"Results reveal that the cost of not offering housing and supportive services is nearly equal to the cost of providing them."

Ms. Burt provides an excellent analysis on the macro causes of homelessness around the globe and her research lends substantial additional credibility to the Housing First model, if the model is implemented with the appropriate wrap-around services administered by competent providers. This is perhaps the most critical - and costly - component of the effort, and it is one that sadly, most agencies and local governments are ill-prepared to address. (From Lexis Nexis Legal) Fordham Urban Law Journal March, 2003 30 Fordham Urb. L.J. 1267 LENGTH: 5879 words ESSAY: CHRONIC HOMELESSNESS: EMERGENCE OF A PUBLIC POLICY NAME: Martha R. Burt* BIO: * Ph.D., Urban Institute, Washington, D.C.

Introduction The past two years have witnessed a major shift in public commitment to end chronic homelessness within the next decade. This Article examines the phenomenon of chronic homelessness and its emergence as the focus of a significant policy transformation. It first sets the scene with a brief review of why homelessness remains a significant social problem after twenty years of public and private investment in homeless assistance networks. It then looks at definitions of homelessness in general, and chronic homelessness in particular. With respect to policy, it traces a story that starts with research. Initial research showed that even the most chronic, disabled, street-dwelling homeless people will accept and remain in housing, given the right configuration and the right supportive services. Research on program effectiveness was followed by analyses showing near break-even public costs for providing the housing. The story continues with evidence that the numbers of chronically homeless people who would need housing are within a manageable range. The Article concludes by examining what advocates have done and are still doing with the research evidence, and an overview of public commitments and the effort it will take to assure that they are fulfilled.

I. Causes of Homelessness Two types of factors are generally acknowledged as causing homelessness in the sense that they create the conditions under which people are more or less likely to find themselves homeless. ⁿ¹ Factors of the first type are structural - they are larger societal trends and changes that affect broad segments of a population. ⁿ² These include changes in housing markets and land use, employment opportunities, the quality and relevance of public education, [*1268] institutional supports for people with disabilities, and discriminatory policies of several varieties. ⁿ³ If housing prices go up, all other things being equal, fewer people can afford housing. ⁿ⁴ If unemployment rises, or if pay levels of the most available jobs remain too low relative to the price of housing, fewer people can afford housing. ⁿ⁵ If public education and other institutions do not prepare most people to obtain jobs that pay a living wage, more people will be at risk of homelessness. ⁿ⁶ And so on. Structural factors determine why levels of homelessness rise or fall in this place, at this time, rather than in some other place or at some other time. ⁿ⁷

Factors of the second type are individual - they are the conditions and circumstances that make particular people particularly vulnerable to homelessness. ⁿ⁸ These include various disabilities (for example, mental illness, developmental disabilities, and physical disabilities), illnesses, illiteracy, and addictions. ⁿ⁹ They may also include personal circumstances such as domestic violence, too many to support on one income, having no family to rely on (for example, because one has been in foster care, or because of familial abuse), apartment condemnation, or fire, flood, hurricane, or war. ⁿ¹⁰

A third factor, public policies, may mitigate structural and individual factors that determine the ultimate level of "literal" homelessness in a particular time and place. ⁿ¹¹ Emergency relief often can provide this for victims of natural disasters or war. A guarantee of housing may afford this for citizens of several European countries. Income and other support for people with disabilities severe enough to prevent their working might prevent their becoming homeless. ⁿ¹² There will always be some people without roofs, communities, or families. The sheer number of people experiencing literal homelessness in the United States during the past two decades, however, indicates a very unfortunate convergence of [*1269] structural and individual factors that, to date, have not been countered with public policies adequate to reduce their ability to generate homelessness. The campaign to end chronic homelessness during the coming decades will arise from recognizing that public policy changes could make a substantial difference.

