06/08/2026
With all the activity in our Trusts recently, Lawsuits, land uses (Geothermal) Houseless, Health Etc. this paper examines their obligations and where we are at going into our second century of Beneficiary struggles. Its on SUBSTACK (link below) but I'm pasting the body of the paper here for public consumption. Originally prepared for the U.S. D.O.I.
https://open.substack.com/pub/kiaiiwialakai/p/native-hawaiian-trust-obligations?r=7bud42&utm_campaign=post-expanded-share&utm_medium=web
NATIVE HAWAIIAN TRUST OBLIGATIONS IN THE 21ST CENTURY
Accountability, Stewardship, Beneficiary Sustainability, and Governance Reform
TABLE OF CONTENTS
Executive Summary
Why This Discussion May Be Timely
A Century of Accomplishment and Challenge Part I–VIII
The Century Test
Findings From Measurement to Action
Recommendations Federal Authority, Oversight, and Opportunities for Action
A Covenant Between Generations
Conclusion Appendices A–G
Native Hawaiian Trust Obligations Prepared for Office of the Deputy Assistant Secretary U.S. Department of the Interior Prepared by James J.K.C. Maioho Founder, Kia’i Iwi Alaka’i
Origins and Purpose of the Native Hawaiian Trust Part II Mission Alignment and Institutional Accountability Part III Trust Accountability and Performance Frameworks Part III-A The Cost of Delay Part III-B The Governance Gap Part IV Military Leases and Trust Responsibilities Part V Beneficiary Sustainability and Blood Quantum Part VI Mission Drift and Trust Land Utilization Part VII Governance Gaps in Cultural Stewardship Part VIII The Beneficiary Perspective
Appendix A HHCA Authorities
Appendix B DHHL Mission and Foundational Documents
Appendix C Admission Act Authorities
Appendix D Military Land Inventory
Appendix E Beneficiary Statistics
Appendix F Comparative Indigenous Governance Models
Appendix G Mauna Ala Governance Timeline
More than one hundred years have passed since enactment of the Hawaiian Homes Commission Act. During that period, substantial public resources, institutional effort, and community leadership have been devoted toward improving conditions for Native Hawaiians through land access, homesteading, education, community development, cultural stewardship, and related programs.
The existence of Native Hawaiian trust obligations is generally not disputed. More difficult questions concern how those obligations should be evaluated, how success should be measured, and how accountability should be maintained over time.
This paper does not advocate predetermined policy outcomes. It does not seek to assign blame. It does not propose federal intervention into state governance.
Instead, it advances a discussion regarding accountability, stewardship, Beneficiary Outcomes, Mission Alignment, and long-term trust effectiveness.
The central proposition is straightforward. The ultimate purpose of a trust is not merely to administer programs.
The ultimate purpose of a trust is to improve the lives of the people for whom the trust was created.
Accordingly, evaluation of Native Hawaiian trust obligations should include not only measures of administrative activity but also consideration of Beneficiary Outcomes, community stability, cultural continuity, and long-term opportunity.
The central question presented throughout this paper is:
How should policymakers determine whether Native Hawaiian trust purposes are being achieved after more than a century of implementation?
Several developments suggest value in a broader discussion regarding Native Hawaiian trust obligations.
These include:
• More than a century of HHCA implementation.
• Continuing demand for homestead opportunities.
• Housing affordability pressures affecting Native Hawaiian families.
• Ongoing discussions regarding military land use and stewardship responsibilities.
• Questions regarding Beneficiary Sustainability.
• Increased public interest in transparency and accountability.
• Continuing discussion regarding stewardship and consultation practices at culturally significant sites.
Individually, none of these developments necessarily indicate institutional failure.
Collectively, however, they suggest value in periodically examining whether trust institutions remain aligned with the purposes for which they were established.
Any discussion of Native Hawaiian trust obligations should begin by acknowledging significant accomplishments achieved during the first century of implementation.
Thousands of beneficiaries have received homestead opportunities. Communities have been established and expanded. Infrastructure has been developed. Educational programs have supported Native Hawaiian families. Cultural initiatives have strengthened community connections.
https://acrobat.adobe.com/id/urn:aaid:sc:US:55f77c37-ef99-490e-a9cf-0959a0537e32
These accomplishments reflect the efforts of beneficiaries, public servants, elected officials, community leaders, and countless individuals who have contributed to trust administration over multiple generations.
At the same time, significant questions remain. Housing affordability continues to affect Native Hawaiian families. Waiting lists remain a subject of public concern. Large numbers of Native Hawaiians reside outside Hawaii. Questions regarding long-term Beneficiary Outcomes continue to emerge. Accordingly, the existence of accomplishments does not eliminate the need for evaluation. Rather, it creates an opportunity to examine how future success should be measured.
PART I
ORIGINS AND PURPOSE OF THE NATIVE HAWAIIAN TRUST
The modern Native Hawaiian trust framework emerged through a series of legal and political developments spanning more than a century.
Among the most significant was enactment of the Hawaiian Homes Commission Act.
The HHCA established a federal homesteading framework intended to improve conditions for Native Hawaiians through access to land and opportunities for rehabilitation, self-sufficiency, and community development.
The Department of Hawaiian Home Lands describes the Act as providing for the rehabilitation of native Hawaiians through a government-sponsored homesteading program.
The Department of the Interior has noted that approximately 200,000 acres were set aside as Hawaiian Home Lands and that Congress intended the trust to support the return of beneficiaries to the land while strengthening long-term self-sufficiency and cultural continuity.
The Admission Act and subsequent constitutional provisions further established responsibilities relating to Native Hawaiian trust administration and the betterment of conditions of Native Hawaiians.
Collectively, these authorities created a framework intended to produce measurable benefits for Native Hawaiian beneficiaries.
