(c) Housing Assistance Council, 1998

ISBN 1-58064-084-2

Permission is granted ONLY to nonprofit community-based organizations to reproduce and/or adapt this document, and only for their own use.

IV. INFRASTRUCTURE DEVELOPMENT AND PROVISION: TIERRA DEL SOL'S ANTHONY PROJECT

Tierra Del Sol (TDS) is a private, nonprofit community-based organization located in Las Cruces, New Mexico. TDS was organized by volunteers, an interfaith reverend, a county commissioner, a group of farmworkers and rural families approximately 20 years ago. The purpose of the corporation is to provide a community housing delivery system to help low-income families. Housing assistance is provided through technical assistance, training, and the development of safe, sanitary, and affordable homes for persons of very low to moderate income. In addition, TDS has become an instrument of change for many low-income communities through its advocacy and community organizing activities.

In all, TDS has successfully developed over 700 single-family housing units by the self-help method. The corporation has also undertaken significant housing rehabilitation over the years. Current activity involves the rehabilitation of 300 single-family housing units in five New Mexico local government jurisdictions. TDS has also sponsored and developed over 470 multifamily housing units in several scattered locations in New Mexico and Texas.

TDS began work in the colonia community of Anthony, New Mexico in 1984. In order to proceed with housing development for colonia residents, TDS realized that they first needed to tackle the lack of infrastructure within the community. Without water and sewer services, TDS would not be able to access the rural housing programs operated by the Farmers Home Administration (now known as Rural Development). Consequently, TDS began by assisting in the formation of a Water and Sanitation District, and initiating the development of community water and sewer facilities. This involved extensive community organizing efforts. Simultaneously, TDS undertook the rehabilitation of housing units throughout the community. As the Anthony Water and Sanitation District formed and expanded, TDS ensured that it included the capacity to serve TDS's future housing developments. TDS then proceeded to develop multifamily housing units, farmworker housing, and single-family ownership housing through the self-help method. In all, TDS has provided approximately 400 units of decent, affordable housing in Anthony. This has been achieved by putting together a variety of financing sources, developing strong relationships and partnerships with a network of service providers, public and private entities, and building both the physical and political infrastructure within the community of Anthony.

General Overview of Doña Ana County and the Anthony Colonia

The community of Anthony is located in Doña Ana County in the state of New Mexico [see Figure 2a]. In order to provide a context for the problems faced by the residents of Anthony, it is necessary to provide some background on the county in general. Doña Ana County, one of the poorest and fastest growing counties in New Mexico, shares its border with Chihuahua, Mexico and El Paso, Texas and has a current population of 144,800. It is located less than 15 miles away from Juarez -- a city of a million and a half in Mexico. Doña Ana is the ninth poorest county in New Mexico and the fifth poorest metropolitan statistical area in the nation. About 22 percent of the county's population lives in colonias.

Most Doña Ana County colonias originated when subdividers began creating unimproved subdivisions within the county by taking advantage of the numerous loopholes in New Mexico's antiquated Subdivision Act. Based on this Act, a parcel of land could be legally divided into four parts.¹⁷  Each of these four lots could then be divided another four times. Subdividers have used this four-lot-split provision in numerous instances, which have resulted in large tracts of land being divided into as many as 200 residential lots which are created without adequate roads, drainage or other infrastructure improvements. The County Planning Department reports that these plots are then sold on unrecorded real estate contracts to low-income people at low monthly payments ($100-300) and high interest rates (up to 18 percent). As with most other colonias, Doña Ana colonias are characterized by dirt roads without drainage control structures, which become flooded and impassable when it rains. Entire colonias are often located in flood plains, leading to saturation of septic tanks, cesspools and the surrounding soil. This results directly in the spread of communicable diseases and in contamination of groundwater. In addition to being a nuisance and health hazard to the residents, this creates a public safety hazard owing to impeded access for fire trucks and ambulances. School buses too have access problems, forcing children to walk large distances in the mud in order to catch the bus to school. Dirt from unpaved roads and illegal trash burning contributes to air pollution in colonia areas. While 75 percent of Doña Ana county's colonias have water supply, fewer than 20 percent of colonia residents are connected to wastewater facilities. The vast majority of households use illegal cess pools and septic tanks or dispose effluent directly into open trenches, causing groundwater contamination as groundwater is quite shallow throughout most of the county. Within the colonias that have water systems, many problems exist with the adequacy of the systems and many need significant upgrading to bring them up to standard. In colonias without water systems, residents typically use wells that present a potential contamination hazard. In some cases, residents use outside spigots to access water, as houses often do not have indoor plumbing. Contamination of public water systems is a frequent occurrence due to overburdened systems and obsolescence.

