Drinking Water and Wastewater Infrastructure: Opportunities Exist to Enhance Federal Agency Needs Assessment and Coordination on Tribal Projects

Tens of thousands of American Indians and Alaska Natives do not have safe drinking water or wastewater disposal in their home—referred to as needs arising from a sanitation deficiency—at a higher percentage than the general population, according to IHS. Among other things, IHS assesses homes, either individually or by reviewing public water systems, to determine any deficiencies. Seven agencies, including IHS, EPA, and USDA, have programs that provide drinking water and wastewater infrastructure assistance to Indian tribes.

GAO was asked to review federal efforts to provide water infrastructure assistance to Indian tribes. This report examines, among other objectives, the extent to which selected federal agencies (1) identified tribes' drinking water and wastewater infrastructure needs and (2) funded tribal water infrastructure projects, including tribes' most severe sanitation deficiencies. GAO reviewed agency data on tribal needs, analyzed agency funding data for tribal water infrastructure projects, reviewed agency policy documents, and interviewed agency officials and officials from 22 tribes representing different geographic locations.

Federal agencies have identified several billion dollars in existing and future tribal drinking water and wastewater infrastructure needs. Specifically, the Indian Health Service (IHS) worked with tribes to identify, in fiscal year 2016, an estimated $3.2 billion in water infrastructure projects to address existing sanitation deficiencies in Indian homes, and the Environmental Protection Agency (EPA) identified an additional $2.4 billion in future tribal drinking water infrastructure needs over the next 20 years. However, IHS could enhance the accuracy of its information about the water infrastructure needs of some Indian homes. In February 2018, the database that IHS uses to track Indian homes' sanitation deficiencies showed that about one-third of the homes (138,700) had no deficiency. However, because the database does not provide IHS with a way to record if a home's deficiency has been assessed, IHS could not determine whether these homes had no deficiency or if they had not yet been assessed to identify a deficiency. IHS officials stated that improving the database's accuracy would be beneficial. By implementing a way to indicate in its database whether these homes' deficiencies have been assessed, IHS could also more efficiently address any deficiencies in these homes.

Federal agencies provided about $370 million for tribal drinking water and wastewater infrastructure projects in fiscal year 2016, including some projects to address what the agencies identified as the most severe sanitation deficiencies (i.e., communities that lack safe drinking water or wastewater disposal). IHS and U.S. Department of Agriculture (USDA) policies direct the agencies to fund tribal projects that address these deficiencies. However, agency scoring processes may not always prioritize the projects that address them:

IHS assigns points to projects using eight scoring factors, including sanitation deficiency and cost. Based on GAO's review of IHS documents and interviews with agency officials, IHS's process for selecting projects can discourage funding some projects that address the most severe sanitation deficiencies, especially those with a relatively high cost per home. As a result, some projects to serve homes without water infrastructure can remain unfunded for many years. IHS officials said the scoring factors balance a number of interests, and the agency is looking to improve the extent to which it funds projects that address these deficiencies.

USDA uses a different set of scoring factors to assign points when evaluating project applications for its tribal water program, including rural population and income levels. However, USDA does not have a scoring factor to assign points to a project based on whether it will serve homes that lack safe drinking water or wastewater disposal, as it does with another program with similar goals. Instead, USDA officials said they use discretionary points to score projects on this basis, but these points may not be awarded at all. As a result, USDA may not have reasonable assurance that it consistently evaluates project applications in a way that aligns with agency policy to fund projects that address the most severe sanitation deficiencies.

By IHS reviewing and USDA updating their scoring processes, the agencies could have more assurance that the projects they fund address the most severe sanitation deficiencies in Indian communities.

GAO is making 16 recommendations, including that (1) IHS develop a way to indicate in its database if homes' deficiencies have been assessed and (2) IHS and USDA review and update project scoring processes. IHS agreed with these recommendations, and USDA proposed an approach for addressing the recommendation on scoring, as discussed in the report.

Tens of thousands of American Indians and Alaska Natives do not have  safe, potable water available in their homes for drinking, cooking, and  cleaning, or adequate facilities to safely dispose of wastewater, according  to the Department of Health and Human Services’ Indian Health Service  (IHS). The agency has stated that, nationwide, members of Indian tribes  are more likely to live in homes without safe drinking water and  wastewater facilities than non-Indians in part due to the remoteness of  many Indian reservations. Moreover, IHS has reported that inadequate  access to safe drinking water and wastewater disposal can lead to many  health problems, including increased hospitalizations for pneumonia,  influenza, and other illnesses.

The federal government’s role in funding construction and repair of  drinking water and wastewater systems in Indian country differs from its  role in funding such systems in the rest of the country. According to IHS  estimates, the federal government provides a significant share of the  financial assistance to construct and repair drinking water and wastewater  infrastructure in Indian country. In contrast, in non-tribal communities,  utilities typically sell municipal bonds and raise revenues to pay for  construction of drinking water and wastewater infrastructure by charging  customers. These communities and utilities can receive funding and  planning assistance from their respective states and the federal  government to repair, replace, and upgrade their drinking water and  wastewater infrastructure. In Indian country, tribes, tribally owned utilities,  or separate entities are generally responsible for operating and  maintaining drinking water and wastewater infrastructure. However,  according to a national intertribal organization, tribes typically do not  have access to the same array of financing options as state or local  governments, and do not necessarily charge their customers for services.

Seven federal agencies administer programs that provide drinking water  and wastewater infrastructure assistance to Indian tribes. IHS, the  Environmental Protection Agency (EPA), and the U.S. Department of  Agriculture (USDA) have drinking water and wastewater infrastructure  programs that are specifically targeted to provide financial assistance for  planning and construction to address Indian tribes’ needs. According to  IHS documentation, such needs arise from a sanitation deficiency in  existing drinking water or wastewater infrastructure (or lack thereof) that  can negatively affect public health. In addition, the Department of Housing  and Urban Development (HUD), the Department of the Interior’s Bureau  of Reclamation, the U.S. Army Corps of Engineers, and the Department  of Commerce’s Economic Development Administration (EDA) administer  programs that may provide financial assistance to tribes for drinking water  and wastewater infrastructure. The types of assistance these agencies  provide vary by program, and each program has its own eligibility  requirements and authorities.

You asked us to review federal efforts to provide drinking water and  wastewater assistance to Indian tribes, including interagency  collaboration efforts. This report examines the extent to which the seven  federal agencies, as applicable, (1) identified Indian tribes’ drinking water  and wastewater infrastructure needs; (2) funded tribal drinking water and  wastewater infrastructure projects, including projects to address the most  severe sanitation deficiencies; and (3) collaborated to meet Indian tribes’  drinking water and wastewater infrastructure needs.