More than a century later, a fundamental question remains. How should policymakers determine whether those intended benefits are being achieved?
This paper suggests that the answer requires consideration not only of institutional activity but also of Beneficiary Outcomes.
PART II
MISSION ALIGNMENT AND INSTITUTIONAL ACCOUNTABILITY
Every institution is created to achieve specific purposes.
Over time, institutions adapt to changing circumstances, evolving responsibilities, demographic shifts, and changing public expectations.
For this reason, Mission Alignment represents a central governance concern. Mission Alignment should not be understood as criticism.
Rather, it reflects a widely accepted principle that institutions periodically benefit from evaluating whether their activities remain connected to their original Trust Purposes.
In the context of Native Hawaiian trust administration, Mission Alignment raises several questions.
How should success be measured? What outcomes should indicate achievement of Trust Purposes? How should policymakers evaluate progress across multiple generations? Beneficiary Outcomes as a Measure of Mission Achievement Mission statements are ultimately expressions of intended outcomes.
Accordingly, evaluation of Mission Achievement should extend beyond institutional activity and include consideration of beneficiary experiences.
Questions that may assist in evaluating Mission Achievement include:
• Are beneficiaries gaining access to land?
• Are waiting periods improving or worsening?
• Are more Native Hawaiians able to remain in Hawaii?
• Are communities becoming more stable and self-sufficient?
• Are future generations experiencing greater opportunity than previous generations?
These questions do not replace traditional performance measures.
Rather, they seek to ensure that institutional activity remains connected to Beneficiary Outcomes.
Mission Compliance Versus Mission Achievement A useful distinction may be made between Mission Compliance and Mission Achievement.
Mission Compliance asks whether institutions are following applicable laws, regulations, and procedures.
Mission Achievement asks whether institutions are producing the outcomes they were created to achieve.
Both questions matter. However, the second question often receives less systematic attention.
This paper suggests that future governance discussions should place greater emphasis upon Mission Achievement.
PART III
TRUST ACCOUNTABILITY AND PERFORMANCE FRAMEWORKS
Accountability is a cornerstone of effective Stewardship. Strong institutions routinely evaluate performance, outcomes, and Mission Alignment.
Such evaluations help strengthen public confidence, improve decision-making, and support long-term effectiveness.
Accordingly, Accountability should be viewed not as criticism but as a tool for institutional strength.
Many existing reporting systems focus upon activity. Funds expended. Projects completed. Leases awarded. Programs administered. These measures are important. However, activity does not necessarily equal impact.
A complementary focus on Beneficiary Outcomes may provide a more complete understanding of trust effectiveness.
Potential outcome measures include:
• Land access.
• Homeownership.
• Waitlist reduction.
• Community stability.
• Economic mobility.
• Cultural participation.
• Beneficiary retention within Hawaii.
As Native Hawaiian trust institutions enter their second century, policymakers have an opportunity to evaluate not only how trust obligations are administered, but whether they are producing the outcomes for which they were created.
A century is long enough to ask whether Trust Purposes are being achieved. The purpose of this paper is not to answer that question definitively.
Rather, it is to encourage development of the accountability frameworks necessary to answer it responsibly.
The discussion that follows focuses upon Beneficiary Outcomes, Accountability, Stewardship, Mission Alignment, and Beneficiary Sustainability.
These concepts are not offered as alternatives to existing reporting systems.
They are offered as complementary tools through which policymakers, beneficiaries, trust administrators, and community stakeholders may evaluate progress during the second century of Native Hawaiian trust administration.
Accordingly, the central question of this paper is:
Discussions regarding accountability are often interpreted as criticism. In practice, accountability is one of the highest forms of stewardship.
Institutions entrusted with public responsibilities routinely evaluate performance, effectiveness, and outcomes.
Such evaluation does not imply failure. Rather, it reflects a commitment to learning, improvement, and long-term success. The same principle applies to Native Hawaiian trust obligations.
Questions regarding Beneficiary Outcomes, Mission Alignment, Stewardship, and Trust Effectiveness should not be viewed as attacks upon institutions or the individuals who serve them.
Instead, they should be understood as evidence of the seriousness with which trust responsibilities are regarded.
Trusts are unique because they operate across generations. As a result, accountability serves two purposes. First, it provides information regarding present performance.
Second, it helps ensure that future generations inherit institutions capable of fulfilling their intended purposes.
In this sense, accountability and stewardship are not opposing concepts. They are complementary responsibilities. Strong stewardship requires accountability. Strong accountability strengthens stewardship.
Together, they help preserve public confidence while ensuring that Trust Purposes remain connected to Beneficiary Outcomes.
The existence of significant accomplishments should be acknowledged at the outset. Communities have been established. Educational investments have occurred. The purpose of this paper is not to diminish those accomplishments.
Rather, it is to examine how success should be measured during the trust’s second century.
Accomplishment and evaluation are not mutually exclusive.
Indeed, the existence of meaningful accomplishments may make evaluation even more valuable because it allows policymakers to identify what has worked, what remains unfinished, and where future efforts may produce the greatest benefit for beneficiaries.
Throughout the first century of implementation, substantial effort has been devoted to trust processes.
Programs have been developed. Applications have been administered. Leases have been issued. Infrastructure has been constructed. Reports have been produced. These activities are necessary. Yet trust processes and Trust Purposes are not identical. Processes describe what institutions do. Purposes describe why institutions exist. The distinction matters.
A trust may successfully administer programs while policymakers continue asking whether intended outcomes are being achieved.
For this reason, the discussion that follows increasingly shifts attention from trust processes toward Trust Purposes and Beneficiary Outcomes.
The question is not whether institutions are active. The question is whether trust purposes are being fulfilled.
Cost of Delay
THE COST OF DELAY
Discussions regarding Native Hawaiian trust obligations frequently focus upon land inventories, budgets, programs, regulations, and administrative processes. These matters are important. Effective administration remains essential to the long-term success of any trust institution.