II. Defining Homelessness and Chronic Homelessness Homelessness has been defined in various ways in different eras, countries, and circumstances. Historically, ideas of homelessness have usually incorporated one or more of the concepts of being without place (not being "from here"), without family, or without housing. ⁿ¹³ In the United States during the last two decades, federal policy has been governed by the definition articulated in the principal federal legislation related to homelessness - the McKinney-Vento Homeless Assistance Act, subsequently renamed the Stewart B. McKinney Homeless Assistance Act ("McKinney Act") ⁿ¹⁴ and subsequent reauthorizations and expansions. ⁿ¹⁵ The Act defines a person as homeless if the "individual lacks a fixed, regular, and adequate nighttime residence." ⁿ¹⁶ People sleeping in "a public or private place not designed for, or ordinarily used as, a regular sleeping accommodation for human beings," as well as those staying in shelters for homeless people, are part of the definition. ⁿ¹⁷

To operationalize the public policy of the Act's definition, at a practical level it is often translated into the narrowest of working definitions - having been without housing last night, or expecting to be without housing tonight. Thus, people in precarious circumstances who still manage to stay in conventional dwellings by moving every few days or weeks from one relative's house to another [*1270] would not be considered homeless until they reached the situation of having nowhere to go but the streets or a shelter.

Similarly, someone whose pension or disability check provides enough money to afford a cheap hotel room for three weeks out of every month, but who resorts to the streets until the next check arrives would only be considered homeless at the end of the month, even if this pattern has lasted for years. The consequence of this policy-driven working definition has been the development of an extensive network of homeless assistance programs that help to ameliorate the realities of homelessness for those already without housing. ⁿ¹⁸ But most existing homeless-specific programs can do little to prevent homelessness or change the forces that continue to generate homelessness.

III. Characteristics of Chronically Homeless People Regardless of how "chronic" is defined, the population is largely male (seventy-seven to eighty-six percent), about sixty percent are middle-aged (between thirty-five and fifty-four years old), and most are very disabled. ⁿ¹⁹ Between eighty-three and eighty-seven percent, again depending on definitions of chronic, have mental health, alcohol, and/or drug problems. ⁿ²⁰ Thus, ending chronic homelessness means assisting people who have one or more severe disabilities, and often have a history of resisting efforts to help them address those disabilities.

IV. Program Success: Evidence that Something Works To make a new policy, one must know what will work and how much will be needed, after which advocacy focuses on the appropriateness of acting on this knowledge. In the 1980s, there was no evidence of what would work to bring chronically homeless people into housing and induce them to stay there. An early contribution of public policy to the knowledge base of what works were the research-demonstration [*1271] programs authorized by the McKinney Act to see what would work to end homelessness among chronically homeless persons with severe mental illness and/or chronic substance abuse. ⁿ²¹ Starting in the early 1990s, with results appearing during the middle and end of that decade, these studies consistently found that if housing was supplied, people would come in from the streets and remain stably housed. Without the housing component, however, no amount of other services affected levels of homelessness. ⁿ²² The approach that worked was permanent supportive housing. ⁿ²³ The housing could take any one of many configurations - apartments, houses, group houses, single room occupancy hotel rooms ("SROs"); the supports could be offered through many mechanisms - on site staff, drop-in, community-based teams. ⁿ²⁴ But the housing component was essential; services alone were not enough. Practitioners and advocates quickly got the message - this can be done, but it takes housing!

V. Numeric Estimates: Evidence of Reasonable Scope The next question for policy makers and advocates was: how much is needed? Some local communities have estimates or counts of homeless populations, and even of chronically homeless or street-dwelling homeless people. ⁿ²⁵ Some of these communities have already used their estimates as the basis for local campaigns to end chronic homelessness. ⁿ²⁶ In order to stimulate national policy, [*1272] however, national data is needed. The only source for national estimates on the homeless population is the National Survey of Homeless Assistance Providers and Clients ("NSHAPC"), conducted in 1996, with point-in-time and annual estimates of the homeless population published in early 2000. ⁿ²⁷

