliency), respondents noted that the funding budgets have not sufficiently increased to accommodate these higher costs. Areas impacted by floods and fire require more preparation to ready the land for construction, which requires separate funding. Northern communities that rely on winter roads to bring in their construction materials noted that climate change has reduced the time in which they can use the winter roads, further limiting the amount of housing that can be added to the supply.

ISC respondents indicated that ISC has no proactive and consistent approach to address climate change impacts on reserve. They also noted the lack of alignment between ISC and existing energy efficiency funding programs from other federal agencies, the provinces, and public utilities. Many First Nation and government respondents stated that community plans need to consider infrastructure resilience. For example, plans should include clearing up flammable biomatter forests and long grasses from around communities, developing housing away from riverbanks or seashores, replacing houses that risk being washed away, and planting trees around houses to create shade. Many respondents also noted the need to include energy efficiency in the design, construction and renovation of existing housing units and for equipment that would mitigate the effects of climate changes, including housing with elevated foundations or crawl spaces, windows with screens, and air conditioning.

One example of a community's use of innovative building systems to develop more resilient housing is in Fort Severn. This community received funding that allowed them to build duplexes that can withstand changes in permafrost and maintain a solid foundation. For this innovation, the First Nation was the recipient of the 2020 Housing Recognition Award from the First Nations Housing Working Group.^{Footnote 29}

Finding #14: The COVID-19 pandemic has illustrated the existing link between overcrowding and respiratory illnesses and posed additional challenges in meeting housing needs on-reserve.

Survey respondents detailed how the COVID-19 pandemic has impacted their communities with 58% indicating that COVID impacted their community to a great extent and a further 25% saying the pandemic somewhat impacted their communities.

For most, the pandemic exacerbated the need for housing as there were:

• Limited space for isolation;
• Delays to construction projects and housing repairs due to supply chain issues and lack of workers (due to sickness and the inability to bring in workers from outside of the community under lockdown orders);
• Increases in the prices of materials and workers also drove up their costs;
• An increase in the number of members requesting to move back to the reserve to assist families impacted by COVID and because they had lost their jobs;
• Increased prevalence of mental health issues; and
• Additional wear on housing as household members spent 24 hours a day in their house for prolonged periods.

Several First Nation respondents indicated they closed their communities to non-residents as a measure to prevent wide-spread community infection due to their overcrowding issues. Community closure also meant that ISC and CMHC regional staff stopped visiting First Nation communities, which created certain delays, notably at ISC, with service transfer promotion and other projects.

The majority of interview respondents mentioned that COVID illustrated the existing link between overcrowding and respiratory illnesses. In turn, this highlighted the importance of having transitional housing commonly referred to as "swing space" for people who need to isolate during a pandemic or for other reasons. Although some communities did receive a few isolation units, respondents noted that more thought could have gone into the type of units employed. While they were intended to be temporary, some commented that if the units were better equipped to handle northern climates or to be used long-term, they could have been repurposed as permanent housing once the crisis had passed. A few respondents noted that not only can they not re-purpose the units, but they also cannot properly dispose of them, adding to environmental issues.

Finding #15: Despite funding limitations, the ORH program supported numerous housing projects and has helped address some infrastructure gaps in First Nation communities.

A 2019 ISC assessment of current housing needs on reserve estimated a need to support 79,000 housing units across First Nation communities; 58,000 existing housing in need of major repairs and 21,000 new builds.^{Footnote 30}

ISC reported on progress on investing in Indigenous community infrastructure between April 2016 and March 2021:^{Footnote 31}

• $987.9 million targeted funding was invested to support 2,761 housing-related infrastructure projects: 21,585 projects completed; 1,176 projects ongoing; 608 First Nations communities benefitting;;
• In collaboration with CMHC, ISC was supporting the construction, renovation and retrofit of a total of 22,498 homes, of which 10,070 were delivered under ISC (6,190 homes completed and 3,880 in progress): 2,041 new unit constructions and 4,149 renovations and retrofits completed;
• In addition to new builds and renovations, First Nations were in the process of acquiring and servicing 1,323 lots, of which 868 were completed and 455 in progress. As well, 1,037 housing-related capacity development and innovation projects in First Nations communities were supported, with 647 projects completed and 390 underway, benefiting 605 FNs.

However, the majority (61%) of survey respondents involved in the ORH program indicated the program did not respond to the need for housing in their community. A greater proportion of survey respondents located in Saskatchewan (79%) and Alberta (70%) noted that the ORH program did not respond to their communities' needs compared to 64% of B.C. survey respondents and 54% of Ontario survey respondents.^{Footnote 32} Additionally, fewer than one-third (32%) of survey respondents agreed that overall the ORH program helped address housing gaps in their community (Figure 5.1). Government respondents also indicated that the ORH program has only partially achieved its objective of building new housing units and renovating housing needing major repairs.

Despite not viewing the ORH program as fully meeting community needs, survey respondents agreed that the program helped their community address five of nine defined housing gaps, including helping communities (Figure 5.1): construct new housing units; renovate units in need of repair; prepare new lots for construction; apply innovative initiatives to address housing needs, and improve the community's housing management and governance.

ISC Evaluation Survey 2022 (Question: To what extent do you agree with the following statements? The On-reserve Housing program helps my community to… Respondents n=93.)

Text alternative for Figure 5.1: Extent On-Reserve Housing Program Has Helped Community

Figure 5.1 "Extent On-Reserve Housing Program Has Helped Community" outlines the responses to the ISC Evaluation Survey 2022 question "To what extent do you agree with the following statements? The On-reserve Housing program has helped my community to…". For each statement, the survey offered the response options "Agree/Strongly Agree", "Neither Agree nor Disagree", "Disagree/Strongly Disagree", and "Don't know".