The demand for low priced housing in colonia areas of Doña Ana County far outweighs the supply. High land costs in Juarez and land use controls in El Paso force many residents to buy land in New Mexico. It should be noted that land is at least four times cheaper in the U.S. than in Juarez. A University of New Mexico study found that an acre of low cost land in Juarez costs between $43,000 and $83,000 without infrastructure. In Doña Ana County, an acre in colonia areas costs between $6,000 and $12,000. Mobile homes and trailers are the most common type of housing found in the colonias.¹⁸   They are often extremely run down, and do not meet any standards. Housing is also constructed out of scrap cardboard stuccoed with mud. It is also not uncommon to find people living in abandoned buses, tar paper shacks or combinations thereof. The majority of colonia residents use Mexican butane tanks for heating and cooking. Butane tanks are purchased in Mexico, just across the border, and are very dangerous due to the lack of regulators and the use of plastic tubing for connection. Owing to a traditionally large family size, and the existing housing being too small, overcrowding is common. None of the statistics reported about substandard living conditions in the colonias adequately portrays the dismal reality of ramshackle trailers dotting dusty expanses of undeveloped land in the shadow of the Cristo Rey mountains on both sides of the border.

The community of Anthony is a small rural unincorporated area, located right on the Texas-New Mexico border. It adjoins the incorporated city of Anthony, Texas. In Anthony, New Mexico, 85 percent of the population is Hispanic, and over 75 percent is low-income. This means on average families earn about $9,000 annually. The community of Anthony developed in the 1880s around the railroad. Most of the community was platted by the 1950s. All subsequent growth has occurred in the platted subdivision, with individuals purchasing lots and locating mobile homes on them. In this respect, Anthony has differed from the traditional "contract for deed" colonia developments. However, according to TDS staff, Anthony has always suffered from substandard housing, inadequate infrastructure, unpaved roads, and other problems that characterize all colonia communities. The State of New Mexico eventually designated Anthony as a colonia in 1989, making it eligible to receive federal and state colonia funds. Most of the colonia growth has occurred on the New Mexico side.

When TDS began work in Anthony the population totaled only 2,000 to 3,000. Most of these residents had no access to water or sewer services. Residents were also politically unorganized and disenfranchised. The current population of Anthony exceeds 5,000, based on data reported by the New Mexico Environment Department. Anthony now houses a large food processing facility and a federal penitentiary, in addition to a few other businesses. Residents are employed by these and other agricultural related concerns located nearby. Some even commute to the cities of Las Cruces, New Mexico and El Paso, Texas, since Anthony is located approximately midway between these two major cities. A significant proportion of farmworkers also reside in Anthony. Local experts report that historically this community has resisted efforts at incorporation. The weak tax base prevalent in the area has been viewed as incapable of supporting local government. In addition, any movement by local activists to incorporate Anthony has faced strong opposition from local farmers. Reasons for this opposition range from a traditional distrust of municipal government to an unwillingness to be assessed greater taxes on farmland owned. Today Anthony is one of the fastest growing areas of the county.