Subsequent analyses of the same data have utilized combinations of "spell length" and "number of times homeless" to create different definitions of "chronic" homelessness. These analyses then estimated how many single adults might fit each category. Using only information about the length of a person's current homeless spell, a definition requiring two years of homelessness to qualify as chronic includes 28.8 percent of all single homeless adults. Reducing the required time to one year increases the proportion considered chronic to 42.7 percent. The pattern examined for multiple episodes (four or more within the past five years) captures the smallest proportion of single homeless adults (16.4 percent). Combining the two criteria (length of current spell and multiple episodes) increases the proportion of single homeless adults who would be defined as chronic, and also illustrates that some people qualify under both criteria - they have had several homeless spells and their current spell has lasted at least one or two years. In terms of numbers, estimates for a single point in time range from a low of 48,000 (based on October estimates and a definition using multiple episodes) to a high of 270,000 (using February estimates and a definition of "at least one year or four or more episodes within the last five years"). Numbers for longer lengths of time such as a year might be as much as twice as large, as people with past homeless episodes come back into homelessness or already homeless people's spells lengthen. But because the estimates are for a chronic population, far less in-and-out movement is expected during a year than would be true for the homeless population as a whole, which may, in the course of a year, see as many as six times as many people experience homelessness as would be true at a single point in time. Roughly speaking, therefore, we could assume that over the course of a year between 150,000 and 250,000 single adults experience chronic homelessness. In the eyes of many people, providing housing and supportive services for a population of this size is manageable.

Most chronically homeless people have significant personal vulnerabilities, such as severe mental illness, substance abuse, or [*1274] both. ⁿ²⁸ These problems often lead the public and policy makers to believe that chronically homeless people will resist housing and services. ⁿ²⁹ But, as the evidence cited earlier shows, most will accept housing and services if they are structured appropriately, and most will stay in that housing rather than return to the streets. ⁿ³⁰

VI. Money: Evidence of Reasonable Costs Providing housing and supportive services to chronically homeless people costs a lot of money, which is one reason why communities do not do more of it. ⁿ³¹ Chronically homeless people, however, also cost communities a lot of money when they are not housed, as well as reducing the quality of life for homeless and non-homeless alike. ⁿ³² Databases showing shelter use by individuals allow us to see that relatively few (about ten to fifteen percent) of the people homeless at any given time are continuously homeless, or return to homelessness regularly and never establish stable residence. ⁿ³³ Further, these few take up at least half of the resources available in the system of emergency response to homelessness - using fifty percent or more of the available shelter bed nights, in quite a number of cities capable of providing this information. ⁿ³⁴ So, they are being housed (in shelters), just badly housed, and expensively housed. Moreover, in shelters they do not get much help to leave homelessness. ⁿ³⁵

In addition to shelter and other resources of the homeless assistance system, chronically homeless people drain the resources of hospital emergency rooms and inpatient services, psychiatric outpatient and inpatient services, substance abuse services, jails and prisons, veterans' services, and other public agencies. ⁿ³⁶ Dennis Culhane and his colleagues at the University of Pennsylvania have recently completed works on supported housing programs in New [*1275] York City and Connecticut, documenting the extensive public costs incurred by these systems in caring for chronically homeless adults. ⁿ³⁷ Results reveal that the cost of not offering housing and supportive services is nearly equal to the cost of providing them. This cost analysis was the final piece of the puzzle that has stimulated recent commitments to ending chronic homelessness.

VII. Developing a Public Policy Research provided the first step toward developing today's emphasis on ending chronic homelessness. Early federally funded demonstrations showed that very long-term homeless people with many disabilities and problems come directly into housing and stay there, with appropriate services and supports. Subsequent studies and evaluations have demonstrated the same thing. National survey data provided evidence that the chronically homeless population was of reasonable size. Finally, financial analyses showed that the public costs of not providing housing and supportive services for this population came very close to equaling the costs of making housing available.