For the statement "Overall, helped address the housing gaps in my community", out of a total of 93 respondents, 32% agree/strongly agree with the statement, 19% neither agree nor disagree, 46% disagree/strongly disagree, and 2% selected "Don't know".

For the statement "Construct new housing units", out of a total of 93 respondents, 53% agree/strongly agree, 24% neither agree nor disagree, 23% disagree/strongly disagree, and 1% selected "Don't know".

For the statement "Renovate units in need of repair", out of a total of 93 respondents, 51% agree/strongly agree, 17% neither agree nor disagree, 31% disagree/strongly disagree, and 1% selected "Don't know".

For the statement "Prepare new lots for construction", out of a total of 93 respondents, 44% agree/strongly agree, 23% neither agree nor disagree, 31% disagree/strongly disagree, and 2% selected "Don't know".

For the statement "Apply innovative initiatives to address housing needs", out of a total of 93 respondents, 38% agree/strongly agree, 26% neither agree nor disagree, 36% disagree/strongly disagree, and 1% selected "Don't know".

For the statement "Improve the community's housing management and governance", out of a total of 93 respondents, 34% agree/strongly agree, 28% neither agree nor disagree, 33% disagree/strongly disagree, and 4% selected "Don't know".

For the statement "Have more reliable and sustainable housing units over the past 5 years", out of a total of 93 respondents, 29% agree/strongly agree, 25% neither agree nor disagree, 42% disagree/strongly disagree, and 4% selected "Don't know".

For the statement "Accommodate segments of the population that are difficult to house", out of a total of 93 respondents, 29% agree/strongly agree, 31% neither agree nor disagree, 37% disagree/strongly disagree, and 3% selected "Don't know".

For the statement "Redesign housing units", out of a total of 93 respondents, 23% agree/strongly agree, 28% neither agree nor disagree, 44% disagree/strongly disagree, and 5% selected "Don't know".

For the statement "Add bedrooms to overcrowded units", out of a total of 93 respondents, 20% agree/strongly agree, 26% neither agree nor disagree, 50% disagree/strongly disagree, and 4% selected "Don't know".

Finding #16: While the funding helped address some urgent housing needs, the scope of the ORH program is insufficient to fully address housing gaps in First Nation communities.

ISC respondents affirmed that targeted funding had helped many First Nations address some urgent housing needs. For example, one First Nation respondent noted that the funding allowed them to complete urgent repairs on about 90% of their band-managed homes. However, housing gaps were too great and the scope of the program too modest to meet housing demands in most of the communities. First Nation respondents noted that if they were successful in obtaining funding, the amounts received only supported a few new builds per year and were insufficient to address major housing repairs. In addition, other costs that are directly tied to building and maintaining housing are not always sufficiently funded, such as the costs to service the lots or to demolish existing housing.

With respect to the extent to which the ORH program has supported First Nations communities, survey respondents disagreed that ISC supported their community to:

• maintain housing on an ongoing basis (51%),
• design and construct housing units (42%),
• have the information needed to allocate resources to manage housing (40%),
• identify housing needs (40%), and
• develop housing plans (38%).

Comments provided by survey respondents about why they felt their community was not being supported centered on overcrowding issues and the high demand for housing, unrealistic funding amounts given rising materials and construction costs. Moreover, while the ORH program can support lot servicing and program communications state that communities are expected to seek other sources of funding other than through the ORH program, some survey respondents expressed dissatisfaction with available support in relation to lot servicing and the fact that communities having to look elsewhere and/or use own sourced revenue to build and maintain housing.

Finding #17: Despite the overall satisfaction for the ORH program being low, many viewed the quality of the ORH program services offered by ISC as having improved over the past five years.

The overall satisfaction with the ORH program as indicated by the survey was low, with 42% indicating they were dissatisfied and only 28% indicating they were satisfied with the program. A greater proportion of respondents from Saskatchewan were dissatisfied with the ORH program than respondents from other regions (62% vs. 60% Alberta, 43% B.C., 27% Ontario).^{Footnote 33} Reasons for the low level of satisfaction with the ORH program included an acknowledgment that the funding provided is helpful but not sufficient to meet housing needs, communities having to build cheaper houses that deteriorate faster, and having to use own-source revenue or divert funding from other departments to address housing issues.

However, more survey respondents (approximately 41%) stated that the quality of the ORH program services offered at the community level had improved over the past five years, while 32% said the quality had stayed the same, and 14% noted it was worse than five years ago (Figure 5.2). Reasons for increased quality included: having increased control over construction, design, and labor; and the ability to leverage additional funding. Reasons for decreased quality included: a lack of human resources to address housing needs and manage housing; increases in the cost of living and construction costs; lot development being sufficiently funded; and growing demand for housing.

ISC Evaluation Survey 2022 (Question: How has the quality of the On-reserve Housing services offered at the community level changed over the past five years or so, has it… The Total may not add to 100% due to rounding. Respondents n=93.)

Text alternative for Figure 5.2: Improvement in the Quality of ORH Program Over Past 5 Years

Figure 5.2 "Improvement in the Quality of ORH Program Over Past 5 Years" outlines the responses to the ISC Evaluation Survey 2022 question "How has the quality of the On-reserve Housing services offered at the community level changed over the past five years or so, has it…". Out of a total of 93 respondents, 4% selected that the quality has improved significantly, while 37% selected that it has improved somewhat, and 32% of respondents selected that the quality has stayed the same. While 4% of respondents stated that the quality is somewhat worse, 10% of respondents selected significantly worse, and 13% of respondents preferred not to say.