To determine the extent to which these federal agencies identified Indian  tribes’ drinking water and wastewater infrastructure needs, we identified  requirements for IHS and EPA to collect and report information on needs,  but we did not identify such requirements for the other agencies. We  reviewed IHS’s and EPA’s most recent reports describing tribal drinking  water and wastewater infrastructure needs and reviewed the supporting  data in IHS’s Sanitation Deficiency System (SDS) on proposed tribal  drinking water and wastewater infrastructure projects from fiscal year  2016, the most recent year of data available at the time of our review.  To assess the reliability of SDS project data and EPA needs information,  we discussed the data and any of its limitations with agency officials and  determined that the data were sufficiently reliable to provide descriptive  information about tribes’ drinking water and wastewater infrastructure  project needs. We also assessed the reliability of specific information in  IHS’s Home Inventory Tracking System (HITS), including the sanitation  deficiencies associated with homes, by reviewing documentation and  interviewing IHS officials. As we discuss later in this report, we indicate  when we found certain limitations with that information. We did not assess  the reliability of other information in HITS that was not relevant to our  review. We interviewed IHS and EPA officials involved with identifying  tribal water needs from all 12 IHS areas and the 9 EPA regions that  administer tribal drinking water and wastewater infrastructure programs.  We also interviewed officials from the other five agencies regarding any  efforts to collect information on tribal drinking water and wastewater  infrastructure needs.

To determine the extent to which the agencies funded tribal drinking  water and wastewater infrastructure projects, we analyzed obligations  data from the seven agencies that administer programs that provide  drinking water and wastewater infrastructure assistance to Indian tribes— IHS, EPA, USDA, HUD, Reclamation, Corps, and EDA—from fiscal years  2012 through 2016. To assess the reliability of the data obtained from  these agencies, we discussed the funding data, each agency’s data  system, and any limitations with agency officials and determined that the data were sufficiently reliable for the purposes of our reporting objective.  To determine the extent to which agency funding addressed the most  severe sanitation deficiencies, we identified programs that have  documented goals in regulation and policy to fund projects that address  these needs. For these programs, we compared the number of funded  projects that addressed the most severe deficiencies with the number of  funded projects that met other needs for fiscal year 2016. During the  course of reviewing these regulations and agencies’ obligations data, we  identified issues with how USDA awarded grants under one of its tribal  programs—the Rural Alaska Village Grant program. We then obtained  and reviewed documentation of these grant awards and interviewed  officials who manage the program and officials from the agency’s Office  of the General Counsel.

To determine the extent to which the federal agencies collaborated to  meet tribal water needs, we reviewed documentation of national-level  interagency collaboration, including memorandums of understanding.  We compared the agencies’ actions to the key features of interagency  collaboration that we have previously identified. We reviewed agencies’  collaboration at the regional level by surveying the seven agencies about  their joint actions on activities related to tribal drinking water and  wastewater in six states—Alaska, Arizona, California, New York,  Oklahoma, and South Dakota—and by conducting a network analysis  using the survey responses. We selected regional offices that operate in  individual states as the unit of analysis because the federal agencies  organize their field structures differently, with some using region, area,  and state offices to work with tribes—we refer to all of these office types  as regional offices. We selected this nonprobability sample of six states to  include a large percentage of the number of federally recognized tribes, to  obtain a range in the total federal obligations to tribes and the identified  needs of tribes, and for geographic diversity. The sample of states is not  generalizable, and the results of our work do not apply to all states where  Indian tribes are located. However, they provide illustrative examples of  interagency collaboration within the six selected states, which include  about 70 percent of the 573 federally recognized tribes.

We sent collaboration surveys to the regional offices of each of the seven  federal agencies in the six states. We also sent a survey to the State of  Alaska because the state provides a 25 percent match for two federal  water infrastructure programs, but we did not include other state agencies  in our survey because they do not provide a similar match. The survey  asked each agency regional office in each state about the mechanisms  that it used to collaborate with each of the other regional offices within the  same state for the 3-year period prior to our survey, the factors that  affected their collaboration, and any additional mechanisms that would be  beneficial to use in the future. We disseminated a total of 46 surveys and  obtained and analyzed 46 responses. We conducted site visits to three of  the six states, selected based on their geographic diversity and the range  of identified water infrastructure needs. We also interviewed federal  agency officials and officials with the State of Alaska about their  collaboration in the six states. We interviewed officials from 22 Indian  tribes and representatives from 8 intertribal organizations to obtain their  perspectives on obtaining drinking water and wastewater infrastructure  assistance from the seven agencies in the six selected states. We  selected these tribes to obtain a range in their geographic locations and  the amount of drinking water and wastewater infrastructure assistance  they have received. Our findings are not generalizable to all tribes but  provide illustrative examples. Appendix I contains a detailed description  of our scope and methodology, and appendix II contains additional  information about our survey and network analysis, including questions  and summary responses.

We conducted this performance audit from August 2016 to May 2018  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

This section provides information on water infrastructure in Indian  country, federal programs that provide drinking water and wastewater  infrastructure assistance to Indian tribes, and our prior work on  interagency collaboration.

The 573 federally recognized Indian tribes in the United States vary  greatly in terms of their culture, language, population size, land base,  location, and economic status. Many are located in remote and often  environmentally challenging areas. According to the U.S. Census  Bureau’s American Community Survey, in 2016, about 26 percent of  American Indians and Alaska Natives were living below the poverty line,  compared with 14 percent for the nation as a whole.

According to EPA databases, tribes operate about 950 public drinking  water systems and about 340 public wastewater systems. Drinking  water systems often include groundwater wells, water treatment plants,  and pipelines to deliver water to homes. A regulated, centralized  wastewater system may include sewer lines, tanks, and wastewater  treatment plants or lagoons, but small, rural communities are more likely  to have decentralized wastewater systems, such as individual septic  systems. Once centralized water or wastewater systems are constructed  in Indian country, ownership is typically transferred to the tribe. A tribally  owned utility, tribal government, or a separate entity operates and  maintains the system on behalf of the tribe. Some tribal utilities charge  user fees to help offset operations and maintenance costs, but other tribal  utilities do not charge these fees because of users’ low income levels or  for cultural reasons, according to IHS and tribal officials.