However, beneficiaries often experience trust systems differently.
For many beneficiaries, the trust is experienced not through statutes, reports, or organizational charts, but through time.
Applications are submitted. Families wait. Years pass. Children grow up. Housing costs increase. Economic conditions change. Life decisions are made.
Accordingly, policymakers may wish to evaluate not only the administration of trust programs but also the consequences associated with prolonged waiting.
The Opportunity Cost of Time The cost of delay is not limited to administrative inconvenience. Time itself possesses value.
Each year spent waiting may represent a year in which a family is unable to build home equity.
A year in which rental payments continue to replace wealth accumulation.
A year in which opportunities available to previous generations become increasingly difficult to obtain.
A year in which housing costs rise beyond reach. Viewed individually, a single year may appear insignificant. Viewed across decades, however, the cumulative impact may become substantial.
The difference between obtaining housing at one point in time versus another point in time can influence household finances, educational opportunities, family stability, retirement security, and intergenerational wealth.
For this reason, waiting periods should not be viewed solely as administrative statistics.
They may also represent deferred opportunity. The Housing Affordability Challenge No discussion of Beneficiary Outcomes can ignore Hawaii’s housing environment. Hawaii consistently ranks among the most expensive housing markets in the United States. For many families, homeownership has become increasingly difficult to achieve. These challenges affect all residents.
However, they may carry particular significance when evaluating trust programs originally intended to improve conditions through access to land and housing opportunity.
As housing costs increase, the consequences associated with delay may also increase.
A waiting period that might have been manageable under one economic environment may produce very different outcomes under another.
Accordingly, policymakers may wish to evaluate waiting periods not merely according to duration, but according to their practical effects upon beneficiaries and families.
The Generational Impact Trust obligations are unique because they operate across generations.
The consequences associated with delay therefore may extend beyond the individual applicant.
Parents apply. Grandchildren are born. Entire family histories unfold while applications remain pending.
The resulting impacts may influence decisions regarding employment, education, housing, relocation, caregiving responsibilities, and family planning.
For some beneficiaries, the question becomes not whether they will eventually benefit, but whether they will benefit within a meaningful period of their lives.
This distinction matters. A trust may ultimately provide access. Yet the value of that access may be affected by the length of time required to obtain it. The Outmigration Question
One of the most significant policy questions confronting Hawaii concerns the continued ability of Native Hawaiians to remain in Hawaii.
Many factors influence relocation decisions. Employment opportunities. Family circumstances. Educational opportunities. Cost of living. Housing affordability. No single factor explains demographic change.
Nevertheless, policymakers may wish to examine whether prolonged waiting periods contribute to broader trends affecting beneficiary retention.
If substantial numbers of Native Hawaiians leave Hawaii because housing and opportunity become increasingly inaccessible, the question becomes relevant to long-term Trust Purposes.
This observation does not establish causation. Nor does it assign blame.
It simply recognizes that housing access, affordability, and opportunity may influence whether beneficiaries remain connected to Hawaii.
The Human Measure Ultimately, the most important questions may be the simplest. Did families gain stability? Did children gain opportunity? Did communities remain intact? Did beneficiaries achieve homeownership? Did future generations inherit greater opportunity than previous generations? These questions move beyond administration and toward outcomes. They focus not upon what institutions did, but upon what beneficiaries experienced.
For this reason, the cost of delay should be understood not solely as a management issue, but as a Beneficiary Outcome issue.
The longer the waiting period, the greater the possibility that opportunity itself becomes delayed.
And when opportunity is delayed long enough, the consequences may extend across generations.
Governance Gap
THE GOVERNANCE GAP
Throughout the first century of Native Hawaiian trust administration, substantial attention has been devoted to questions of law, administration, funding, program delivery, land management, and institutional responsibility.
These discussions remain important. Trusts require administration. Programs require management. Land requires stewardship. Resources require accountability. Yet a broader question emerges when these discussions are considered collectively. Who evaluates whether Native Hawaiian Trust Purposes are actually being achieved? This question may appear simple. In practice, it is surprisingly difficult to answer. The Accountability Challenge Most institutions possess mechanisms designed to evaluate compliance. Financial audits examine expenditures. Legislatures review budgets. Courts interpret legal requirements. Administrative agencies evaluate procedural performance. Inspectors and oversight bodies review adherence to applicable rules. These systems serve essential functions. They help protect public resources. They strengthen transparency. They promote lawful administration. However, compliance systems and outcome systems are not always identical.
An institution may successfully satisfy reporting requirements while questions remain regarding long-term outcomes.
Programs may operate exactly as designed while broader objectives remain difficult to measure.
This observation should not be interpreted as criticism.
Rather, it reflects a common governance challenge faced by institutions throughout the public sector.
The Difference Between Activity and Outcomes How much money was spent? How many projects were completed? How many leases were awarded? How many applications were processed? How many reports were submitted?
These questions are important because activity provides evidence that institutions are functioning.
Yet activity alone does not necessarily reveal whether intended outcomes are being achieved.
A school may measure attendance while still asking whether students are learning.
A hospital may measure services delivered while still asking whether patients are becoming healthier.
Likewise, trust institutions may measure administrative activity while still asking whether beneficiaries are experiencing improved outcomes.
For this reason, effective governance often requires both forms of measurement. Activity matters. Outcomes matter. The Governance Gap emerges when one receives substantially more attention than the other. The Beneficiary Outcome Question
If the purpose of trust administration is ultimately to improve conditions for beneficiaries, then policymakers may wish to evaluate questions such as:
Are beneficiaries gaining meaningful access to opportunity? Are more Native Hawaiians able to remain in Hawaii? Are communities becoming stronger and more stable? Are future generations experiencing greater opportunity than previous generations? Are Trust Purposes being advanced over time? These questions differ from traditional administrative measures. They require longer timelines. They involve multiple variables. They may not fit neatly within existing reporting structures. Nevertheless, they may be among the most important questions policymakers can ask. Who Measures Success?