Approximately 20 years ago, when TDS began working in Anthony, the community was a typical colonia without any water or sewer infrastructure. TDS formed a network with a group of committed local activists and set about acquiring infrastructure services for Anthony. Just across the border, the city of Anthony, Texas had a well functioning sewer system in place with excess capacity. With help from the Doña Ana County government, the group of local activists managed to negotiate an agreement with Anthony, Texas to share their system and use their excess capacity effectively. With critical support from the Department of Housing and Urban Development, the colonia of Anthony utilized Community Development Block Grant (CDBG) funds to build infrastructure for the core community and hooked it up with the system operated by Anthony, Texas. This was strictly a wastewater operation.¹⁹ This was an ideal arrangement for both sides. Anthony, New Mexico got its infrastructure, and Anthony, Texas gained revenues by effectively using its excess capacity. Unfortunately, owing to the prevalence of larger water-related political conflicts between El Paso, Texas and the state of New Mexico, this arrangement did not survive for very long and an alternative had to be found. This situation was what ultimately led to the creation of the Anthony Water and Sanitation District, the details of which are explained later.

Simultaneously, in the early 1970s, the community of Anthony also began to notice the effects of entrenched water pollution in the area. Numerous dairy farms located at a higher gradient than Anthony caused the leaching of large quantities of nitrates into the groundwater supply, causing numerous chronic health problems among residents, especially children. With the passage of the Clean Water Act and the federal buy-out of dairies for stabilizing milk prices, some control was established on continued contamination of groundwater. At this time, most of the community depended on wells for their water needs. However, since Anthony is located at a distance from the river valley, accumulated solids in well water continued to be a serious problem. Something needed to be done.

TDS and the group of local activists came together and formed a nonprofit water association. The association lobbied the state to pass legislation authorizing the creation of an independent infrastructure system for the community of Anthony. The local activists had crucial support from the county government in this venture. Together, this network of the water association, the county and the local community formed the Anthony Water and Sanitation District. This was a bold move, as not many such districts existed in the state at that time. The District started by formulating its boundaries. This was not an easy task owing to resistance by farm owners and the weak local tax base. They succeeded despite the odds, after agreeing to exclude farmland. In fact, at the time this research was conducted, farmland adjoining Anthony was still not included within the Water and Sanitation District. The District then worked with the county to acquire $250-300,000 in HUD CDBG funds and designed a wastewater system for Anthony. Special state appropriations and other federal funds from the National Demonstration Water Project supplemented the CDBG funds. Securing state support was a major achievement, since historically the state government focused on the northern part of New Mexico. The core community, comprising of that portion of the colonia that initially organized to create the Water and Sanitation district, was designated as the immediate growth area and was to be served first. The rest of the community was to be served in phases, using five and ten year growth projections.

Under state statute, a special Water and Sanitation District has many powers. It has bonding capacity and can levy taxes. It has the right of eminent domain and can condemn properties as well as designate easements and rights of way. It can establish boundaries, and has the power to expand as well as to provide services to its residents. In addition to water and sewer services, the District can participate in funding other public services such as parks, recreation, streets, and street lighting. In fact, the Water and Sanitation District serves as a transition between an unorganized, unincorporated area and a functioning incorporated city.

Once formed, Anthony's District managed to leverage funding from a variety of federal and state sources. With help from grants and loans from HUD CDBG, EPA, Rural Development (formerly Rural Economic and Community Development), EDA and state monies, the District was able to bring in an investment of approximately $10.6 million to Anthony for infrastructure development. This took tireless efforts over an extended period of time. For the first 10 years, after its inception in 1977, the District was able to provide service to the core community alone. After solidifying this service, the District proceeded to build the first phase of a treatment plant, providing an additional 150 connections. A private water system continued to serve part of the community. The District was finally able to buy out the private provider in 1993 and extend service to the rest of the community. Today, the District provides over 1,500 sewer connections and 2,200 water hookups, serving nearly all of the community. Nearly 75 percent of the community served was provided with grant funds through the state to hook up to the system. The District has also created a number of programs to assist families with water and sewer hookups. For instance, the District uses a network of Community Action Agencies to deliver the hook-up funds to the families. When combined with self-help labor for digging trenches, each hook-up costs only $200, enabling the District to stretch its dollars to serve the maximum number of families.

