15.1.16.030 Findings

The San Ildefonso Council hereby finds that,

(a) San Ildefonso Housing Authority ("SIHA") is the Tribally Designated Housing Entity ("TDHE") authorized to develop, rehabilitate and manage affordable housing activities for San Ildefonso and to participate in the design and implementation of comprehensive community and housing development activities.

(b) The Pueblo and SIHA has determined that the lack of new sustainable homes impedes ICDBG eligible family's ability to remain living on the reservation and risks the health, safety and well-being of San Ildefonso Tribal members and therefore threatens the viability of the Pueblo.

(c) Eligible Tribal Organizations are permitted to submit applications under the Community Development Block Grant for Indian Tribes and Alaska Villages regulation 24 CFR 1003.5(b).

(d) SIHA is recognized by the Bureau of Indian Affairs as an eligible Tribal Organization as defined in Title I of the Indian Self Determination Education and Assistance Act, and as a Tribal Organization, the Pueblo Housing Authority is also therefore an eligible recipient under that Act.

(e) SIHA is recognized by the Bureau of Indian Affairs as an eligible Tribal Organization as defined in Title I of the Indian Self Determination Education and Assistance Act, and as a Tribal Organization, the Pueblo Housing Authority is also therefore an eligible recipient under that Act.

(f) Only Community Based Development Organizations ("CBDO") may apply for ICDBG funding for New Construction and HUD has confirmed SIHA meets the definition of a CBDO under 24 C.F.R. 1003.204.

(g) The Pueblo must meet certain threshold requirements in order to be deemed eligible for ICDBG funding whether the application is made directly by the Pueblo or on the Pueblo's behalf by an eligible tribal organization and the Pueblo intends to fully comply with the threshold requirements and of the 2024 ICDBG application process, including the citizen participation requirements.

(h) The Pueblo, through activities carried by SIHA, sought and considered community input and posted the Citizen Participation Statement, Budget and Schedule for the Homeownership Assistance Project in advance of the 2024 Indian Community Development Block Grant Application in compliance with the Notice of Funding Availability governing the contents of the application for 2024 ICDBG funding expressed at 24 C.F.R. § 1003.604(a), and has considered comments received in preparing the application

(i) SIHA has adopted a code of ethics policy and, in coordination with the Pueblo, prepared and disclosed to the public a statement of conflict of interests, specifically that no conflict of interest exists within the qualified applicants for the Homeownership Assistance project nor the criteria for the selection of the proposed beneficiaries.

(j) SIHA has adopted the Fiscal Management and Procurement and Contract Management policies that meets 2 CFR 200 requirements.