Finding #18: The current ORH program funding model and allocation cycles limit the ability of First Nations communities to build more housing units – predictable, sustainable and flexible funding is necessary to support more long-term and strategic planning.

Virtually all interview respondents indicated that the A-base funding or minor allocation funding is too limited in scale. Several respondents pointed out that A-base funding has not been increased in decades and that in their experience this funding limits the number of housing units that can be built. As a result, the ORH program has been relying on time-limited B-base funds through budget announcements over the years, which was seen to be a 'band-aid' solution that addresses the most urgent gaps but is not predictable and sustainable. Both First Nation and government respondents stated that this funding model is constraining and it does not allow for long-term planning.

The majority of respondents supported committed, long-term, flexible funding so that communities can plan strategically, including plans for how to acquire funds from a variety of revenue sources (such as rent and other own-source revenue) to finance housing and related infrastructures, and a healthy mix of tenures. Many interviewees suggested the funding be for twenty years or more to reflect the lifecycle of an infrastructure, otherwise it disincentivizes communities from developing strategic plans and realizing the maximum values for investments.

While being passed shortly beyond the evaluated period, it is important to note that the AFN Special Chiefs Assembly resolution 12/2021 was regarding support for closing the infrastructure gap by 2030, which urged the federal government to commit to sustained long-term funding over the next five to fifteen years. Resolution # 18/2022 re-affirmed the need for long-term predictable funding and for the government to "transition the insufficient housing and infrastructure investment commitment timeframes of 5 to 10 years to long-term commitments of 25 to 30 years or more to provide on-going, predictable, and sustainable funding."

Funding Allocation Cycles

When being asked whether the funding allocation is timely to address community needs, 21% agreed as compared to 45% who disagreed (see Figure 5.3). Several interviewees noted that funding can be ill-timed in relation to their construction season causing delayed or postponed projects. Infrastructure projects are dependent on building seasons, which could vary among communities depending on their location. For example, communities that are easily accessible or located in southern regions of the country would prefer to receive funding in early spring so they can begin projects immediately. Northern communities require funding mid-winter so they can move materials using the ice roads and are prepared to begin construction when the ground thaws. This could help explain the split of opinions of survey respondents.

ISC Evaluation Survey 2022 (Question: The following questions are about ISC funding for the On-reserve Housing program. To what extent would you agree with the following statements? Respondents n=93.)

Text alternative for Figure 5.3: Agreement with Funding for ORH Program

Figure 5.3 "Agreement with Funding for ORH Program" outlines the responses to the ISC Evaluation Survey 2022 question "The following questions are about ISC funding for the On-reserve Housing program. To what extent would you agree with the following statements?". The response options for this question are "Agree/strongly agree", "Neither Agree nor Disagree", "Disagree/Strongly Disagree", and "Don't Know".

For the statement "The funding requirements are clear", out of a total of 93 respondents, 57% agree/strongly agree, 18% neither agree nor disagree, 22% disagree/strongly disagree, and 3% selected "Don't Know".

For the statement "The funding is allocated in a timely manner", out of a total of 93 respondents, 21% agree/strongly agree, 26% neither agree nor disagree, 45% disagree/strongly disagree, and 2% selected "Don't Know".

For the statement "The funding approach is flexible enough to address community needs", out of a total of 93 respondents, 19% agree/strongly agree, 25% neither agree nor disagree, 55% disagree/strongly disagree, and 1% selected "Don't Know".

For the statement "The funding approval is enabling a whole-of-community approach", out of a total of 93 respondents, 18% agree/strongly agree, 36% neither agree nor disagree, 40% disagree/strongly disagree, and 7% selected "Don't Know".

For the statement "The funding is sufficient", out of a total of 93 respondents, 8% agree/strongly agree, 12% neither agree nor disagree, and 81% disagree/strongly disagree.

The current funding allocation aligned with the federal government's fiscal cycle, where annual funding approval and regional allocation take place towards end of March or early April, does not necessarily allow for optimal timelines for construction, and the impacts are most evident in remote communities. For other in-year approved projects, funding could arrive in the regions anytime during the year. ISC staff also indicated that for new Budget funds, funding could be allocated to regions later than March-April. Both internal and external interviewees noted that the timing of funding can be a challenge as funding could be allocated late in the construction season when communities receive their funds.

Related to the timing of funding are the timelines for spending the funds. First Nation respondents noted that they are in principle required to spend their funding within a given period, usually within the fiscal year in which funding is received. Although the Department is permitted to carry forward eligible lapsing funds to future years, the decision must be assessed on a case-by-case basis, which could limit First Nations ability to spend in a timely manner. Moreover, delayed receipt of funds impacts project timelines and therefore it cannot always be spent within the specified timelines. Communities must then request extensions to expand the timeline for spending the funds, which in turn can impact reporting timelines and can jeopardize future funding approvals if reporting is submitted late.

Finding #19: The current ORH program funding process through FNIIP is effective for identifying projects, but not for funding them; the prioritization criteria being used in the FNIIP process do not sufficiently consider public health and environment-related standards and considerations.

First Nation respondents were divided as to the effectiveness of the FNIIP.^{Footnote 34} Many indicated that the FNIIP was effective for identifying projects. Some First Nation respondents used the FNIIP five-year plan to guide their longer-term planning. One respondent noted that the five-year plan helped keep their community's housing planning on track; identify areas of housing that will require attention before they become bigger issues, and establish goals for future projects.