Advocacy followed the research. Armed with the evidence that it was possible to get chronically homeless people off the streets, that the numbers were not that large, that the people affected have many vulnerabilities, and that it does not even cost very much, advocates prepared the case. Some organizations and communities had already been working to develop permanent supportive housing, including the Massachusetts Housing and Shelter Alliance in partnership with the Massachusetts Department of Mental Health, Columbus/Franklin County, Ohio's Community Shelter Board in its Rebuilding Lives initiative, and the Corporation for Supportive Housing in projects in eight states. What advocates began to promote was national commitment.

Advocacy was an early step, undertaken to convince Congress to make permanent supportive housing a priority within federal homeless funding streams. Such housing is an essential element in any plan to end homelessness among chronically homeless individuals. For the first time, for federal fiscal year 1999, the United States Department of Housing and Urban Development ("HUD") [*1276] appropriation bill carried the stipulation that thirty percent of HUD's funding for the supported housing program be set aside for permanent supportive housing. Advocacy and bipartisan Congressional support has seen to it that the thirty percent set-aside has been maintained; additional funds have also been made available to assure renewals of permanent supportive housing programs whose initial grants were expiring.

The National Alliance to End Homelessness kicked off a campaign during its 2000 annual conference, unveiling its "Ten Year Plan to End Homelessness." ⁿ³⁸ The part of the plan pertaining to ending chronic homelessness marshaled the evidence reviewed above, then laid out steps that will be necessary to achieve the goal, including the now oft-repeated phrases of:

. "Opening the Back Door" - providing housing to help people leave homelessness. ⁿ³⁹

. "Closing the Front Door" - assuring that people leaving institutions such as mental hospitals, substance abuse treatment facilities, and the foster care system do not leave into homelessness. ⁿ⁴⁰

. "Building Infrastructure" - creating more housing, more earning capacity, and better preventive services. ⁿ⁴¹

The National Alliance worked to build partnerships and get commitments from federal agencies, and eventually also from the White House. ⁿ⁴² Early in his tenure, National Alliance members visited HUD Secretary Mel Martinez and convinced him that ending chronic homelessness was something that could be done, and should be done. ⁿ⁴³ The fact that there was strong Congressional backing for providing federal funds to the effort also helped move HUD toward a commitment to work on ending chronic homelessness. ⁿ⁴⁴ By the National Alliance's 2001 annual conference the [*1277] HUD Secretary was a featured speaker, discussing the need to end chronic homelessness in the United States. ⁿ⁴⁵

By July 2002, the Federal Interagency Council on Homelessness was revived (it had been moribund for six years), and a staunch advocate from Massachusetts, Philip F. Mangano, was appointed as its executive director. ⁿ⁴⁶ His portfolio includes working to end chronic homelessness and increasing cooperation and coordination among the major federal agencies to bring this about. ⁿ⁴⁷ In July 2002, the Council was able to announce a new federal strategy to end chronic homelessness, including a substantial commitment to work on prevention (closing the front door) as well as helping people once they become homeless. ⁿ⁴⁸ That commitment involved directives to three federal agencies (the Department of Health and Human Services, the Department of Housing and Urban Development, and the Department of Veteran Affairs) to develop working relationships around ending homelessness.

As part of this rapid increase in emphasis on ending chronic homelessness (two years from announcement to federal commitment is very fast in the world of politics), national commitment appears to be growing. Editorials have appeared in major newspapers calling for the end of chronic homelessness and declaring it possible to accomplish. ⁿ⁴⁹ A national conference in May 2002 sponsored by the Corporation for Supportive Housing began a national campaign to get local and state jurisdictions to agree to a "compact" to end chronic homelessness by developing 150,000 units of permanent supportive housing in the next ten years. The momentum can be seen in the number of communities that are starting to think of developing their own plans to end chronic homelessness (or all homelessness) in ten years, and a number that have already developed such plans and are acting on them.