According to EPA, thousands of Indian homes are not currently served by  a regulated, centralized drinking water or wastewater system, due in part  to the logistical and other challenges associated with Indian water  systems that must serve widely dispersed populations in remote  locations. Instead, as we reported in September 2017, homes that are  not served by water systems may have private wells and septic  systems, or they may be entirely unserved. According to EPA and IHS  documents, some tribal members may haul drinking water from a  regulated drinking water source. However, containers used to haul and  store the water can introduce bacteria and other contaminants. Also,  because the regulated water source in some communities may be many  miles away, residents may haul drinking water from nearby unregulated  water sources, such as streams or livestock wells. For homes without  access to a wastewater disposal system, residents may use a privy, use  honeybuckets, or discharge waste directly to the ground.

According to researchers with the Centers for Disease Control and  Prevention, restricted access to clean water for hand washing and  hygiene, along with manually disposing of waste, exposes people— especially infants and the elderly—to higher rates of illness and  hospitalization. We reported in January 2017 that such health concerns  underscore the importance of quality health care—including preventative care, such as providing safe sanitation facilities—for American Indian and  Alaska Native people. Further, according to IHS, American Indian and  Alaska Native families living in homes with satisfactory environmental  conditions, which include safe water and sewer systems, require  appreciably fewer medical services and place fewer demands on primary  health care delivery systems.

Federal Drinking Water and Wastewater Infrastructure Programs to Assist Indian Tribes

Seven federal agencies administer a number of programs that provide  assistance to tribes for drinking water and wastewater infrastructure  projects. Each agency has its own programs and processes for providing  this assistance, with some similarities. Tribes can apply to one or more  federal programs for financial assistance. In some cases, federal  agencies coordinate to jointly fund the same project if the project is too  large for one agency to fund. In other cases, agencies may work together  by separately funding different parts of a large project or different phases  of a multi-year project. Of these agencies, IHS, EPA, and USDA  administer drinking water and wastewater infrastructure programs that are  specific to Indian tribes.

IHS’s mission is to raise the physical, mental, social, and spiritual health  of American Indians and Alaska Natives to the highest level. To fulfill this  mission, IHS provides primary health care and disease prevention  services. IHS’s Office of Environmental Health and Engineering’s  Sanitation Facilities Construction program, established in 1959,  contributes to IHS’s disease prevention efforts. This program provides  technical and financial assistance to Indian tribes for the cooperative  development and construction of drinking water and wastewater systems  and support facilities. According to the Indian Health Care Amendments  of 1988, it is the policy of the United States that all Indian communities  and Indian homes, new and existing, be provided with safe and adequate  water supply systems and sanitary wastewater disposal systems as soon  as possible. IHS’s 12 regional offices, called Areas, are responsible for  working with tribes when administering the Sanitation Facilities  Construction program.

The Indian Health Care Amendments of 1988 require that IHS report  annually to Congress on the sanitation deficiency levels for Indian tribes  and communities, including, among other things, the amount of funds  necessary to raise all Indian tribes and communities to zero sanitation  deficiency. The act identifies five deficiency levels, and IHS uses a  deficiency level of 0 to represent the absence of a deficiency in its data  systems (see table 1).

To develop its annual report to Congress and identify sanitation  deficiencies in Indian communities and homes, IHS maintains two data  systems: (1) the Sanitation Deficiency System (SDS), which contains  proposed drinking water and wastewater infrastructure projects to  address identified sanitation deficiencies; and (2) the Home Inventory  Tracking System (HITS), which contains home-specific information that  complements the SDS’s project-specific information. According to IHS  program documentation, the project descriptions in the SDS are to  include information about the sanitation deficiency level that each project  will address, the project’s estimated cost, and the number of Indian  homes that the project will serve. According to IHS documents, HITS is  to include information about each Indian home that may have a sanitation  deficiency that is eligible to receive Sanitation Facilities Construction  program assistance, including the home’s geographic location and  deficiency level. Eligible homes can be located on or off reservations, but  according to IHS officials, the agency typically does not collect information about Indian homes located in large urban areas. According  to IHS program documentation, IHS uses information in HITS to track the  status of and plan for the provision of sanitation facilities for Indian  homes.

To address tribes’ identified sanitation facility needs, IHS is authorized to  construct essential sanitation facilities, including domestic and community  water supplies and facilities, as well as wastewater disposal facilities for  Indian homes, communities, and lands. Under the Sanitation Facilities  Construction program, IHS administers two primary drinking water and  wastewater infrastructure activities: one to address sanitation deficiencies  in existing homes and communities based on needs identified in the SDS,  and one to provide water infrastructure for newly constructed or recently  renovated Indian homes—these needs are not included in the SDS.  According to IHS policy, the agency selects projects to fund that address  deficiencies in existing homes based on ranked project lists contained in  the SDS, by area.

According to IHS policy, the agency can manage sanitation projects on  behalf of a tribe (direct service), or a tribe or tribal entity can elect to  manage projects. According to this policy, to implement a project under  direct service, a tribe formally requests IHS assistance, and IHS  engineers typically develop projects to include in the SDS. When IHS  selects the project to fund, the tribe decides whether it will complete the  project design and manage the construction contract or have IHS  engineers do so.

EPA provides annual grants to states to help finance drinking water and  wastewater infrastructure through its Drinking Water and Clean Water  State Revolving Fund programs, respectively. EPA sets aside a certain  percentage of the appropriations it receives for these programs to make  grants directly to Indian tribes for drinking water and wastewater  infrastructure. Nine EPA regions administer the Drinking Water  Infrastructure Grants Tribal Set-Aside and the Clean Water Indian Set- Aside programs, while states administer the State Revolving Funds.  Under the drinking water set-aside program, EPA funds projects for  community water systems that serve tribal populations, as well as for non- profit, non-community water systems owned by a tribal government that  serve a tribal population. Under the clean water set-aside program, EPA  provides funding for the planning, design, and construction of wastewater  treatment plant facilities that serve federally recognized Indian tribes,  Alaska Native villages, and certain tribes in Oklahoma. According to EPA  officials, tribes are among those eligible to receive loans from the states’  State Revolving Fund programs. In addition, EPA administers the  separate Alaska Native Villages and Rural Community Water Grant  program that awards grants to the State of Alaska to, among other things,  improve sanitation in rural and Alaska Native villages.