However, many First Nation respondents indicated that their FNIIP was ineffective in getting projects funded. They likened the FNIIP to a 'wish list'. Some expressed frustration with having projects remain on the list for years that may never be funded. One respondent noted that they use the FNIIP solely as a planning tool and do not expect that a project listed on the FNIIP will get funded. Moreover, some First Nation respondents indicated that the FNIIP, while useful for new projects, was not effective for planning upgrades or housing repairs. Program recipients also raised issues in relation to FNIIP prioritization criteria, justification and transparency around funding decisions. Some shared having to complete the FNIIP yearly but not receiving any explanation from ISC for the reasons why they did not get funding.

"First Nations do not really plan well beyond the first year because they don't have any indication that they will get funding the following year, so the best they can say is what I need next year without expecting it to be funded. That is the weakness of the FNIIP."

Access to EPHO services to support service standards can mitigate risks for housing, water, wastewater systems and public buildings. EPHO bridge infrastructure and health outcomes by promoting public health standards, and monitoring and preventing public health risks at all stages of infrastructure planning, design, construction and operation. As compared to EF or OCI, the importance of EPHOs to identify issues related to public health and other safety issues is more evident for the ORH program, given that housing units are not subject to Asset Condition Reporting System (ACRS) inspections, which identify asset deficiencies in relation to health and safety. In addition, consistent climate-informed infrastructure standards and mapping over 20 to 40 years are urgently needed, especially for remote communities where risks to health are more prominent as a result of climate change. These considerations are not systematically integrated in infrastructure planning for programs to remain relevant in responding to community needs and the changing environment.

Finding #20: While the formula-based funding requirements were mostly viewed as clear, the cost reference manuals and formulas cannot always keep pace with the dynamic costs of housing construction and maintenance; In terms of the proposal-based approach, a number of challenges were identified in accessing housing funds through the process.

The majority (57%) of survey respondents agreed that ORH program funding requirements were clear. Internally, ISC respondents viewed the processes and procedures for minor funding allocation as appropriate and the allocation of A-base funding from NCR to the region's objective using criteria of population, size, community needs, and the well-being index. While ISC uses updated Maximum Unit Prices to estimate costs in collaboration with the CMHC, many First Nation respondents noted that available funding does not reflect the current costs of construction and materials. Some respondents reported having to revise their housing designs and purchasing inferior materials to build houses within the funding received. Respondents in remote locations noted that costs to bring materials into the community have significantly increased further impacting their housing budgets.

While the majority of community respondents indicated that they understood the processes and procedures for A-base funding allocation, many expressed concerns in accessing proposal-based funding which requires complicated and time-consuming applications. Respondents indicated that the proposal-based approach is fundamentally inequitable as it creates a bias toward more organized, wealthier communities that can afford to pay consulting firms to develop proposals. Moreover, some First Nation reported that often the timeline to apply for funding was too short, making it more difficult for communities with limited capacity to access funding. Others stated that the notice of funding is sent only to their chief who may not forward it to those responsible for housing in a timely manner. These respondents stated that ISC should make greater efforts to invite other staff such as CEOs and housing managers into conversations about funding announcements to ensure notices are sent to those who will be preparing a response.

Many reported that funding for new projects can be withheld for incomplete reports or failure to submit reports on previous projects. This holding back of funds creates significant barriers for communities struggling with capacity issues. Often the person completing the report has little knowledge about the project or experience with completing such reports. If the report is deemed incomplete or requires further clarification, it may take months to resolve, further tying up resources. Some First Nation respondents noted that they were permitted to re-submit if their original proposal was not successful; however, they were given little feedback on how to improve their proposal and often were still unsuccessful. Some respondents suggested that it would be helpful if ISC provided workshops around preparing reports that will meet with ISC's satisfaction. The proposal-based funding allocation approach was also viewed as not reflecting the First Nation care and control principles by some as communities are dependent on how ISC staff review their proposals and prioritize the allocations.

Finding #21: The O&M amount received for housing is not sufficient in conducting necessary repairs and maintenance; The continuous lack of O&M funding reduces the maximum lifecycle for housing units on reserve.

First Nations communities can use A-base funds provided annually by the Department. A-base funding has remained static over the years, which means fewer maintenance dollars are available per housing unit. First Nation respondents indicate that the funding cannot cover their backlogs of repairs, especially major repairs. A lack of regular maintenance due to the backlogs, compounded by wear and tear from overcrowding, poorly built homes and worsened weather conditions, resulted in the lifespans of housing on-reserve far shorter than housing elsewhere in Canada. For example, some estimated housing on-reserve needed to be replaced every fifteen years or so. Further, due to limited infrastructure funding, some communities used O&M funds to build or renovate housing units, which further contributes to the lack of repairs.

The A-base support provided by the ORH program does not allow First Nation communities to properly maintain their housing units, leading to increased health and safety issues. Several interviewees noted that the ORH program is unable to achieve its expected outcomes of healthy and safe homes primarily due to budget constraints. Many interviewees shared that First Nations who have the capacity and are wealthier put money aside for O&M that allows them to do the maintenance and complete repairs, but those with less capacity, experience, and money use the totality of their funding to build new units or renovate those in need.

While a few First Nation respondents indicated that they have received emergency funding to help repair homes after events such as storms and floods, it is one-time funding that does not address the ongoing wear. In addition to lack of funding, training and capacity development in operation and maintenance were indicated as a gap by many interviewees.