A central theme of this paper is that responsibility for measuring outcomes is often less clearly defined than responsibility for administering programs.
Most institutions can identify who is responsible for daily operations. Most institutions can identify who is responsible for budgets. Most institutions can identify who is responsible for legal compliance. It is often less clear who is responsible for evaluating long-term success. Who determines whether Trust Purposes are being achieved? Who evaluates whether current strategies remain effective? Who assesses whether outcomes align with original objectives? Who speaks for future beneficiaries?
These questions suggest the existence of a governance challenge that extends beyond any individual agency, administration, or policy dispute.
The Future Beneficiary Problem Trust institutions are inherently intergenerational. This characteristic distinguishes them from many other public programs. Trust decisions made today may affect individuals who have not yet been born. Land decisions made today may influence opportunities decades into the future. Stewardship decisions made today may shape cultural continuity for generations. As a result, policymakers face a unique challenge. Present beneficiaries possess understandable interests. Current administrators possess immediate responsibilities. Elected officials operate within limited terms. Future beneficiaries possess none of these advantages.
Their interests may be affected by current decisions despite lacking direct representation in present-day discussions.
This reality creates what may be described as the Future Beneficiary Problem. How should institutions evaluate whether present decisions support long-term opportunity?
How should policymakers account for consequences extending beyond current planning horizons?
How should Stewardship systems balance immediate needs against future obligations?
These questions deserve thoughtful consideration as Native Hawaiian trust institutions enter their second century.
The Governance Opportunity The existence of a Governance Gap should not be viewed solely as a challenge. It may also represent an opportunity.
Institutions that periodically evaluate Mission Alignment, Beneficiary Outcomes, and long-term effectiveness often strengthen public confidence.
Transparency improves. Decision-making improves. Trust improves. Accountability improves. The objective is not to create additional bureaucracy.
The objective is to ensure that institutions remain connected to the purposes for which they were created.
The Core Question
Throughout this paper, discussions regarding housing affordability, military leases, demographic change, cultural stewardship, and Beneficiary Sustainability have repeatedly returned to a single underlying question.
How should policymakers determine whether Native Hawaiian Trust Purposes are being achieved?
The Governance Gap exists because this question does not always have a clearly identified owner.
It falls between agencies. Between reporting systems. Between election cycles. Between generations.
For this reason, future discussions may benefit from greater emphasis on outcome-focused accountability systems capable of evaluating long-term Beneficiary Outcomes rather than administrative activity alone.
Such systems would not replace existing oversight. They would complement it.
And in doing so, they may help ensure that Stewardship remains connected to purpose, purpose remains connected to outcomes, and outcomes remain connected to the beneficiaries the trust was created to serve.
A century after enactment of the Hawaiian Homes Commission Act, policymakers may wish to consider a small number of beneficiary-centered questions.
These questions are not presented as criticism. They are presented because they go directly to outcomes. Verified Indicators Native Hawaiian population (2020): approximately 680,442. Native Hawaiians residing in Hawaii: approximately 47 percent. Native Hawaiians residing outside Hawaii: approximately 53 percent.
DHHL applicant waitlist: approximately 29,424 applicants as of publicly available 2024 reporting.
Applicants who died while waiting: public reporting confirms that deaths while awaiting homestead opportunities are not merely theoretical and may warrant further study.
Additional Questions Requiring Verification
• Total homestead awards since enactment.
• Average waiting periods.
• Current residents on Hawaiian Home Lands.
• Decade-by-decade award trends.
• Century-wide totals of applicants who died while awaiting awards.
These indicators do not answer every question regarding trust effectiveness.
However, they illustrate the importance of measuring Beneficiary Outcomes alongside administrative activity.
If these questions cannot be readily answered, additional outcome measurement may be warranted.
Finding 1 Trust Purposes Require Outcome Measurement
A century after enactment of the Hawaiian Homes Commission Act, substantial attention has been devoted to administration, compliance, land management, and program delivery.
Less attention has been devoted to establishing a consistent framework for measuring long-term Beneficiary Outcomes.
If Trust Purposes are to remain meaningful, policymakers may wish to evaluate not only institutional activity but also outcomes experienced by beneficiaries.
Finding 2 Mission Compliance and Mission Achievement Are Distinct
An institution may successfully comply with applicable laws, regulations, reporting requirements, and administrative procedures while questions remain regarding long-term outcomes.
Mission Compliance and Mission Achievement should therefore be understood as complementary but distinct concepts.
Both deserve evaluation.
Finding 3 The Cost of Delay Extends Beyond Administration
Waiting periods may influence housing opportunity, wealth accumulation, family stability, relocation decisions, and intergenerational outcomes.
For this reason, waiting should not be viewed solely as an administrative statistic. It may also represent an important Beneficiary Outcome.
Finding 4 Housing Affordability Influences Trust Effectiveness
Housing affordability represents one of the most significant challenges confronting Native Hawaiian families.
Accordingly, evaluations of trust effectiveness may benefit from considering the relationship between trust programs, housing opportunity, and long-term beneficiary stability.
Finding 5 Outmigration Warrants Continued Examination
Available demographic data indicate that a majority of Native Hawaiians now reside outside Hawaii.
The causes are varied and complex.
Nevertheless, the trend raises important questions regarding retention, opportunity, housing access, and long-term Beneficiary Sustainability.
Finding 6 Beneficiary Sustainability Represents a Second-Century Governance Issue
The first century of trust administration focused heavily upon implementation.
The second century may require increased attention to long-term demographic, economic, cultural, and governance sustainability.