USDA’s Rural Utilities Service allocates a portion of its appropriation for  rural water and wastewater disposal programs to make drinking water  and wastewater infrastructure grants to Indian tribes; this is referred to as  the Native American program. USDA administers the Native American  program at the national level and works with tribes at the state office and  local level to conduct outreach and assist with the application process,  among other things. The Native American program provides grants for  water and wastewater facilities and services to rural and low-income tribal  communities “whose residents face significant health risks … due to the  fact that a significant proportion of the community’s residents do not have  access to, or are not served by, adequate affordable water supply  systems or waste disposal facilities.” In addition, USDA administers the  Rural Alaska Village Grant program, which provides grants to the State of  Alaska for development and construction of water and wastewater  systems that address dire sanitation conditions in rural or Alaska Native  villages with 10,000 or fewer people. Tribes are also eligible to receive  loans and grants for infrastructure investments from the agency’s Water  and Waste Disposal Program, which is administered by USDA’s state  offices. Tribes that are located close to the U.S.-Mexico border and that  meet the definition of a colonia are eligible for assistance from USDA’s  Colonias program, a water infrastructure grant program to serve state- designated, low-income, unincorporated areas along the border. Finally,  USDA administers a grant program to provide technical assistance and  training, and the agency makes pre-planning grants available to tribes,  organizations that serve tribes, and other recipients through multiple  programs to assist with the development of application components, such  as preliminary engineering or environmental reports.

Four additional agencies may provide drinking water or wastewater  assistance to Indian tribes through other programs not specific to drinking  water or wastewater or as authorized by statute:

HUD. HUD administers the Indian Community Development Block  Grant program, a set-aside from the agency’s Community  Development Block Grant program that is specific to Indian tribes.  Indian Community Development Block grants can be used for  construction of public facilities, provision of public services, housing,  and certain economic development projects, among other things.  HUD also awards Indian Housing Block Grants to tribes for affordable  housing activities, which may include the development and  rehabilitation of utilities, necessary infrastructure, and utility  services.

Reclamation. As authorized by statute, Reclamation provides  assistance for drinking water infrastructure in the 17 western states,  including rural water supply projects for tribes. Some of the statutes  that direct Reclamation to construct rural water supply projects for  tribes are enacted Indian water rights settlements. In addition, until  September 2016, Reclamation’s rural water supply program was  authorized to conduct appraisal investigations and feasibility studies  for proposed rural water supply projects, including those that serve  Indian tribes, but the program was not authorized to construct rural  water supply projects.

Corps. As authorized by statute, the Corps may provide designated  communities, counties, and states with design and construction  assistance for drinking water and wastewater infrastructure. For  example, Congress has authorized and made appropriations for  the Corps to provide assistance to Indian tribes for water-related  environmental infrastructure projects—including wastewater treatment  facilities and water supply, storage, treatment, and distribution  facilities—through the Corps’ Section 219 Environmental  Infrastructure Program.

EDA. EDA’s Public Works Program provides grants to economically  distressed areas to, among other things, help rehabilitate, expand,  and improve their public works facilities, including drinking water and  wastewater facilities. The Economic Adjustment Assistance  Program provides grants for, among other things, development of  public facilities, including drinking water and wastewater facilities.  EDA’s Planning Program provides grants to various entities, including  tribes, to pay the costs of economic development planning, which can  include planning for water infrastructure.

Prior GAO Work on Interagency Collaboration

As part of our body of work on interagency collaboration, our September  2012 report discussed a variety of mechanisms to implement interagency  collaborative efforts and identified key features that all efforts benefit  from. Mechanisms to implement interagency collaborative efforts  include establishing interagency task forces or signing memorandums of  understanding. Key features, many of which are related to practices to  enhance and sustain collaboration identified in our previous work, fall into  the following categories: outcomes and accountability, bridging  organizational cultures, leadership, clarity of roles and responsibilities,  participants, resources, and written guidance and agreements.

Federal Agencies Estimated About $3 Billion in Existing Tribal Drinking Water and Wastewater Infrastructure Needs in Fiscal Year 2016, but the Needs Are Underestimated

IHS and EPA estimated costs for tribal water infrastructure needs, with  IHS identifying at least $3.2 billion in estimated costs for infrastructure  projects to address existing drinking water and wastewater infrastructure  needs for fiscal year 2016 and EPA estimating the costs of future tribal  drinking water infrastructure needs at an additional $2.4 billion over the  following 20 years. However, IHS’s estimate of existing needs is likely too  low because IHS has not identified all eligible Indian homes that may  have existing sanitation deficiencies—drinking water or wastewater  infrastructure needs—and some data in the system that IHS uses to track  home-specific infrastructure needs are not accurate.

IHS and EPA Have Estimated Several Billion Dollars in Existing and Future Tribal Water Infrastructure Needs

In fiscal year 2016, IHS identified about $3.2 billion in estimated costs for  projects to address existing tribal drinking water and wastewater  infrastructure needs. This estimate represented more than 2,000 projects  in the SDS to address 373 tribes’ existing drinking water and wastewater  infrastructure needs. To develop these projects, IHS policy directs area  staff to invite all federally recognized tribes to identify existing drinking  water and wastewater infrastructure needs each year. IHS staff then  work with interested tribes to develop projects, including cost estimates,  to include in the SDS. In fiscal year 2016, projects to address deficiency  levels 4 and 5—homes or communities that lack a safe drinking water  supply or wastewater disposal system, or both—accounted for  $1.6 billion, or about half, of the total estimated costs of tribal  infrastructure needs in the SDS. More than 80 percent of the deficiency  level 4 and 5 project costs were located in the IHS Alaska and Navajo  areas. In addition, in fiscal year 2016, IHS determined that more than  60 percent of the total existing drinking water and wastewater  infrastructure needs in the SDS were infeasible, mostly due to the  significant costs associated with infeasible deficiency level 5 projects.

EPA collects and reports data on the drinking water infrastructure needs  of the nation’s public water systems, including the future needs of tribally  owned or operated drinking water systems. Specifically, EPA is required  to assess capital improvement needs of all eligible public water systems  every 4 years, and EPA has conducted its Drinking Water Infrastructure  Needs Survey and Assessment to obtain this information every 4 years  from 1995 through 2015. EPA last reported in 2013 on the estimated  costs of capital improvement projects needed to repair, replace, and  upgrade existing tribal and other public drinking water systems over the  following 20 years. In its 2013 report, EPA estimated the costs of future  tribal drinking water needs of public systems at approximately  $2.4 billion. EPA does not, and is not required to collect information  about future tribal wastewater infrastructure needs.

Other agencies that provide tribes with assistance for drinking water or  wastewater infrastructure projects do not—and are not required to— systematically identify tribal drinking water or wastewater infrastructure  needs. For example, USDA officials explained that tribes identify needs  through the applications they submit to the agency’s programs. These  officials stated that they also identify tribal needs through outreach to  tribes and coordination with other agencies, such as IHS. In addition,  HUD officials said that they do not collect information specifically about  tribal water infrastructure needs because they rely on the tribes to  propose or identify projects to meet any needs based on the tribes’  priorities.