[*1278]

Conclusion The question is, will the momentum of new policies and commitments carry through to actual changes in levels of chronic homelessness? Ending chronic homelessness will not be cheap, and although costs are near to break-even with current practices that leave vulnerable people on the streets, the costs come out of different agencies' pockets. It will take political will in local communities and at the federal level to capture the savings from various departments and invest them in the activities and programs that will end chronic homelessness. Further, the effort must be sustained over a decade and beyond. Columbus, Ohio, for instance, began its Rebuilding Lives campaign and its commitment to create 800 units of permanent supportive housing for street homeless people almost five years ago, and it is now less than halfway to its goal. ⁿ⁵⁰ In this effort, political will is everything, but political will is usually very hard to sustain as years go by and administrations change.

The larger question also, of course, remains - what will it take to end homelessness altogether. In a recent brief, the Author discussed several steps that are widely regarded as essential if we are to see the end of all types of homelessness in this country. ⁿ⁵¹ These steps are quite similar to the "building infrastructure" component of the National Alliance's plan to end homelessness.

First, housing has to become more affordable. The simplest way to do this is to subsidize housing; research indicates that the public policy that would do the most to reduce the risk of homelessness is subsidizing housing. ⁿ⁵² This involves no need to build new units, no struggles with project siting or zoning or "not in my back yard" behavior. All it takes is providing those people with the most disparate housing costs in relation to their income the financial resources to remain in place. In addition, new housing needs to be created that is affordable by people earning relatively little despite working regularly - renewed incentives for producing affordable rental housing [*1279] would greatly help the current situation of inadequate housing supply.

It is also essential that people who are poor today, and their children, have the educational and training opportunities to assure that they are not poor tomorrow. That is, we have to increase the ability of the poorest people in this country to be able to afford housing without requiring subsidies in the future. The problem is, these steps are not in political favor at this time, being seen as the old anti-poverty agenda. Instead, present federal budget proposals actually offer significant cuts in public and subsidized housing - actions that in the long run will work against the federal commitment to end chronic homelessness. Ultimately, the solution to chronic homelessness will rest on the solution to homelessness in general; the latter begets the former. Only a few communities so far have committed themselves to this larger goal. Legal Topics: For related research and practice materials, see the following legal topics: Labor & Employment LawDisability & Unemployment InsuranceDisability BenefitsCoverage & DefinitionsDisabilitiesInsurance LawProperty InsuranceCoverageHurricanes & TornadoesReal Property LawOwnership & TransferDeath & IncapacityGeneral Overview FOOTNOTES:

n1. Martha Burt et al., Helping America's Homeless: Emergency Shelter or Affordable Housing? 7 (2001); Paul Koegel et al., The Causes of Homelessness, in Homelessness in America 25 (Jim Baumohl ed., 1996).

n2. Burt et al., supra note 1, at 7; Koegel et al., supra note 1, at 26-27.

n3. Burt et al., supra note 1, at 7; Koegel et al., supra note 1, at 26-29.

n4. Koegel et al., supra note 1, at 26-29.

n5. Id.

n6. Id.

n7. Burt et al., supra note 1, at 8-10.

n8. Burt et al., supra note 1, at 8; Koegel et al., supra note 1, at 25, 29-33.

n9. Burt et al., supra note 1, at 8; Koegel et al., supra note 1, at 25, 29-33.

n10. Burt et al., supra note 1, at 8; Koegel et al., supra note 1, at 25, 29-33.

n11. Burt et al., supra note 1, at 6 ("'Literal' homelessness is defined on a day-by-day basis, and involves sleeping either in a facility serving homeless people, in accommodations paid for by a voucher from a program serving homeless people, or in places not meant for human habitation.").

n12. Id. at 327-28.