Finding 7 The Governance Gap Deserves Further Review
Many institutions measure activity.
Fewer institutions possess clear responsibility for evaluating whether long-term Trust Purposes are being achieved.
The resulting Governance Gap may warrant additional consideration.
Finding 8 Future Beneficiaries Require Representation
Trust institutions operate across generations.
As a result, decisions made today may affect beneficiaries who do not yet possess a voice in present-day governance discussions.
Mechanisms that consider future beneficiaries may strengthen long-term Stewardship.
Finding 9 Stewardship Continuity Matters
The Mauna Ala case study illustrates broader questions regarding succession planning, consultation, continuity, and cultural participation.
These issues extend beyond any individual site and may have relevance throughout Hawaii.
Finding 10 Mission Alignment Reviews May Strengthen Governance
Periodic reviews focused on Mission Alignment may help institutions remain connected to their founding purposes while adapting to changing conditions.
Finding 11 Public Outcome Reporting May Improve Accountability
A recurring, publicly accessible framework focused upon Beneficiary Outcomes may improve transparency, strengthen Accountability, and encourage informed policy discussion.
Finding 12 Trust Effectiveness Ultimately Depends Upon Beneficiary Outcomes
The most important measure of trust effectiveness is not administrative activity alone.
The most important measure is whether beneficiaries experience improved opportunity, increased stability, stronger communities, and greater ability to thrive across generations.
The findings presented above do not dictate specific policy outcomes.
Reasonable people may disagree regarding implementation strategies, priorities, and governance approaches.
Nevertheless, the findings suggest several opportunities through which policymakers, trust administrators, beneficiaries, and community stakeholders may strengthen Accountability, Stewardship, Mission Alignment, and long-term Beneficiary Outcomes.
The following recommendations are offered in that spirit.
The findings presented throughout this paper point toward a common conclusion.
Many of the questions surrounding Native Hawaiian trust obligations are ultimately questions regarding measurement.
How should success be defined? How should progress be evaluated? How should policymakers distinguish between activity and achievement? How should future generations determine whether Trust Purposes have been fulfilled? These questions do not require unanimous agreement regarding every policy issue. Individuals may disagree regarding land use. They may disagree regarding governance structures. They may disagree regarding program priorities. They may disagree regarding implementation strategies.
Yet meaningful progress remains possible if agreement can first be reached regarding how outcomes should be measured.
Measurement does not eliminate disagreement. Measurement provides a framework through which disagreement may become more productive. It allows discussions to focus on evidence. It encourages transparency. It strengthens Accountability.
Most importantly, it helps ensure that discussions remain connected to beneficiaries rather than institutions alone.
For this reason, the recommendations that follow should be understood as practical tools designed to strengthen the relationship between Trust Purposes and Beneficiary Outcomes.
The recommendations are not intended to determine outcomes. They are intended to improve the ability to evaluate outcomes. In this respect, Accountability should not be viewed as an endpoint.
It should be viewed as an ongoing process through which institutions learn, adapt, and improve over time.
The recommendations presented below are intended to strengthen Accountability, Stewardship, Mission Alignment, Beneficiary Sustainability, and long-term Trust Effectiveness.
They are not presented as mandates. Nor are they intended to predetermine policy outcomes.
Rather, they are offered as potential frameworks through which future discussions may occur.
Recommendation 1 Native Hawaiian Trust Governance Roundtable
Establish a recurring governance roundtable bringing together beneficiaries, trust administrators, policymakers, cultural practitioners, researchers, and community stakeholders.
The purpose of the roundtable would be to encourage discussion regarding long-term Trust Purposes, Beneficiary Outcomes, Accountability, Stewardship, and Mission Alignment.
Unlike issue-specific working groups, the roundtable would focus upon long-range governance questions affecting multiple institutions and generations.
Potential topics may include:
• Beneficiary Outcomes.
• Housing opportunity.
• Stewardship responsibilities.
• Mission Alignment.
• Demographic sustainability.
• Outcome measurement.
• Cultural continuity.
The objective would not be consensus. The objective would be sustained dialogue.
Recommendation 2 Independent Beneficiary Outcomes Study
Commission an independent study focused specifically upon Beneficiary Outcomes. Traditional reporting often measures administrative activity.
A Beneficiary Outcomes Study would focus upon questions such as:
• Housing stability.
• Community retention.
• Educational attainment.
• Long-term family opportunity.
The study would seek to answer a simple question:
How are beneficiaries actually experiencing trust programs?
Recommendation 3 Trust Accountability Metrics Working Group
Establish a working group charged with developing consistent outcome-focused measures.
• Occupancy rates.
• Housing retention.
• Educational outcomes.
• Economic indicators.
Such metrics could improve consistency across future reporting systems.
Recommendation 4 Beneficiary Sustainability Study
Undertake a long-range demographic review examining the future sustainability of Native Hawaiian trust institutions.
Areas of inquiry may include:
• Population trends.
• Geographic distribution.
• Housing affordability.
• Beneficiary participation.
• Future demand.
• Demographic projections.
The objective would be to better understand challenges likely to emerge during the second century of trust administration.
Recommendation 5 Mission Alignment Review Process
Establish recurring Mission Alignment reviews at regular intervals.
These reviews would evaluate whether institutional activities remain connected to stated Trust Purposes.
Questions may include:
• Are current programs advancing intended outcomes?
• Have priorities shifted?
• Are resources aligned with mission objectives?
• What adjustments may improve effectiveness?
Mission Alignment reviews are common governance tools and should be viewed as opportunities for improvement rather than criticism.
Recommendation 6 Military Stewardship and Trust-Benefit Review Framework
Develop a framework through which military land arrangements may be periodically reviewed in relation to Stewardship obligations and Trust Purposes.
Potential considerations include:
• Environmental stewardship.
• Cultural resource protection.