IHS Underestimates Existing Tribal Water Infrastructure Needs Because IHS Has Not Identified All Eligible Homes with Infrastructure Needs and Relevant Data Are Not Accurate

IHS area staff work with tribes each year to (1) identify Indian homes  eligible for and in need of IHS drinking water or wastewater infrastructure  assistance to include in IHS’s home-specific tracking system, HITS; and  (2) develop projects aimed at correcting any identified sanitation  deficiencies in these homes to include in the SDS. Through this process,  IHS has entered information about hundreds of thousands of eligible  Indian homes in HITS and developed thousands of projects in the SDS.  According to agency documents, HITS is to include information about  each Indian home that is eligible to be served by the Sanitation Facilities  Construction program and that may have an existing sanitation  deficiency. However, based on our review of IHS documentation and  interviews with IHS officials, HITS does not contain all eligible Indian  homes that may have existing sanitation deficiencies, and some data in  the system are not accurate.

HITS Does Not Contain All Eligible Indian Homes That May Have Existing Water Infrastructure Needs

According to IHS officials, as of February 2018, HITS contained  information for about 406,000 Indian homes. However, according to IHS  area officials, the system does not contain information about all Indian  homes eligible to be served by the Sanitation Facilities Construction  program. For example, Oklahoma City Area officials we interviewed  estimated that, based on Census data and their professional experience,  more than 100,000 Indian homes in their area may be eligible for IHS  program assistance but are not included in the system, and an unknown  number of those homes likely have existing drinking water and  wastewater infrastructure needs. These officials, as well as tribal  officials administering the Sanitation Facilities Construction program for  their tribes in Oklahoma, said that the system does not contain all eligible  Indian homes, in part because it is difficult to identify where tribal  members are living since most of the communities in the state are a  mixture of tribal and non-tribal residents and are not located on  reservations. In addition, Portland Area officials stated that they believe  the system is missing an unknown number of eligible Indian homes in  their area because it is challenging to identify eligible homes that are in  scattered locations away from tribal community facilities. In contrast,  Navajo Area officials said they believe the system is more than  95 percent complete for their area, in part because the area aligns with  the Navajo Nation’s lands.

IHS headquarters officials stated that they do not expect HITS to capture  all eligible Indian homes, in large part because some tribes have chosen  to not provide such information to IHS for cultural or other reasons. These  officials said they are focused on working collaboratively with tribes to  identify homes that have existing deficiencies rather than all homes  eligible for services but added that IHS areas are expected to identify  such homes during the normal course of their work. IHS area officials and  tribal officials we interviewed stated that identifying eligible Indian homes  not located on reservations is resource intensive, and they do not have  sufficient resources to locate these homes. IHS Oklahoma City Area  officials said it would be helpful to find efficient ways to identify additional  eligible homes that may have sanitation deficiencies. For example, these  officials said they have started using EPA data to target communities with  water systems that do not meet EPA’s water quality standards and  identify eligible homes within those communities, but they have made  limited progress with their existing resources.

Standards for Internal Control in the Federal Government calls for  management to use quality information to achieve the entity’s objectives;  such information is appropriate, current, complete, accurate, accessible,  and provided on a timely basis. We recognize that it would be resource  intensive for IHS to locate every eligible Indian home to include in HITS,  but because the system may not contain roughly 20 percent of eligible  Indian homes, opportunities exist for IHS to identify in a targeted, efficient  way additional homes with existing deficiencies to include in HITS. By  implementing a targeted, resource-efficient method to identify additional  eligible Indian homes that may have existing sanitation deficiencies to  include in HITS, IHS could have better assurance that it has more  complete information to help improve its estimate of the number of eligible  Indian homes that may need sanitation facilities assistance.

Deficiency Levels Are Not Accurate For Every Home in HITS

Deficiency levels for thousands of homes may not be accurately captured  in HITS. IHS headquarters officials stated that, as of February 2018, of  the roughly 406,000 total tribal homes in HITS, about 229,400 homes had  a deficiency level of 0. Therefore, the remaining approximately  176,600 tribal homes had deficiency levels 1 through 5. HITS  automatically assigns a deficiency level 0 to each home when IHS enters  it into the system, and homes remain at a deficiency level 0 until IHS  develops projects in the SDS to serve those homes. HITS does not  provide IHS with the option of recording a home’s deficiency level as  unassessed, so a deficiency level 0 could indicate that there is no  deficiency or that the home has not yet been assessed to determine a  deficiency.

IHS area officials we interviewed stated that they were aware of homes  with sanitation deficiencies that were not accurately reflected in HITS. For  example, Phoenix Area staff said they knew of homes with a deficiency  level 4 or 5 that had a deficiency level 0 in HITS because these homes  were not yet included within the scope of an SDS project. Also,  California Area officials estimated that they had not assessed deficiency  levels for about 20,000 eligible homes in their area, and Oklahoma City  Area officials said they had not assessed more than 100,000 homes in  their area—these homes’ deficiency levels all appeared as deficiency  level 0 in HITS, but their actual deficiencies were unknown.

According to IHS officials, there are multiple ways to assess homes’  deficiency levels. For homes that are not connected to a public water  system, such as homes with private wells, IHS staff may need to visit  homes to identify any existing deficiencies, with permission of the tribe.  For homes connected to a public water system, staff can assign the  homes the deficiency level associated with the water system but may  need to visit the community to assess the system’s overall deficiency  level. IHS officials from the California and Oklahoma City areas said they  did not have the staff resources to begin the process of identifying  whether the deficiency level 0 homes in their areas had deficiencies and  developing projects for the SDS to serve them.

IHS headquarters officials stated that they have identified homes that the  Sanitation Facilities Construction program has served since implementing  HITS in 2015. For example, IHS officials stated that of the about  229,400 homes with a deficiency level 0 in HITS, they had determined  that about 90,700 correctly show that deficiency level because they have  been included in a project in the SDS since 2015. IHS had not included  the remaining approximately 138,700 homes with a deficiency level 0 in  a project in the SDS. Therefore, using HITS, IHS could not determine if  these homes had (1) no deficiency, (2) a deficiency that IHS addressed  prior to 2015, or (3) an unknown deficiency because the homes had not  been assessed.