n13. See Burt et al., supra note 1, at 2-5; Kim Hopper, Reckoning with Homelessness (The Anthropology of Contemporary Issues) 16-17 (2003); Kim Hopper & Jim Baumohl, Held in Abeyance: Rethinking Homelessness and Advocacy, 37 Am. Behavioral Scientist 522, 522-25 (1994); Kim Hopper, Homelessness Old and New: The Matter of Definition, 2 Housing Pol'y Debate 757, 757-814 (1991); Kim Hopper & Jim Baumohl, Redefining the Cursed Word: A Historical Interpretation of American Homelessness, in Homelessness in America, supra note 1, at 3-6.

n14. The McKinney-Vento Homeless Assistance Act, renamed, Stewart B. McKinney Homeless Assistance Act, Pub. L. No. 100-77, 101 Stat. 482 (1987) (codified as amended at 42 U.S.C. 11301 et seq. (1995)).

n15. For a description of subsequent reauthorizations and expansions of the McKinney Act, see the U.S. Department of Housing and Urban Development website, at http://www.huduser.org/publications/homeless/mckin/intro.html (last visited Mar. 15, 2003).

n16. 42 U.S.C. 11302(a)(1).

n17. Id. 11302(a)(2)(C).

n18. Burt et al., supra note 1, at 12.

n19. U.S. Dep't of Hous. & Urban Dev., Homelessness: Programs and the People They Serve - Highlights Report: Findings of the National Survey of Homeless Assistance Providers and Clients (Dec. 1999) [hereinafter 1999 Highlights Report], available at www.huduser.org/publications/homeless/homelessness/highrpt.html (last visited Mar. 15, 2003); Martha R. Burt, Homeless Families, Singles, and Others: Findings from the 1996 National Survey of Homeless Assistance Providers and Clients, 12 Housing Pol'y Debate 737, 741-47, 763-68 (2001), available at http://www.fanniemaefoundation.org.proxy.library.vanderbilt.edu/programs/hpd/pdf/HPD 1204 burt.pdf (last visited Mar. 15, 2003).

n20. 1999 Highlights Report, supra note 19; Burt, supra note 19, at 763-68.

n21. 42 U.S.C. 11302.

n22. Deirde Oakley & Deborah L. Dennis, Responding to the Needs of Homeless People with Alcohol, Drug, and/or Mental Health Disorders, in Homelessness in America, supra note 1, at 179-80; David L. Shern et al., Housing Outcomes for Homeless Adults with Mental Illness: Results from the Second-Round McKinney Program, 48 Psychiatric Services 239, 239-41 (1997); Marybeth Shinn & Jim Baumohl, Rethinking the Prevention of Homelessness, in U.S. Dep't of Hous. & Urban Dev. & U.S. Dep't of Health & Human Servs., Practical Lessons: The 1998 National Symposium on Homelessness Research 13-1 (Linda B. Fosburg & Deborah L. Dennis eds., 1999).

n23. Nat'l Alliance to End Homelessness, A Plan: Not a Dream - How to End Homelessness in Ten Years 10 (2000), available at http://www.naeh.org/pub/tenyear/10yearplan.pdf (last visited Mar. 15, 2003).

n24. See id. at 11.

n25. Id. at 3.

n26. Nat'l Alliance to End Homlessness, State and Local Plans to End Homelessness, at http://www.naeh.org/localplans (last visited Mar. 15, 2003). In Ohio, Columbus and Franklin Counties have relied upon gathered estimates, as has the city of Philadelphia. Continuum of Care Steering Comm., Columbus & Franklin County, 10-Year Plan to End Chronic Homelessness: Columbus and Franklin County Implementation Plan July 2002-December 2003 (2002), available at http://www.csb.org/What s New/Ending%20Chronic%20Homelessness%20Cover.htm (last visited Mar. 15, 2003); Greater Phil. Urban Affairs Coalition, Our Way Home: A Blueprint to End Homelessness in Philadelphia 8-9 (1998), available at http://www.homelessphila.org/gpuac.pdf (last visited Mar. 15, 2003). The National Alliance to End Homelessness provides links to the plans for thirteen states and localities on its website. Nat'l Alliance to End Homlessness, supra.