• Community impacts.
• Trust-benefit analysis.
• Consultation practices.
• Long-term land use considerations.
The framework would not predetermine outcomes. Its purpose would be to support informed decision-making.
Recommendation 7 Cultural Stewardship Best Practices Initiative
Identify and promote best practices regarding cultural Stewardship governance.
Areas of focus may include:
• Succession planning.
• Knowledge transfer.
• Community participation.
• Cultural consultation.
• Stewardship continuity.
• Long-term governance structures.
Lessons drawn from cultural sites throughout Hawaii may assist future Stewardship efforts.
Recommendation 8 Public Beneficiary Outcome Dashboard
Develop a publicly accessible reporting system focused upon Beneficiary Outcomes.
Potential indicators may include:
• Homestead awards.
• Average wait periods.
• Housing outcomes.
• Long-term opportunity indicators.
The objective would be transparency and informed discussion.
Recommendation 9 Century Review of HHCA Outcomes
Conduct a formal review examining outcomes achieved during the first century of HHCA implementation.
The review should seek to identify:
• Accomplishments.
• Continuing challenges.
• Lessons learned.
• Future opportunities.
The review should be balanced, evidence-based, and focused upon long-term outcomes.
Recommendation 10 Periodic Governance Review Process
Establish recurring governance reviews examining:
• Accountability.
• Stewardship.
• Beneficiary Sustainability.
• Long-term Trust Effectiveness.
The objective would be continuous improvement rather than episodic crisis response.
Recommendation 11 Native Hawaiian Trust Report Card
Establish a recurring public Accountability framework through which Native Hawaiian trust performance may be evaluated against stated Trust Purposes and Beneficiary Outcomes.
The report card should occur at regular intervals, such as every five years.
• Economic mobility indicators.
The objective would not be to rank institutions or assign blame.
Instead, the objective would be to create a transparent framework through which policymakers, beneficiaries, and trust administrators may evaluate progress over time.
Most importantly, the report card would help distinguish Mission Compliance from Mission Achievement.
Programs may function effectively. Budgets may be balanced. Reports may be completed.
Yet the ultimate question remains:
Are beneficiaries experiencing improved outcomes?
The Native Hawaiian Trust Report Card provides a mechanism through which that question may be asked consistently and transparently over time.
Closing Observation
Collectively, these recommendations seek to strengthen the connection between Trust Purposes and Beneficiary Outcomes.
They emphasize Accountability without accusation. Stewardship without rigidity. Transparency without hostility. And governance without predetermined conclusions.
The recommendations are therefore best understood not as prescriptions, but as invitations to continued discussion regarding how Native Hawaiian trust obligations may be evaluated, strengthened, and sustained during their second century.
PART X
The discussion presented throughout this paper raises questions regarding Accountability, Stewardship, Beneficiary Outcomes, Mission Alignment, Beneficiary Sustainability, and long-term trust effectiveness.
These questions naturally lead to a further inquiry.
What role, if any, should the United States Department of the Interior play in future discussions regarding Native Hawaiian trust obligations?
This paper does not advocate expansion of federal authority.
Nor does it suggest that the Department of the Interior should dictate policy outcomes, override state decision-making, resolve personnel disputes, or assume responsibilities assigned elsewhere.
Instead, this paper recognizes that DOI possesses substantial expertise in areas directly relevant to the issues discussed herein.
Across the United States, the Department of the Interior has extensive experience involving:
• Indigenous governance.
• Trust administration.
• Cultural resource management.
• Stewardship systems.
• Consultation frameworks.
• Long-term beneficiary programs.
• Intergovernmental coordination.
As a result, DOI may possess unique opportunities to support constructive dialogue regarding Native Hawaiian trust obligations.
Convening Authority One of DOI’s most valuable tools may be its ability to convene. Many governance challenges do not result from a lack of commitment. Rather, they result from fragmentation. Different institutions focus on different responsibilities. Different stakeholders possess different perspectives. Different agencies operate under different mandates. Convening functions create opportunities for those perspectives to be brought together. Federal involvement in this context need not involve control. Instead, it may involve facilitation. Research and Information Sharing DOI may also support informed decision-making through research and information sharing. Comparative governance models. Trust administration practices. Stewardship frameworks. Outcome measurement systems. Beneficiary reporting mechanisms.
These topics have been examined throughout Indian Country and other indigenous governance environments.
Lessons learned elsewhere may help inform discussions in Hawaii. Facilitating Difficult Conversations
Many of the questions raised in this paper involve issues on which reasonable people may disagree.
Questions regarding land use. Questions regarding stewardship. Questions regarding demographic sustainability. Questions regarding outcome measurement. The existence of disagreement should not prevent discussion.
In some circumstances, a neutral convening role may help facilitate conversations that might otherwise prove difficult.
Supporting Accountability Perhaps most importantly, DOI may help encourage discussions regarding Accountability. Accountability should not be understood as criticism. Strong institutions welcome evaluation. Strong institutions seek evidence. Strong institutions periodically ask whether intended outcomes are being achieved.
Accordingly, DOI may be well positioned to encourage outcome-focused conversations without advocating predetermined conclusions.
The Opportunity Ultimately, the opportunity before DOI is not one of control. It is one of leadership. Leadership through convening. Leadership through research. Leadership through dialogue. Leadership through encouraging thoughtful examination of long-term beneficiary outcomes.
Trust obligations differ from many other public responsibilities because they operate across generations.
The individuals who helped establish the Hawaiian Homes Commission Act are gone. Many of the first beneficiaries are gone. Many of the families who first placed their hopes in the trust are gone. Yet the obligations remain. This reality creates a unique form of Stewardship.
Unlike projects measured in months or years, trust obligations must be evaluated across decades and generations.