Finding #22: ORH program funding allocations varied across regions; the flexibility helped increase the effectiveness of service delivery.

The effectiveness of the ORH program funding varied among First Nation communities given the flexibility across the regions in their approaches to allocating funding and the extent to which communities were successful in their bids for proposal-based funds. While ISC staff indicated there was no universal method used by the regions for allocating annual funding, many agreed that having some regional flexibility increased the effectiveness of service delivery.

Some regions do not use proposal-based funding allocation:

• Yukon and Alberta regions asked for applications^{Footnote 35} that were reviewed using regionally developed priority frameworks and ISC experts to determine priorities and allocations.
• In the Atlantic region, all First Nations were asked to produce a housing plan to be eligible to receive funding; however, the allocation of funding was based not on the plan but rather on a formula considering population size and remoteness level.
• Saskatchewan did not use requests for proposals, reasoning that every community needed the funding. They tried unsuccessfully to come up with the "perfect formula." After consulting with First Nations in the region, and failing to reach a consensus, regional staff used population size and remoteness to allocate funding.
• Likewise, British Columbia did not request proposals either because of the large number of small communities in that region. Regional staff noted that asking for a proposal would add costs to the process, which would be unfair to these small nations. As the expected amounts to be received were small, the allocation was based on a population formula.

A few regions have used a proposal-based approach with varying degrees of success:

• Ontario used a proposal-based approach in 2016 but dropped that approach in 2018.
• Manitoba has been combining I-base funding with the targeted proposal-based funding using a proposal-based approach. However, for the next budget iteration, this region is considering splitting the total amount (A-Base and proposal-based targeted funding) in two with the first half distributed equally among their 63 nations and the other half divided up using a population-based formula.
• The Quebec region released a call for proposals under five themes for the targeted investments. This region employed a tripartite committee made up of ISC and CMHC employees and the local AFN to decide the priorities and allocations. The committee prefers "strategic" investments such as lots servicing and capacity building initiatives over "shorter-term wins" such as new constructions and renovations.

Finding #23: In reporting on the achievement of the program, performance data is mostly at the output level; Alternative performance measurement approaches were proposed to measure the success of the infrastructure investment on reserve more effectively by integrating a wellbeing or human rights centred lens.

Currently, the ORH program reports on results using data such as number of housing units built and amount of funds spent. While these data are useful in demonstrating the scale of investments and implementation efforts, they are not fully corresponding to what communities and partners view as the most appropriate way of measuring success in relation to housing outcomes and closing the infrastructure gaps on-reserve. Moreover, by reporting on the numbers of units built at the output level does not demonstrate to what extent the program has achieved its outcome by providing reliable and sustainable housing to First Nations communities, given the early deterioration of housing on-reserve.

During the evaluated period, the Performance Information Profile for housing on-reserve had not been updated since 2018 and there were no defined indicators for all immediate outcomes, i.e. ISC has the information it needs to make strategic decisions and First Nation communities have the information they need to allocate resources to manage their ISC-funded housing within established health and safety standards; and First Nation communities are supported in managing their housing. For the Performance Information Profile indicators that were being tracked, not all years were available.

A few ISC respondents noted that improved data collection of existing metrics would result in a clearer picture of the effectiveness of the ORH program. Interviewees from the Quebec region across all categories of interviewees suggested that ISC's focus on outputs such as units built or renovated constitutes a disincentive for communities to invest money into long-term planning and capacity enhancement. Several respondents suggested that other "forward-looking" metrics should be collected such as structural changes including capacity, subdivision and lots serviced, a cultural shift towards private ownership, and community long-term housing plans.

Canada's Federal Housing Advocate, Marie-Josée Houle, suggested during the 2022 First Nations Housing Forum to go beyond the numbers of units built and apply a human-rights-centered approach, which values participation, non-discrimination, equity, transparency, empowerment and respect for human rights and obligations. Similarly, the IFSD has proposed implementing a wellbeing-centered housing and infrastructure performance measurement framework by assessing service level performance. According to the IFSD, applying the well-being lens to infrastructure helps transform the First Nations infrastructure investment narrative from focusing on fixing legacy issues to a holistic system-wide approach on-reserve.

Finding #24: Despite the existence of a number of systems (such as the ICMS and the Grants Contributions and Information Management System) to track projects, housing units, conditions and financials, data availability and reliability remain as issues.

ISC respondents consistently commented on the lack of housing data and up-to-date housing performance measures. The housing cost reference manual and funding formulas use data from the ICMS to determine A-base funding allocations. More accurate ICMS data could help the program to better assess and update the A-base funding formula. With these in place, the program would offer allocations better reflecting the current cost of housing construction and repairs.

Data availability and sufficiency were identified as an issue by both internal and external respondents. Many (government and First Nation) noted that the current extent of infrastructure gaps was unknown or under reported due in part to lack of available data on the condition and needs of First Nations infrastructure. Some indicated that the ICMS does not capture sufficient data on infrastructure projects.

Consistency was raised as a concern in relation to data entry into the ICMS and interpretation of the various fields in the ICMS among users. As projects are self-reported by First Nations, regions must enter the data they receive from First Nations into the ICMS. While regional officers make every effort to ensure accuracy when entering project information into the ICMS, their interpretations of certain fields and requirements may vary, as there is not a set of specified definitions associated with these fields. This created inconsistency in data entered not just among regions but also users in the same region, which resulted in discrepancy on project data and unreliability in reporting. Moreover, regional practices vary on what to enter into the ICMS, with some entering only funded projects into the ICMS, others entering all project proposals. Further, during the evaluated period, limitations existed on verifying the accuracy of the data entered into the ICMS. While data review takes place at the national level on a quarterly basis, data entry and verification mostly took place at the regional level. Finally, regions indicated the challenge of obtaining data from First Nations in the first place, which could be delayed by one to three years in some regions and the received data could be missing or incomplete.