n27. Martha R. Burt & Laudon Y. Aron, Urban Inst., America's Homeless II - Populations and Services (Feb. 1, 2000), available at http://www.urban.org/url.cfm?ID=900344 (last visited Mar. 15, 2003). This work was later published in detail in Burt et al., supra note 1.

n28. See supra notes 8-10 and accompanying text.

n29. Koegel et al., supra note 1, at 146.

n30. See supra Part IV.

n31. Nat'l Alliance to End Homelessness, supra note 23, at 10-11.

n32. Id.

n33. Id.

n34. Dennis P. Culhane et al., Public Shelter Admission Rates In Philadelphia and New York City: Implications for Sheltered Population Counts, 5 Housing Pol'y Debate 107, 109-10, 121 (1994).

n35. Id. at 132-37.

n36. Dennis P. Culhane et al., Public Service Reductions Associated with Placement of Homeless Persons with Severe Mental Illness in Supportive Housing, 13 Housing Pol'y Debate 107, 111, 116, 120-35 (2002), available at www.fanniemaefoundation. org/programs/hpd/pdf/hpd 1301 culhane.pdf (last visited Mar. 15, 2003).

n37. Id. at 108-09 (discussing supported housing programs in New York City); see Arthur Anderson LLP et al., The Corp. for Supportive Hous., Connecticut Supportive Housing Demonstration Program Evaluation: Report Highlights 1-2 (2002) (discussing supported housing programs in Connecticut), available at http://documents.csh.org/pdfs/EvalHighlights.pdf (last visited Mar. 15, 2003).

n38. Nat'l Alliance to End Homelessness, supra note 23, at 1.

n39. Id. at 10.

n40. Id. at 9.

n41. Id. at 13.

n42. See L.A. Homeless Servs. Auth., Strategic Plan to End Homelessness, at http://www.lahsa.org/strategicplan.htm (last visited Mar. 15, 2003).

n43. Nat'l Alliance to End Homelessness, Annual Report 2001, at 15 (2001), available at http://www.naeh.org/pub/anreport2001.pdf (last visited Mar. 15, 2003).

n44. See Congress Nearing Adjournment, Crucial Issues Still Unresolved, Alliance, Sept.-Oct. 2000, at 1, 3, at http://www.naeh.org/pub/newslet/165issue.pdf (last visited Mar. 15, 2003).

n45. See Secretary Mel Martinez, Taking on the Problem that "Cannot Be Solved," Remarks at the National Alliance to End Homelessness National Conference (July 20, 2001), at www.hud.gov/news/speeches/homelessness.cfm (last visited Mar. 15, 2003).

n46. Interagency Council on Homelessness, Biography - Philip F. Mangano, at www.ich.gov/library/pr02-078.html (last updated Apr. 1, 2003).

n47. Id.

n48. Press Release, Interagency Council on Homelessness, White House Interagency Council Announces New Strategy to Combat Chronic Homelessness (July 18, 2002), at www.ich.gov/library/pr02-078.html (last visited Mar. 15, 2003).

n49. See, e.g., Editorial, Ending Chronic Homelessness, N.Y. Times, Mar. 13, 2002, at A24.

n50. Martha R. Burt et al., Urban Inst., U.S. Dep't of Hous. & Urban Dev., Evaluation of Continuums of Care for Homeless People: Final Report 23 (2002), available at http://www.huduser.org/Publications/pdf/continuums of care.pdf (last visited Mar. 15, 2003)

n51. Martha R. Burt, Urban Inst., What Will It Take to End Homelessness? 5 (2001), available at http://www.urban.org/uploadedPDF/end homelessness. pdf (last visited Mar. 15, 2003)

n52. John M. Quigley et al., Pub. Policy Inst. of Ca., Homelessness in California iii-xi (2001), available at http://www.ppic.org/content/pubs/R 1001JQR.pdf (last visited Mar. 15, 2003).