The decisions made today may affect individuals not yet born. The opportunities created today may influence families for generations. The consequences of delay may also extend far beyond the present moment. For this reason, Stewardship requires more than administration. It requires perspective. The trust inherited by one generation becomes the responsibility of the next. Each generation receives both benefits and obligations.
Each generation becomes a temporary steward of responsibilities intended to extend beyond its own lifetime.
This concept may be understood as a covenant between generations. The generation that established the trust acted with future beneficiaries in mind.
The generation that administers the trust today bears responsibilities to future beneficiaries as well.
This perspective changes the nature of the questions presented throughout this paper.
The question is no longer:
What is best for today?
The question becomes:
What decisions will best serve beneficiaries across generations? How should land be managed? How should opportunity be expanded? How should cultural continuity be protected? How should Trust Purposes remain meaningful over time? How should future beneficiaries be considered? These questions possess no simple answers.
Yet they remain among the most important questions confronting trust institutions entering their second century.
Future Generations Throughout this paper, repeated reference has been made to future beneficiaries. This emphasis is intentional. Future beneficiaries cannot attend public meetings. They cannot submit testimony. They cannot vote. They cannot advocate for themselves. Yet they may experience the consequences of present-day decisions.
This reality places special responsibility upon current leaders, policymakers, administrators, and stakeholders.
Stewardship therefore involves more than management. It involves guardianship. It involves preserving opportunity.
It involves ensuring that future generations inherit institutions capable of fulfilling their intended purposes.
The Legacy Question Ultimately, every trust institution faces a legacy question. How will future generations evaluate the decisions made today? Will they conclude that opportunities expanded? Will they conclude that communities strengthened? Will they conclude that Stewardship responsibilities were fulfilled? Will they conclude that Trust Purposes remained meaningful? No report, audit, or program can answer these questions fully. Only time can do so.
Nevertheless, thoughtful governance may improve the likelihood that future generations inherit stronger institutions than those received by the present generation.
This paper has examined Native Hawaiian trust obligations through the lenses of Accountability, Stewardship, Beneficiary Outcomes, Mission Alignment, Beneficiary Sustainability, cultural governance, demographic change, housing opportunity, military land stewardship, and long-term trust effectiveness.
It has not sought to determine winners and losers. It has not sought to assign fault. It has not attempted to prescribe specific policy outcomes.
Instead, it has sought to encourage thoughtful discussion regarding how Native Hawaiian trust obligations should be evaluated after more than a century of implementation.
The central proposition of this paper is straightforward.
Trust obligations should not be evaluated solely through expenditures, administrative activity, procedural compliance, or organizational performance.
Those measures remain important. However, they represent only part of the picture.
The ultimate purpose of a trust is to improve conditions for the people for whom the trust was created.
Accordingly, evaluation of trust effectiveness should include consideration of Beneficiary Outcomes.
Did beneficiaries gain opportunity? Did communities become stronger? Did future generations inherit greater opportunity? Did Trust Purposes remain aligned with beneficiary needs? These questions do not replace traditional accountability systems. They complement them.
The Century Test proposed in this paper is therefore not intended as a verdict. It is intended as an invitation. An invitation to measure. An invitation to evaluate. An invitation to ask whether trust purposes are being achieved. Strong institutions are strengthened by thoughtful evaluation. Strong Stewardship is strengthened by Accountability. Strong governance is strengthened by transparency.
The second century of Native Hawaiian trust administration presents an opportunity to build upon accomplishments, address challenges, and strengthen institutions for generations yet to come.
Ultimately, the success of Native Hawaiian trust obligations will not be measured solely by programs administered or reports completed.
It will be measured by the opportunities experienced by beneficiaries.
And by whether future generations conclude that the promises embodied within those obligations were honored.
THE SECOND CENTURY OPPORTUNITY
The first century of Native Hawaiian trust administration was necessarily focused upon implementation.
Institutions were created. Programs were developed. Communities were established. Infrastructure was constructed. Governance systems evolved. The second century presents a different opportunity.
Rather than asking only how programs should operate, policymakers may now ask how outcomes should be measured.
Rather than focusing exclusively upon administration, greater attention may be directed toward effectiveness.
Rather than evaluating activity alone, future discussions may increasingly evaluate results.
This shift should not be interpreted as criticism of past efforts.
To the contrary, it reflects the reality that mature institutions periodically examine whether their efforts remain aligned with their intended purposes.
Such reflection is common among successful organizations. It is a sign of institutional strength rather than weakness.
The opportunity before Native Hawaiian trust institutions is therefore not simply to continue existing practices.
The opportunity is to build upon a century of experience while developing stronger tools for evaluating Beneficiary Outcomes, Accountability, Stewardship, and Mission Alignment.
If pursued thoughtfully, this opportunity may strengthen trust institutions while preserving flexibility regarding future policy choices.
Most importantly, it may help ensure that future generations inherit systems capable of translating Trust Purposes into measurable opportunity.
The question facing Native Hawaiian trust institutions is no longer whether obligations exist.
Those obligations are well established.
The question facing the second century is whether Hawaii possesses the tools necessary to determine if those obligations are being fulfilled.
A century is long enough to ask the question. Future generations deserve an answer. The responsibility of the present generation is not merely to administer the trust. It is to steward it.
And Stewardship ultimately requires the willingness to ask whether the promises embodied within the trust are being translated into measurable opportunity, meaningful outcomes, and lasting benefit for the people the trust was created to serve.
APPENDIX A
HHCA AUTHORITIES
Purpose
The Hawaiian Homes Commission Act (HHCA) established the foundational framework for the Hawaiian Home Lands Trust and remains the principal authority governing the Department of Hawaiian Home Lands.
The Act was intended to improve conditions for Native Hawaiians through access to land, homesteading opportunities, rehabilitation, self-sufficiency, and community development.