During the course of establishing infrastructure for the community of Anthony, HUD mandated a set aside of CDBG funds for the colonias in 1991. The District hoped to use these funds to expand its infrastructure system. According to local experts interviewed, the state opposed this set-aside provision vehemently. Federal regulations required an assessment of the local population in order to establish the numbers of low-income residents. The District would then be required to provide matching funds to pay for service to residents who were not low-income. Local activists claim that the state seized upon this regulation and interpreted it in a harsher way that the federal agency intended. The state wanted a detailed survey conducted. This would have cost the District over $15,000 -- which it could not afford. TDS staff report that they stepped in and helped the District bring this to the attention of HUD's national office. HUD subsequently dropped both the survey requirement and the requisite matching funds. In this instance, HUD was more responsive to local needs than the state of New Mexico, according to local activists.

Unfortunately, since this initial use of the colonias set-aside, there has been limited success in utilizing these funds in Doña Ana County. County residents interviewed insist that the state has tended to scatter the funds available based on political considerations. They also concur that the state government has historically favored the northern part of the state over the south. The dollars provided to Doña Ana County have been inadequate to fund projects in their entirety, and the county has found it necessary to leverage funds from other sources, causing delays in implementation. Owing to the complexities of executing colonia projects, and the resulting delays, the county has been unable to meet its annual threshold of projects as of 1995 as required by HUD. Once this threshold is not met, the county cannot access further funding without completing pending projects and gets caught in a vicious cycle. As a result, Doña Ana County colonias have received negligible funds from the colonias set-aside dollars between 1992 and 1995. Local experts interviewed strongly emphasize the need for an alternative mechanism to deliver this funding.

In all, it took the concerted efforts of the Anthony Water and Sanitation District, TDS, and other local advocates, and over 20 years of political negotiation, creative fund-raising and hard work to develop the requisite infrastructure capable of supporting new housing development. Sufficient capacity for housing development was ensured through the participation of TDS in the formation of the District from the very beginning. Today the District has also put together a policies manual with the help of TDS. These policies are the culmination of 20 years of problem solving and serve as a model for other districts being formed in the state and for small communities elsewhere.

Housing Development in Anthony

As mentioned earlier, Tierra Del Sol initially began working in Anthony in the early 1970s. Their housing activities in Anthony have spanned over 20 years, with each project representing myriad collaborations with different funding sources and partners. Describing each of these in detail would be extremely complex. Consequently, this study presents highlights of the different projects undertaken in Anthony, with a view to providing other nonprofit housing developers with useful insights. The development undertaken by Tierra Del Sol in 1994 is described in greater detail, and is illustrative of the negotiations involved in each of the prior projects.

While collaborating on the formation of the Anthony Water and Sanitation District, TDS simultaneously began rehabilitation work on housing units scattered throughout the colonia. Through rehab work, TDS was able to assist a number of very low-income homeowners bring their substandard homes into safe and sanitary compliance, through grants and loans. In particular, housing rehabilitation helped keep some of the elderly in Anthony living independently in safe and decent homes. The primary source for funding for rehabilitation work came from HUD's Community Development Block Grant (CDBG) program. Additional funds came from RHS (formerly FmHA), state Weatherization program, foundations and private lenders. While TDS believes rehab work on substandard units is a "Band-Aid" approach and not a cure, there was no alternative available to them at this juncture. They could not proceed with developing self-help housing through the RHS (formerly FmHA) program without the availability of infrastructure. In addition, funding for rehab work was more readily available than financing for new homes at that time. Pragmatic concerns dictated proceeding with housing rehabilitation, while working to lay the groundwork for new housing development in the future.

Subsequently, TDS moved on to develop 109 units of self-help homes in a subdivision called Mercure Estates. This subdivision did not use Anthony Water and Sanitation District's water or sewer services since their system was not extended to this subdivision at the time. TDS actually worked with the residents of Mercure Estates to develop their own wastewater treatment plant. TDS also managed to procure extra funds, as part of their self-help application, for providing increased water tank capacity for these units. Later, once the District was formed and had adequate capacity, Mercure Estates hooked up their own system with that of the District. This was the first self-help project undertaken by TDS in Anthony.