During the evaluation data collection, the evaluators learned that some features were not available in the ICMS for tracking projects to certain causes. For example, impacts of projects in strengthening resilience to the effects of climate change could not be measured due to a lack of tagging ability for projects. Also, ISC staff noted the extent to which A-base funding contributes to the achievement of intended program outcomes could not be sufficiently measured as there was no performance information related to A-base funding. There was also deficiency in linking the financial system and the ICMS, the example of which was provided under section 3.3 Challenges and Limitations of this report.

First Nation respondents expressed their desire that ISC should streamline their reporting processes. For example, using an online system whereby new data can be entered or updated and feed into the reports would help ease the reporting burden for First Nations.

Finding #25: The ORH program provided increased employment and training opportunities as well as social and economic impacts within the community, and the housing units built increased community pride.

Both interviewees and survey respondents acknowledged additional benefits to the communities as a result of the ORH program. Overall, survey respondents were more likely to agree than disagree that the ORH program positively impacted most social and economic aspects of their community (Figure 5.4).

ISC Evaluation Survey 2022 (Question: To what extent do you agree with the following statements? Respondents n=93.)

Text alternative for Figure 5.4: Agreement with Social and Economic Impacts of On-Reserve Housing Program on Community

Figure 5.4 "Agreement with Social and Economic Impacts of On-Reserve Housing Program on Community" outlines the responses to the ISC Evaluation Survey 2022 question "To what extent do you agree with the following statements?". The response options for this question are "Agree/strongly agree", "Neither Agree nor Disagree", "Disagree/Strongly Disagree", and "Don't Know".

For the statement "Contributes to the wellbeing of my community", out of a total of 93 respondents, 41% agree/strongly agree, 36% neither agree nor disagree, 21% disagree/strongly disagree, and 3% selected "Don't Know".

For the statement "Increased my community's capacity to manage housing projects and program", out of a total of 93 respondents, 41% agree/strongly agree, 24% neither agree nor disagree, 30% disagree/strongly disagree, and 5% selected "Don't Know".

For the statement "Contributes to economic development of my community", out of a total of 93 respondents", 40% agree/strongly agree, 23% neither agree nor disagree, 33% disagree/strongly disagree, and 4% selected "Don't Know".

For the statement "Improves children's health and wellbeing in my community", out of a total of 93 respondents, 40% agree/strongly agree, 37% neither agree nor disagree, 20% disagree/strongly disagree, and 3% selected "Don't Know".

For the statement "Allowed opportunities for my community to provide input on how the program is delivered", out of a total of 93 respondents, 30% agree/strongly agree, 30% neither agree nor disagree, 33% disagree/strongly disagree, and 7% selected "Don't Know".

The most frequently mentioned positive unintended impact of the ORH program was the employment opportunities created for community members. Many respondents indicated that construction and maintenance projects funded by the program helped to support construction workers and licensed tradespeople living on reserve. Larger communities noted that they have on reserve construction firms that serve as general managers to oversee their housing projects and use local workers, which in turn retains more of the economic impact within the community. Some First Nation respondents noted that the funding also helped to provide training to housing staff who were members of the community, thus increasing their skills, knowledge, and capacity. One respondent noted that having such employment opportunities improves the quality of life for their community members.

Another positive outcome is the increased pride community members have when new construction and upgrades are done in their community. One respondent noted that members of their community are excited to see new construction and become more engaged as witnessed by an increased number of band members submitting applications for housing and wanting to become homeowners. Another respondent noted a growth in community spirit as a result of new construction. They also observed that children who attend school and share sports activities with non-Indigenous children were now more likely to want to have their off-reserve friends come to visit their homes.

Finding #26: Other unintended outcomes included impact on the quality of the housing units built as a result of short-term investments, additional costs for projects as a result of COVID-19 and innovative practices in the communities.

A few ISC respondents indicated that the rush to build provoked by short-term investments may have negatively impacted the quality of the units built. A CMHC respondent suggested that sudden, large influxes of funding at once put lots of pressure on First Nations to build quicker and cheaper, which meant that these units would most likely need repairs sooner. Also, as a result of COVID-19, many projects were delayed ("some projects were abandoned right then and there" said one informant) and required additional costs to complete.

Some First Nation respondents indicated that the lack of sufficient funding forced them to develop alternative solutions to their housing needs. These innovations included educating community members on home maintenance, providing loan programs for members to become homeowners, seeking community input on housing solutions, and getting leadership support for long-term planning.

Finding #27: While there is collaboration with the CMHC, the ORH program is mostly delivered without integration with other government programs or initiatives addressing housing on-reserve, which created inefficiencies.

Under ISC's ORH program and CMHC's housing program, communities have the ability to stack funding or to coordinate funding from one program in advance of receiving funding to complete a housing project (e.g., funding for lot servicing before funding to build houses). This feature was viewed as beneficial in seeing more funding for housing on-reserve. However, a number of government and First Nation interviewees indicated that it required additional efforts to coordinate these stacking activities.

Respondents suggested that efficiencies could be gained among the various infrastructure programs, for example, by coordinating funding approval for developing the infrastructure required to service lots with funding for the construction of houses on these lots. Many stated there should be better planning and communication between federal departments. A few ISC and government respondents promoted a federal "one-window approach" for grants and contribution funding through which First Nations could apply. A few First Nation respondents have called for a First Nations housing agency to facilitate the planning and coordination of housing and infrastructure related funding among ISC initiatives and other federal departments.