The HHCA reflects a recognition that land ownership, land stewardship, and connection to place play important roles in economic stability, cultural continuity, and long-term opportunity.
Core Authorities
The HHCA established:
• The Hawaiian Home Lands Trust.
• Eligibility standards for beneficiaries.
• Homestead leasing authorities.
• Land management responsibilities.
• Administrative structures governing trust operations.
• Long-term stewardship obligations.
Foundational Questions
The HHCA raises several enduring policy questions:
• How should rehabilitation be measured?
• How should self-sufficiency be evaluated?
• How should success be assessed across generations?
• What outcomes best reflect fulfillment of Trust Purposes?
These questions remain relevant more than a century after enactment.
APPENDIX B
DHHL MISSION AND FOUNDATIONAL DOCUMENTS
Current Mission
The Department of Hawaiian Home Lands states that its mission is to effectively manage the Hawaiian Home Lands Trust, develop and deliver lands to Native Hawaiian beneficiaries, and partner with beneficiaries toward self-sufficient and healthy communities.
Mission Themes
Several themes emerge from the mission:
• Land delivery.
• Community development.
• Beneficiary partnership.
• Self-sufficiency.
• Long-term trust management.
Relationship to This Paper
The concept of Mission Alignment discussed throughout this paper derives directly from the principle that institutional activities should remain connected to stated purposes and intended beneficiary outcomes.
The mission therefore provides an appropriate benchmark against which progress may be evaluated.
APPENDIX C
ADMISSION ACT AUTHORITIES
Background
The Admission Act transferred substantial public land responsibilities to the State of Hawaii while preserving certain trust obligations.
Section 5(f) identifies several public trust purposes, including the betterment of the conditions of Native Hawaiians.
Significance
The phrase “betterment of the conditions of Native Hawaiians” remains among the most important standards associated with trust administration.
However, the phrase itself raises important questions. How should betterment be measured? What indicators best demonstrate improved conditions? How should progress be evaluated across generations? Connection to Outcome Measurement
The Accountability frameworks proposed in this paper are intended to assist policymakers in answering those questions.
APPENDIX D
MILITARY LAND INVENTORY
This appendix is intended to provide contextual information regarding major military land-use discussions associated with trust stewardship questions.
The appendix is not intended to advocate any specific lease outcome. Pohakuloa Training Area Island: Hawaii Approximate State-Leased Acreage: 23,000 acres Lease Status: Current lease scheduled to expire in 2029
Primary Considerations:
• Stewardship. • Cultural resources. • Environmental management. • Community engagement. • Trust-benefit analysis.
Makua Military Reservation Island: Oahu
Kahuku Training Area Kawailoa-Poamoho Policy Question
How should long-term military land use be evaluated in relation to Stewardship responsibilities, Trust Purposes, cultural resources, and beneficiary interests?
APPENDIX E
BENEFICIARY STATISTICS
This appendix provides demographic and program indicators relevant to the Century Test and broader discussions regarding Beneficiary Sustainability.
Native Hawaiian Population Approximate Population: 680,442 Source: 2020 Census reporting Population Distribution Native Hawaiians residing in Hawaii: Approximately 47% Native Hawaiians residing outside Hawaii: Approximately 53% These figures indicate that a majority of Native Hawaiians now reside outside Hawaii.
While the causes are varied and complex, the trend raises important questions regarding retention, opportunity, housing affordability, and long-term beneficiary outcomes.
DHHL Applicants Approximate Applicant Count: 29,424
The continuing existence of a substantial waiting list demonstrates ongoing demand for homestead opportunities and trust-related benefits.
Additional Data Requiring Verification
• Average wait time.
• Residents currently living on Hawaiian Home Lands.
• Century-wide applicant mortality while waiting.
Century Test Observation
APPENDIX F
COMPARATIVE INDIGENOUS GOVERNANCE MODELS
Comparative review may provide useful insights regarding accountability, stewardship, beneficiary reporting, and long-term governance.
Maori Governance Models Relevant Features
• Co-governance systems. • Treaty-based frameworks. • Cultural stewardship integration. • Long-term community participation.
Cherokee Nation
• Citizen-focused reporting. • Community investment. • Strategic planning. • Outcome-oriented governance.
Navajo Nation
• Large-scale land stewardship. • Multi-generational governance. • Community-centered planning.
Alaska Native Corporations
• Shareholder accountability. • Asset management. • Long-term beneficiary focus. • Sustainability planning.
Observation
Although legal structures differ significantly, each model demonstrates the value of connecting administration with measurable outcomes.
APPENDIX G
MAUNA ALA GOVERNANCE TIMELINE
This appendix is included as a governance case study illustrating questions involving stewardship continuity, consultation, succession planning, and cultural participation.
1865 Royal Mausoleum established as the resting place of Hawaii’s aliʻi. 1865–1893 Stewardship responsibilities evolve under Kingdom administration. 1893 Hale o Ho’olulu established. Mariah Beckley stewardship appointment. 20th Century Successive generations maintain stewardship continuity. Knowledge transfer occurs through cultural practice, participation, and lived experience. State Era Governance responsibilities transition through state administrative structures.
Questions regarding stewardship continuity, consultation, and participation continue to evolve.
2023
Stewardship transition generates broader discussion regarding:
• Continuity. • Succession planning. • Consultation. • Cultural participation. • Shared stewardship models.
Present
Discussion continues regarding long-term governance frameworks capable of supporting stewardship continuity while maintaining public accountability and cultural legitimacy.
The value of the Mauna Ala case study lies not in any individual dispute. Its value lies in the governance questions it raises. How should culturally significant sites preserve continuity? How should stewardship knowledge transfer across generations? How should consultation occur? How should future stewards be prepared?
These questions extend beyond Mauna Ala and may hold relevance for stewardship discussions throughout Hawaii.
ARE THEY BEING MET?