TDS then proceeded to develop 16 units of self-help housing in a subdivision called Las Familias. This was followed by 91 units (45 self-help and 46-contractor built) in the O"Hara subdivision. This subdivision provided a new challenge. According to FEMA flood maps the land TDS wanted to locate the O"Hara subdivision on was designated a flood plain. TDS engineers disagreed with this designation and, after several years, convinced FEMA the area was not, in fact, a flood plain.

In addition, TDS developed 24 units of farm labor housing for the farmworkers of Anthony, undertook some scattered site infill housing development, and completed 30 units of HUD 202 elderly housing across the border in Anthony, Texas. TDS is currently working to complete Phase II of a subdivision called Tierra Linda. Phase I of Tierra Linda was comprised of 45 units of housing and was completed in 1993. When complete, Phase II will add another 40 units to this subdivision. In all, TDS will have contributed over 400 units of good quality, affordable housing to the colonia of Anthony. The process of bringing the Tierra Linda subdivision to fruition is described here, as an example of the types of financing and negotiations undertaken by TDS in order to successfully develop affordable housing in the colonias.

Constructing the Tierra Linda Subdivision

TDS began Phase I of the Tierra Linda subdivision by selecting a site and purchasing an option to buy the land. They chose the site with a view to expanding the development into Phase II, providing they could later secure the needed finances. This is one of TDS's primary strategies: planning for the future while working on a current project, so that they can always move to the next phase of implementation immediately upon completing the development in hand. Since TDS had been intricately involved in the creation of the Water and Sanitation District, they were able to locate this development near the District in order to facilitate the extension of infrastructure services. The close ties TDS developed with the District over the years also facilitated access to infrastructure for housing developments sponsored by TDS. This is indicative of the extent of forethought required by nonprofit groups interested in changing conditions in the colonias. Effective community development takes many years of hard work, and requires involvement in addressing every aspect of the community's needs. It also requires the building of key relationships with other players in the community.

TDS decided to approach the Federal Home Loan Bank (FHLB) for Affordable Housing Program (AHP) funds to assist with financing the acquisition and construction of the building lots, which would then be purchased by eligible families with financing from RHS (then FmHA). They succeeded in negotiating a $380,000 loan at 5 percent interest for two years and a $90,000 grant from the FHLB through the First Federal Bank of Las Cruces as the local lender. The $90,000 grant was pivotal to the success of this venture. It facilitated the extension of water and sewer services to the subdivision, and effectively reduced the cost of each lot by $2,000. Once developed, the lots were sold to families. This sale was financed by RHS, and mortgaged at approximately $3.2 million, which was set aside by RHS for 100 percent of the construction and permanent financing. RHS also committed a grant of $249,000 for technical assistance, including construction management of the homes.

This project also involved the integral working partnership of two nonprofit organizations, Tierra Del Sol (TDS) and Housing and Economic Rural Opportunities (HERO). TDS, with its experience as a nonprofit developer of self-help housing, was the project sponsor and developer, while its partner, HERO, was responsible for purchase of the land and site development. TDS and HERO share a special working relationship that proves extremely advantageous when developing affordable housing projects. HERO was created by TDS in the mid 1980s as a response to an obstacle TDS encountered while trying to develop self-help housing projects. HUD was responsible for executing subdivision approvals prior to the developers receiving federal funds. FmHA (now RHS) had a reciprocity agreement with HUD to accept their approval process and requirements. TDS staff claim that HUD's requirements were based on their experience in urban areas, and placed an unreasonable burden on housing developers working in rural areas. In addition, TDS developed an adversarial relationship with the local HUD staff in charge of the approval process. Consequently, local HUD staff proceeded to stall approvals for TDS subdivisions. TDS began lobbying to get HUD and RHS out of the subdivision approval process, and recommended that local regulations for subdivisions be considered sufficient. In the meantime, TDS created a separate nonprofit, HERO, for carrying out land development activities and seeking subdivision approvals. TDS staff assert that this structure enabled them to circumvent the roadblocks placed in their path by local HUD officials. Finally, in 1993, Congress mandated that HUD and FmHA (now RHS) would no longer be responsible for subdivision approvals. However, TDS continued to function with HERO as an integral part of its organizational structure, owing to other advantages this partnership had to offer. TDS is able to divide liability on a project with HERO, so that the assets of both groups are better protected. In addition, TDS is able to charge for certain work, such as house plans, through HERO. It would otherwise not be able to charge for these services, owing to quirks in RHS regulations.

