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and lack a full complement of agricultural support services. DHHL Land Base Serves Two Purposes The DHHL land base is used to develop native Hawaiian homesteads and to generate revenues for administration and other costs. These conflicting purposes for the land have been a continuous source of confusion and controversy. Expanded homestead programs experienced since 1975 create additional demands for staff to provide services and maintain quality standards. Planning, design, and construction of homestead improvements are largely dependent on State funds. It has been suggested that DHHL allocate raw land without services or improvements. However, experience has shown, that a balanced program of services and improvements is required. DHHL is caught in a continual bind—it cannot develop homestead improvements fast enough to use large tracts of land and it needs to use the same land base to generate revenues for expanded services. Federal Role Omitted The draft report introduction states that the purpose of the investigation was: ...to determine if the Department of the Interior has adequately executed its trust responsibilities for programs «  and activities of the Hawaiian Homes Commission as provided by the Hawaiian Homes Commission Act, 1920, and the Hawaii Admission Act of 1959. (page 1) The draft report does nor attempt to define federal responsibilities, nor does it include an evaluation of the performance of the federal government in its trustee capacity. This is a serious deficiency of the draft report. The federal government has played an active role throughout the history of the HHCA. The U.S. Congress created the HHCA. The federal government had jurisdiction over its implementation when Hawaii was a Territory and retained trust responsibilities outlined in the HHCA and Admission Act that are still in effect. The basis for interpreting the U.S. Department of the Interior (USDI) role as "ministerial" in a 1972 memorandum of DHHL is not clarified. The draft report does not discuss whether this passive role is still considered adequate or whether the feder.x government's trustee responsibilities are more extensive in scope and active in nature. The draft report describes specific actions by the federal government that are questionable without recommending corrective actions. This refers to the USDI approval of HHCA land exchanges and the illegal use of 1,356 acres at Lualualei, Oahu, by the U.S. Navy. Alternative Funding Sources Not Explored The draft report contains no substantive and detailed recommendations on alternative funding sources, including federal funds, that may be channeled to DHHL. It is clear that many of the problems faced by the DHHL and documented in the draft, report are related to the lack of funds for site improvements, construction, financing, programs, and operations. DHHL has made significant strides under the present State Administration 404