In delivering the housing programs, there's some alignment between ISC, CMHC and provincial housing agencies although regional practices vary. For example, one respondent pointed to the tripartite committee in Quebec that consists of representatives from ISC, the CMHC, and AFN-QL to address housing issues; however, in some regions, there was hesitation in involving other provincial housing agencies due to concerns of being excluded from funding opportunities if communities did not support these organizations.

First Nation respondents from Ontario, and B.C. reported accessing funding through provincial programs; however, they noted that these programs were also siloed and not well aligned with the federal ORH program. The experience seems to vary much from one province to another, with some provinces willing to cooperate and others not at all, even in cases where a certain issue should theoretically be their responsibility. It appears that there is a tendency for provincial governments to consider anything that has to do with First Nations as under ISC jurisdiction.

A total of 36% of survey respondents disagreed that the ORH program delivery is coordinated with other federal or provincial programs that support housing on-reserve (versus 28% that agreed) (Figure 6.1).

ISC Evaluation Survey 2022 (Question: To what extent would you agree that Indigenous Services Canada's On-reserve Housing program delivery is coordinated with other federal or provincial programs that support housing on-reserve? The Total may not add to 100% due to rounding. Respondents n=93.)

Text alternative for Figure 6.1: Agreement with Extent On-Reserve Housing Program is Coordinated with Other Federal or Provincial Programs that Support Housing

Figure 6.1 "Agreement with Extent On-Reserve Housing Program is Coordinated with Other Federal or Provincial Programs that Support Housing" outlines the responses to the ISC Evaluation Survey 2022 question "To what extent would you agree that Indigenous Services Canada's On-reserve Housing program delivery is coordinated with other federal or provincial programs that support housing on-reserve?". Out of a total of 93 respondents, 28% strongly agree/agree, 33% neither agree nor disagree, 36% disagree/strongly disagree, and 3% prefer not to say.

Reasons for disagreement included: no comprehensive programs to address housing issues; no provincial programs to be accessed; and lack of communication between and within governments. Reasons for agreement included noting that combined efforts with all levels of government is necessary, the ability to include green energy initiatives when creating housing plans, and the ability to coordinate funding with CMHC.

Finding #28: The asset-focused and project-based approach in delivering the ORH program without systemic integration with other asset areas under the CFMP has not only resulted in more administrative burdens on First Nations but also lost opportunities to better support them in addressing the needs and priorities identified by their communities from a whole-of-community lens.

Currently, the planning and approval of housing projects do not take into consideration infrastructure investments in other sub-assets under the CFMP, in particular Other Community Infrastructure, Water and Wastewater, and education facilities. This has resulted in instances where housing was built without proper enabling features funded under the OCI, e.g. connecting roads, sidewalks, electricity, in which case the housing units could not be used immediately in a safe and effective manner. The administrative burdens are on First Nations to request for funding for projects under various sub-assets which were not guaranteed to be approved at the same time.

Many interviewees (First Nation and government) agreed that infrastructure siloes should be broken down to support logical and holistic community infrastructure planning. Such an approach would lead to better outcomes for all community infrastructure programs and realize greater cost efficiencies in the long term. A universal sentiment expressed was that all community infrastructure assets are interrelated. For example, off-site infrastructure (such as lighting, roads and sidewalks, energy systems) is needed to support housing.

Although the relationship between housing and outcomes such as health, education, and employment are well known, it has not been demonstrated for the program. Several First Nation respondents spoke of the challenges of separating social issues from housing issues and noted that more needs to be done to find integrated solutions to address these issues as a system. A few respondents both from ISC and Indigenous organizations discussed the need to consider housing in a more holistic manner in terms of its connections to other infrastructures, and health, education, social services, and economic development.

Finding #29: Cost-efficiencies in the ORH program were not fully achieved due to accelerated housing deterioration as a result of the use of lesser quality materials and insufficient repair, as project approval decisions tend to opt for the lower-costs options rather than based on long-term asset management planning.

Asset management is tied to long-term capital planning as it considers lifecycle maintenance costs and timelines. Asset management was raised by many respondents as crucial in assessing the condition of housing, estimating costs for repairs and upgrades, and accommodating community growth to facilitate planning to extend the lifespan and value of housing units. Many respondents noted that the lack of asset management planning, in particular in relation to maintenance and repair costs, has prevented housing units from reaching their expected lifespans due to early deterioration, which in turn makes the delivery of housing in First Nation communities less efficient.

Moreover, due to budget limitations, the communities opted to use lesser quality materials that do not withstand the effects of local climate and the increasing effects of climate change, which has further reduced the efficiency of housing funding as homes experience accelerated deterioration. Many First Nation respondents indicated that making their housing programs cost-effective required long-term housing plans. Such planning included a needs assessment and up-to-date data on the condition of their housing inventory (i.e., asset management). This planning allowed communities to build in efficiencies and to develop a proactive approach to housing management as opposed to managing crisis situations.

Some First Nation respondents commented that while they try to find less expensive materials and cheaper energy sources for construction (e.g. oil-fired furnaces), these workarounds often result in added costs for maintenance and repairs. Other First Nation respondents pointed that the funding they received does not cover the actual costs to build the homes, which means that communities may opt to build less expensive housing that is often unsuitable for the environment.