IHS officials stated that in the future they will be able to use HITS to better  track the agency’s service and project history at the individual home level.  However, IHS officials did not explain what steps they would take to  identify deficiencies for the approximately 138,700 homes in HITS that  had not been included in an SDS project. Standards for Internal Control in  the Federal Government calls for management to use quality information  to achieve the entity’s objectives; such information is appropriate, current,  complete, accurate, accessible, and provided on a timely basis. IHS  officials said that improving the system’s accuracy would be beneficial. By  implementing a mechanism to indicate in HITS whether each home with a  deficiency level of 0 has been assessed, IHS could also have more  efficient ways to take steps to address the deficiencies of the homes  contained in HITS.

Federal Agencies Provided Funding for Tribal Water Infrastructure Projects, but Processes May Not Prioritize Projects That Address the Most Severe Deficiencies

In fiscal year 2016, federal agencies obligated approximately $370 million  for tribal drinking water or wastewater infrastructure projects. The  agencies with tribal-specific programs for drinking water and wastewater  infrastructure—IHS, EPA, and USDA—funded some projects to address  what they identified as the most severe sanitation deficiencies— communities and homes that do not have safe drinking water or  wastewater disposal facilities. However, the agencies’ processes may not  always prioritize projects that address the most severe sanitation  deficiencies. In addition, during the course of our review, we identified  issues with how USDA awarded grants under its Rural Alaska Village  Grant program.

Federal Agencies Provided About $370 Million in 2016 for Tribal Water Infrastructure Projects

In fiscal year 2016, federal agencies provided about $370 million to  develop, construct, or repair tribal drinking water and wastewater  infrastructure projects to address tribes’ needs. This amount represents  about 11 percent of the more than $3 billion in total existing tribal drinking  water and wastewater infrastructure needs that IHS identified in 2016.  Appendix III contains additional detail about agency obligations for tribal  drinking water and wastewater infrastructure projects for fiscal years 2012  through 2016.

Federal agency obligations were used to address a variety of tribal  drinking water and wastewater infrastructure needs. For example,  IHS, EPA, USDA, and the State of Alaska provided approximately  $15.9 million for multiple, phased projects to bring first-time, in-home  piped drinking water and wastewater service to approximately 90 homes  in the Native Village of Eek in Alaska (see fig. 1). The residents of Eek  obtain their drinking water by hauling water from the village washeteria,  a building that contains toilets, washing machines, and a spigot for  purchasing water for use in the home. Most homes in the community do  not have piped water or sewer service to kitchens or bathrooms, and  residents use washbasins for handwashing and food preparation and  honeybuckets for wastewater disposal. As of April 2017, construction was  ongoing, and officials estimated that the entire community of about  300 people would be served by the fall of 2018. See appendix IV for other  examples of tribal drinking water and wastewater infrastructure projects  that we visited.

In addition to providing financial assistance for projects to design or  construct water infrastructure, federal programs provided grants for  technical assistance and training for tribal utilities and staff. For example,  in fiscal year 2016, USDA awarded a $130,000 grant from its Technical  Assistance and Training program to one organization that works with  tribes. USDA also awarded a contract to the National Rural Water  Association for it to employ a network of technical consultants who can  provide on-site technical assistance to eligible systems, including tribally  operated systems experiencing day-to-day operational issues, among  other challenges.

Federal programs mostly did not provide financial assistance for routine  operations and maintenance of installed community or individual  infrastructure. Tribal officials we interviewed, however, said that paying  for operations and maintenance is often the tribe’s biggest challenge once  a system is constructed or upgraded. For example, officials from one tribe  said that the tribe did not have sufficient resources to operate and  maintain a newly constructed water treatment system. Tribal officials we  interviewed stated that their members are often unable to afford the utility  fees needed to support the water system. For private systems, officials  from two tribes said some of their members have trouble maintaining new  drinking water filtration and septic systems because, for example, the  systems are technically complex and costly to maintain. Officials from  another tribe said homeowners who have difficulty operating and  maintaining a system may return to using an unsafe drinking water source  they previously used, for example. According to IHS officials, the agency  has been collaborating with EPA, USDA, and tribes to improve collection  of information about the cause of some systems’ premature failure and to  analyze best practices for operations and maintenance of tribal water  systems.

Agencies Funded Some Projects to Address the Most Severe Sanitation Deficiencies

Agencies with tribal-specific programs for water infrastructure—IHS, EPA,  and USDA—selected and funded projects that address the most severe  sanitation deficiencies. Three of these agencies’ programs—IHS’s  Sanitation Facilities Construction, EPA’s clean water set-aside, and  USDA’s Native American program—documented in regulation or policy  their goal of funding projects to address these needs. Specifically,  according to IHS’s Sanitation Facilities Construction program policy, the  program’s goal includes providing funding first and in greater degree to  homes and communities with the greatest needs, that is, those that lack  safe drinking water or wastewater disposal, or both. EPA’s clean water  set-aside program policy states the program’s goal is to protect public  health in Indian country by addressing the lack of access to sanitation  facilities (i.e., deficiency levels 4 and 5 for IHS and EPA). Finally, under  the applicable requirements and policy, USDA’s Native American  program’s objective is to provide water and waste disposal facilities and  services to low-income rural communities whose residents face significant  health risks. The program’s goal includes funding the neediest projects,  giving priority to areas that lack running water, flushing toilets, and  modern sewage disposal systems.

According to agency policy, IHS’s Sanitation Facilities Construction  program and EPA’s clean water set-aside program prioritize and select  projects to fund according to the projects’ rankings in each IHS area’s  SDS list. To create the ranked lists, IHS staff assign scores to each  project based on a set of eight scoring factors, each with a different  number of points that may be assigned to a project (see table 2).

USDA prioritizes and selects projects to fund from its Native American  program using a different process than IHS and EPA. USDA’s process  involves tribes, working with USDA state offices, submitting project grant  applications to the headquarters office. USDA state offices score project  applications before submitting them to the headquarters office. USDA  policy directs the program to make funds available according to priority,  and the agency accepts and evaluates applications and awards grants  throughout the year. USDA officials said the program maintains a wait list  for eligible applications received after all available funds have been  obligated each year. According to USDA’s scoring sheet for the Native  American program, the agency evaluates project applications based on a  set of five scoring factors, each with a different number of points to award.  These scoring factor categories include population, income, joint  financing, and discretionary points that can be awarded at state offices  and headquarters (see table 3). USDA officials said that they also take  SDS deficiency levels into account when reviewing project applications,  but that the statute authorizing the Native American program does not  specifically reference IHS’s deficiency level definitions.