TDS worked in partnership with a number of other organizations in order to successfully develop the Tierra Linda subdivision. The Doña Ana County Planning and Zoning Commission reviewed and approved the 20-acre subdivision located in the heart of the colonia community of Anthony. In addition, they assisted TDS with offsite road improvement planning. The Anthony Water and Sanitation District provided infrastructure planning, construction financing and assistance for off-site sewer lines with $600,000 in grant funds from HUD CDBG colonias set-aside funding. The Anthony Water Works, a private water system, assisted with the planning and construction of offsite water lines. The state legislature provided $25,000 of grant funds through their Safe Water Program for water and sewer connection costs for low-income families. Skyline Engineering, a private engineering consulting firm, designed and inspected the construction of subdivision lots. The Housing Assistance Council was also a partner in this venture, and assisted by providing a $190,000 guarantee of the loan from the commercial lender under the FHLB program, in order to meet the requirements of the Office of Thrift Supervision.

Actual construction of the homes was carried out by the mutual self-help method by the owners themselves, in groups of eight families. The RHS mutual self-help program is modeled on the old "barn raising" concept, which involves neighbors helping each other to build their homes. Each family work group includes eight or ten families that perform volunteer, unskilled labor, coupled with licensed subcontractors and supervision by TDS to complete the home. This process truly serves to empower the poor through homeownership. The benefitting families contribute a fair amount of sweat equity to the project and receive home loans from RHS, the lender of last resort, since they are not able to access traditional financing. Some of the homes in the subdivision were built by local, licensed subcontractors, then sold to low-income families financed by RHS. This arrangement works well for families who are unable to participate in the construction of their homes. The Tierra Linda units are standard wood-frame units with a brick and stucco facade, and are nearly 1,100 square feet in area.²⁰ [See Figure 2b for a view of the units.]

The typical new, single-family, three-bedroom self-help house in Tierra Linda costs $37,000. The contractor built units cost about $48,000. These housing costs are best appreciated when placed in the context of the prevalent local housing market. Local realtors report that the lowest priced home of comparable quality sold in a comparable location typically costs $60,000 to $70,000. At conventional rates of about 11 percent interest, plus down payment and financing fees, the buyer must pay about $660 to $760 per month, not including taxes and insurance. Clearly, families with annual incomes between $8,000 and $12,000 that TDS hoped to serve could not afford these payments. It should be noted that the county Public Housing Authority reported that its waiting list included more than 300 people and was no longer open. Private rental units are almost nonexistent. Consequently, participating in the self-help construction program with TDS offers low-income families in Anthony a unique opportunity to own their homes.

As part of the project, TDS combined administration of the self-help program with family credit counseling, preconstruction training, and homeownership counseling. The training and counseling efforts are a crucial ingredient of the success of the housing developments completed by TDS. Counseling ensures that the families participating in the program are truly committed and ready for the hard labor they are required to contribute. Counseling also helps prevent families from becoming delinquent and losing their homes. In addition, the construction training provides families with necessary skills to maintain their homes in good condition. The total package offered by TDS promotes real self-sufficiency for low-income families that is beyond the mere dollar value.

After completing Phase I of the Tierra Linda subdivision, TDS proceeded with construction of Phase II. HAC and Bank of America were financial partners in this stage of the project, along with RHS. TDS will complete construction of the 40 homes in this phase by the end of 1996. They had hoped to complete construction of these units at least a couple years earlier. TDS staff attributes this delay in part to the difficulty of obtaining $5 million in funding for sewer expansion from federal agencies in a timely fashion. TDS claims this obstruction is a classic example of problems arising from the bureaucratic handling of funding requests by federal EPA and state environment departments administering the colonias water and sewer grant funds. It cost the County three years of unmet thresholds and a consequent loss of CDBG grant funds. Anthony also lost a huge economic development project. A discount store mall that was planning to locate in Anthony withdrew. In addition, this delay cost TDS $20,000 of accrued interest on construction loans.²¹ Eventually Congressional action, and the intervention of the new Rural Development State Director, achieved the release of the final obstruction.