One example of the lower-cost option was the use of prefabricated homes. A few ISC respondents indicated the use of prefabricated homes as being inefficient, as although First Nation communities can get their homes faster, prefabricated homes may not withstand harsh climates thus leading to rapid deterioration, more repairs, and the need to rebuild sooner. The use of prefabricated homes also does not support the training and retention of local First Nation youths and other community members within First Nation communities.

Finding #30: There is a lack of a cohesive approach towards capacity building for housing management and asset management, which inhibits the efficiency in delivering housing outcomes. Investment towards staff capacity building on housing management and asset management was seen as an efficient use of housing funds.

Many First Nation respondents cited the lack of trained staff as the main reason inhibiting the reform of their housing programs and in turn making their programs less efficient or cost-effective. They noted that the lack of tenant relation officers, repair crews, housing managers, and support staff to help administer housing meant they were less focused on efficiency as they were struggling to manage housing. Many communities relied on costly external consultants for support in preparing proposals, reports, and needs assessments, and in hiring inspectors to ensure buildings met construction standards.

According to representatives from the FNHPA, communities employing trained housing managers with the capacity in applying asset management principles realized more efficiency in delivery their housing program. Continued focus on developing the capacity for housing management was suggested as an efficient use of housing funds.

Interviewees from both the FNHPA and ISC regional offices raised concerns in relation to the lack of a cohesive approach towards capacity building for housing management. While some regions such as Atlantic, Quebec, and Ontario have increased their capacity for managing housing, Western Canada is experiencing a higher turnover of housing managers and behind on housing capacity development. They suggested that a focus on training cohorts of housing professionals recognized for their skills and experience would be an efficient use of funding. They also noted that ensuring these professionals are well-paid would help ensure they remain in First Nation communities and not seek higher-paying positions in other communities.

Respondents associated with tribal councils and housing technical organizations acknowledged an increase in support programs and services designed to develop community capacity to manage housing; however, they indicated that more could be done to help train housing managers within their communities. Some noted that while funding may be available to provide skills training and capacity building, not all can take advantage of these opportunities given their workloads that limit their ability to attend training, especially, to attend training for which they would need to travel. A few respondents suggested that a program similar to the Circuit Rider Training Program implemented in the Water and Wastewater Program that provides community-located training for operating, monitoring, and maintaining drinking water and wastewater systems be developed to train housing managers and staff.

Finding #31: Some cost savings have been realized through bulk purchasing and contracting multiple builds with the same contractor by the communities.

Several First Nation respondents indicated that they have found cost savings through the bulk purchase of materials and using the same consultant/contractor for multiple projects to negotiate better rates. Some found savings in contracting jobs to local workers instead of having these workers on the band's payroll. Some First Nations indicated they have partnered with organizations such as Habitat for Humanity to reduce costs. However, some ISC respondents cautioned that practices such as using the same contractor for several housing projects either within the same community or among several communities could have undesirable effects in that some professional firms could take advantage of this and end up charging more for their services than if they had been selected through a Request for Proposals.

Finding #32: High turnover of staff, both ISC staff and First Nation communities, results in inefficiencies due to loss of capacity and additional efforts by First Nations.

First Nation community and organization respondents observed that the high turnover of both First Nations and ISC staff has hindered their ability to deliver their housing programs. The high turnover of First Nation staff means that communities must invest additional effort and funding to train new staff, which results in less efficient management of housing as there are fewer staff to respond to the housing demands of their community. ISC staff turnover impacts First Nation communities as knowledge and lessons learns are not always transferred to new staff. Several First Nation respondents indicated that the time spent developing relationships with ISC staff and helping them to understand their community's housing situation and unique needs is lost when the ISC staff leave, and they must begin anew with other ISC staff.

The high turn-over of ISC staff in infrastructure programs was raised by many First Nations respondents (including partners and communities), which was viewed as an inefficient management practice of infrastructure programs as there was no sufficient knowledge transfer following the departure of staff. Based on an assessment of the staffing numbers across the three programs (including both NRC and Regions)^{Footnote 36}, the data reviews that there has been a total of 829 counts of turnovers, including both new hires and departures from 2016-17 to 2020-21 (Table 6.1).

Finding #33: Some noted that the program was cost-effective as many First Nations identified housing costs borne by their communities that could be considered by ISC to include in the ORH program.

While being covered under the ORH program, due to funding limitations, some communities have to prioritize over some projects that are directly tied to building and maintaining housing, such as the costs to service the lots or to demolish existing housing. As a result, First Nations communities need to seek additional funding elsewhere or share those costs in order to access the ORH program funding, which means the communities without the financial resources are often unable to effectively leverage the funding.

While First Nations communities are expected to secure funding from other sources for their housing needs including shelter charges and private-sector loans under the ORH program, 61% of survey respondents provided examples of housing related costs borne by their community that were not covered or sufficiently covered by the ORH program, including:

• Development of funding proposals;
• Hiring of architects and engineers;
• Purchase of suitable lands;
• Covering increases in construction costs and supplies;
• Paying staff wages and inspections; and
• Retrofits to units to support seniors and individuals with special needs.

First Nation respondents agreed that preparing proposals for funding was a complicated and time-consuming process, often requiring months to prepare and with costs incurred that are not reimbursed if the proposal is unsuccessful. While some respondents indicated they had the capacity in-house to develop strong proposals, many relied on external consultants, tribal councils, or other service organizations to help them complete proposals.

Some First Nation respondents noted that they receive their funding in installments and often must pay for things upfront that will be later reimbursed; however, this creates a strain for communities that do not have own-source funding. One respondent indicated that they look to their social or health departments for funds to retrofit homes or make repairs.