Using their respective processes to prioritize and select projects for  funding, IHS’s Sanitation Facilities Construction program, EPA’s clean  water set-aside program, and USDA’s Native American program  obligated a total of nearly $110 million in fiscal year 2016 for projects to  meet a mixture of needs. For example, for approximately 190 projects  from the SDS that IHS, EPA, and others funded in fiscal year 2016, about  40 percent were projects to address deficiency levels 2 and 3, and about  60 percent were projects to address deficiency levels 4 and 5. Further,  in fiscal year 2016, USDA reported that its Native American program  funded four projects that provided new drinking water and wastewater  service to some tribal communities and funded nine projects that  replaced, renovated, or expanded existing infrastructure. Based on our  review of IHS and USDA documents, deficiency level 2 and 3 projects as  well as replacement and renovation projects can address important water  quality and other problems, but they generally do not address the most  severe deficiencies or the most significant health risks.

Based on our review of IHS and EPA documents and interviews with  these agencies’ officials, we found that their process for prioritizing and  selecting projects to fund from the SDS can discourage funding some  deficiency level 4 and 5 projects, especially those with a relatively high  cost per home. According to some IHS area officials we interviewed,  applying IHS’s scoring factors and the points associated with each factor  means that deficiency level 3 projects may score higher than—and  therefore receive funding before—deficiency level 4 or 5 projects. For  example, a project’s cost per home is a significant contributor to its score  because IHS assigns as low as minus 20 points for projects that have a  relatively high cost to implement per home. IHS officials said that,  typically, deficiency level 3 projects replace existing community  infrastructure and serve more homes, which makes those projects’  relative cost per home lower than deficiency level 4 and 5 projects. IHS  headquarters officials explained that they developed the SDS scoring  system in consultation with tribes so the system could balance the need  to fund deficiency level 4 and 5 projects with the need to fund projects  with lower deficiencies that address health needs and serve a larger  number of homes. However, because deficiency level 4 and 5 projects  may rank lower than some projects that address less severe deficiencies  and rank too low to be funded in a given year, hundreds of feasible  projects to address the most severe sanitation deficiencies have  remained on SDS lists for 5 years or more, based on our review of these  lists. As of the end of fiscal year 2016, many of these projects had not  been selected for funding from IHS or EPA.

IHS headquarters officials said that the agency is working to improve the  extent to which it funds feasible projects to address the highest sanitation  deficiencies. For example, these officials said that they are updating the  2003 Sanitation Facilities Construction program guidelines to incorporate subsequently issued guidance, and this update should also more directly  align the guidelines with the program’s original focus—to prioritize service  to Indian homes and communities that lack access to piped water and  sewer systems. However, a senior IHS official said that changing the  SDS scoring factors is not part of this effort because the current scoring  factors balance a number of interests in addition to projects’ deficiency  levels. The official said that higher deficiency level projects ranking lower  than other projects on the SDS list in a given year does not mean that  public health needs are going unaddressed. Yet, our analysis shows that  projects to address the highest deficiency levels have remained in the  SDS for many years. We recognize that IHS faces trade-offs when  selecting tribal infrastructure projects to fund. By reassessing the point  distribution across the SDS scoring factors as part of IHS’s program  guidelines update, in light of trade-offs between funding projects that  address the most severe sanitation deficiencies and projects that meet  other needs, IHS may have better assurance that its projects address the  most severe sanitation deficiencies in Indian communities.

Regarding USDA’s Native American program, based on our review of  agency documents and interviews with USDA officials, we found that the  agency’s process for prioritizing and selecting projects may not provide  USDA with reasonable assurance that it is selecting projects to fund that  address the most severe sanitation deficiencies. Specifically, USDA’s  scoring factors for its Native American program do not include a scoring  factor category to evaluate the extent to which projects will address health  risks that stem from tribes’ lack of drinking water and wastewater  infrastructure. In contrast, USDA prioritizes projects to fund under its  Colonias grant program using an additional scoring factor that awards  points based on the extent to which a proposed project will address  health risks stemming from lack of safe drinking water and wastewater  disposal in a colonia. For example, USDA awards 50 points for projects  in colonias where a lack of access to safe drinking water and wastewater  disposal results in a significant health risk. We recommended in  December 2009 that USDA take steps to better target its limited funds  for the Colonias program, and USDA responded in part by creating the  additional scoring factor for colonias to ensure that the neediest colonias  receive funding.

To prioritize Native American program applications that address  significant health risks, USDA officials said they use discretionary points.  However, according to program policy, USDA state office and  headquarters officials may award discretionary points to meet other  purposes that are not related to addressing health risks, such as  encouraging projects with green infrastructure or promoting geographic  diversity among grantees, or they may not award these points at all. As a  result, USDA may not have reasonable assurance that it is consistently  evaluating or funding project applications in a way that aligns with the  Native American program’s goal. USDA policy states that both the Native  American and Colonias programs are to prioritize areas that lack running  water, flushing toilets, and modern sewage disposal systems. By  implementing a scoring factor similar to the one in the Colonias  program—that is, one that awards points for proposed projects that  address health risks from a lack of access to safe drinking water and  wastewater disposal—for the Native American program, USDA would  have more assurance that it is evaluating project applications consistently  and funding projects to address the most severe sanitation deficiencies in  Indian communities, consistent with the program’s goal.

USDA Did Not Always Award Rural Alaska Village Grants to Authorized Recipients, and the Program’s Regulations Are Inconsistent with Its Authority

During the course of reviewing funding for tribal drinking water and  wastewater infrastructure projects, we encountered several issues with  one of USDA’s tribal drinking water and wastewater infrastructure  programs, the Rural Alaska Village Grant program. Specifically, section  306D of the Consolidated Farm and Rural Development Act authorizes  USDA to make grants to the State of Alaska for the benefit of rural or  Native villages to provide for the development and construction of  drinking water and wastewater systems. According to USDA reports,  these grants are used for projects that have provided, for example, rural  Alaska Native residents with access to safe drinking water and flush  toilets in their homes. From the program’s beginning in fiscal year 1997  through fiscal year 2016, USDA awarded 455 grants totaling more than  $444 million to provide safe drinking water and wastewater disposal to  thousands of Alaska Natives in remote communities.