Figure 2c: Construction of Tierra Linda Phase I

Despite their travails, at the time of this research TDS staff said that they were pleased that they would be able to successfully complete work on the Tierra Linda subdivision, providing 85 needy families with new homes. The Anthony Water and Sanitation District reports that TDS's focused efforts in Anthony have changed the overall character of the colonia. Today Anthony is on the threshold of taking the next step in community development. It has begun to attract economic development opportunities for its residents, and is even considering incorporating.

  Lessons Learned and Replicability

With over 20 years of experience in successfully developing affordable housing in the colonias, TDS has a number of lessons to offer other groups interested in undertaking similar projects.

TDS attributes its success to strong community-based support for its mission, and the close relationships it has worked to develop over the years with key players in the field. The Director of the Anthony Water and Sanitation District concurs with this assessment. Having a committed group of people working with focused attention in a target area is key to effecting positive change in the community. For instance, TDS's relationship with the Water and Sewer District helped ensure that TDS would be able to acquire needed infrastructure for future housing subdivisions. TDS recommends building partnerships and relationships with a broad range of players. At the same time, it urges other local groups to get involved with lobbying and advocating for their interests. A strong network of local interests can effectively impact policies and legislation, as well as counter delaying actions by local-level civil servants. For instance, TDS demonstrated this through removing HUD and RHS from the subdivision approval process.

Often the art of nonprofit housing development involves juggling several funding sources and their reporting requirements. TDS recommends obtaining clarity on these reporting requirements in advance in order to avoid confusion in the midst of developing a housing project. TDS learned this when problems occurred while working with FHLB's AHP program. The process of clarifying the necessary reporting requirements while the project was underway had the unfortunate side effect of making the local lender extremely nervous. This experience destroyed TDS's relationship with this particular local lender, since it affected the local lender's confidence in TDS. It is important to maintain a good relationship with local lenders in order to obtain their continued participation in affordable housing development.

Land purchase and development, and careful timing of different stages of housing development, are crucial aspects of a successful project. TDS cautions against purchasing land without having all the rest of the financing pieces in place. Interest on loans for land purchase and development can accrue rapidly. TDS recommends locking in desirable land with an option, while pursuing the rest of the financing. It is equally important to carefully coordinate utility provision, homebuyer financing, and actual construction. Sometimes it is necessary to commence construction before the entire site is developed and all the infrastructure is in place in order to get this timing right. In order to proceed, it is often necessary to obtain a guarantee of credit for the lender. s comfort that the entire site will eventually be developed. Intermediary groups such as HAC are able to provide this service, and should be utilized.

TDS also recommends instituting an organizational structure that reduces liability. The relationship between HERO and TDS is an example of such a structure. In addition, each project/apartment complex developed by TDS is an independent nonprofit corporation under TDS, which TDS has an agreement to manage. In all, TDS manages a dozen such nonprofit corporations. Each of these nonprofits even has its own board. This facilitates a greater local community voice in the management of the housing projects, in addition to reducing TDS's liability. In this way, no one housing project can bring down the entire organization. Similarly, each project is also protected from any mistakes TDS might make.

Another lesson TDS has to offer is that effecting change in the colonias requires long term commitment. It has taken over 20 years of targeted work in Anthony to achieve the results that can be seen today. Other groups need to accept this reality, and not be disheartened when they do not see immediate results, or are faced with obstructions and delays.

Finally, TDS's approach with beginning with organizing the community around infrastructure development, and finally proceeding to single-family housing, is undeniably replicable. In fact, at the time of this study, TDS had already begun replicating this approach in the colonia of Sunland Park, NM.

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