We found that from fiscal year 1997 through fiscal year 2016, USDA  awarded 159 Rural Alaska Village grants totaling about $157 million to  recipients not authorized by section 306D. These recipients were Alaska  Native villages, municipalities, and the Alaska Native Tribal Health  Consortium, which is the tribal organization that administers IHS’s  Sanitation Facilities Construction program in Alaska. USDA’s  appropriations acts for fiscal years 2012 through 2017, however,  authorized USDA to provide Rural Alaska Village grants to the  Consortium. Of the 159 grants, USDA awarded 127 grants (about  $121 million) to municipalities and Alaska Native villages from 1997  through 2016, and it awarded 32 grants (about $36 million) to the  Consortium in 2011 before first receiving authority to do so in fiscal year  2012. Based on our review of a list of USDA grant agreements, selected  agreements, and according to agency officials, in 2011, USDA signed  32 such agreements with the Consortium and the communities on whose  behalf the Consortium administered the grants. USDA officials stated that  the agency made seven total obligations to the Consortium in 2011 for  these grants.

USDA officials stated that they did not agree that the agency had  awarded Rural Alaska Village grants to ineligible entities because the  program’s authorizing statute gives the State of Alaska control over the  use of the grants, and the state concurred with USDA making some  grants directly to other parties. For example, the USDA officials stated  that a 2011 memorandum of agreement between USDA, the State of  Alaska, IHS, and the Consortium was a vehicle for the state to direct a  portion of the Rural Alaska Village grants to other parties. These officials  stated that since the statute does not prevent the state from redirecting  portions of the grant to other parties, it is not improper for USDA to enter  into an agreement with the state to award the grants directly to other  parties so that the state does not have to redirect them. In commenting on  a draft of this report, USDA noted that the agency has awarded two  grants to municipalities since signing the 2011 agreement.

In addition, USDA officials said that they entered into the memorandum  of agreement and began awarding grants to the Consortium in 2011 to  address problems with the program’s administration, which resulted in  projects that were delayed or halted. For example, USDA stated in a 2010  report that the State of Alaska had not adequately documented project  costs and that USDA staff were concerned that the state had not applied  the obligations it received from USDA to the intended communities.  According to USDA officials, they have seen a significant improvement in  the state’s grant administration and more timely delivery of projects since  the 2011 agreement. In addition, the Rural Alaska Village Grant program  manager said the agency awards grants directly to Native villages that  have the capacity to administer them. In commenting on a draft of this  report, USDA stated that the agency has made all grants to the  Consortium pursuant to the 2011 memorandum of agreement.

The State of Alaska can choose to make subgrants once it receives the  Rural Alaska Village grant, but section 306D of the Consolidated Farm  and Rural Development Act only authorizes USDA to award grants to the  State of Alaska. Moreover, the 2011 memorandum of agreement cannot  authorize USDA to award grants to recipients that are not authorized by  statute. By ensuring that all Rural Alaska Village grants are awarded only  to recipients identified as eligible in section 306D or USDA appropriations  acts, USDA will have assurance that it is complying with the law. If USDA  wants to award Rural Alaska Village grants to municipalities and Alaska  Native villages, it should seek authority to do so, as it did to award such  grants to the Consortium.

In addition, the regulations governing the Rural Alaska Village Grant  program identify rural or native villages in Alaska as eligible grant  recipients. USDA officials explained that the agency amended the Rural  Alaska Village Grant program regulations in 2015 to codify the 2011  memorandum of agreement. However, this regulation identifying rural  and Alaska Native villages as eligible grant recipients expands USDA’s  authority to award grants beyond the existing statutory authorities, which  do not list rural or Alaska Native villages as eligible recipients. Until  USDA amends the Rural Alaska Village Grant program regulations to  be consistent with USDA’s authority, the agency’s regulations will  continue to recognize recipients not authorized by statute.

The Extent to Which Federal Agencies Collaborated to Meet Tribes’ Water Infrastructure Needs Varied at the National Level and in Six Selected States

Most of the seven federal agencies that administer programs to provide  drinking water and wastewater infrastructure assistance to Indian tribes  have taken actions to collaborate at the national level, and the agencies  have identified additional opportunities to collaborate. At the regional  level, seven federal agencies we surveyed reported collaborating on a  range of activities within six selected states—with some agencies  frequently working together and others rarely collaborating—and the  agencies identified opportunities to increase collaboration at the regional  level to better serve tribes.

Most Reviewed Agencies Have Taken Actions to Collaborate at the National Level on Tribal Water Infrastructure and Have Identified Additional Opportunities to Increase Collaboration

Most of the seven federal agencies we reviewed have taken actions to  collaborate at the national level and identified additional opportunities to  collaborate that they have not yet taken. In our previous work, we found  that achieving important national outcomes—such as providing access to  safe drinking water and wastewater disposal—often requires coordinated  and collaborative efforts of a number of programs spread across the  federal government. For example, IHS, EPA, USDA, HUD, and  Reclamation have formed a national tribal infrastructure task force to  facilitate the agencies’ collaborative efforts when providing services,  support, and technical assistance to tribes.

The tribal infrastructure task force’s efforts reflect some of the key  features that we have found all collaborative mechanisms benefit from in  our previous work:

Written guidance and agreements. We have previously reported  that agencies that articulate their agreements in documents can  strengthen their commitment to working collaboratively. The  members of the tribal infrastructure task force first documented their  agreement in a memorandum of understanding in 2007, the year the  task force was created. The agencies updated the memorandum most  recently in 2013, and they use the document to formally agree on the  group’s common goal and purposes and to clarify and define roles  and responsibilities. Having participating agencies document their  agreements on how they will be collaborating, and continually  updating and monitoring these agreements, are practices that are  consistent with our prior work.

Outcomes and accountability. In our previous work, we have  reported on the importance of groups having clear goals. In its 2013  memorandum of understanding, the tribal infrastructure task force  identified a common goal of improving access to safe drinking water  and basic sanitation for American Indians and Alaska Natives. In the  memorandum, the member agencies also agreed on the task force’s  stated purposes, one of which is to enhance the efficient leveraging of  funds.

Leadership. We have found that identifying one agency as the leader  of a collaborative group is often beneficial because it centralizes  accountability and can speed decision making. EPA has served as  the federal focal point for the task force; this has included hosting the  task force’s website that serves as a common source for documents  the group has produced. According to an official involved with the task  force, EPA’s role has provided continuity in leadership.

The task force’s efforts have yielded some specific results. For example,  in 2013, tribal infrastructure task force members agreed to adopt a  uniform preliminary engineering report template, a key supporting  document that multiple agencies require in their project application and  evaluation processes. Task force members created this template in part  in response to our October 2012 recommendation that EPA and USDA  develop such a document. According to agency officials we interviewed,  the report template has been helpful for tribes since they no longer have  to produce different versions of the same document when submitting  multiple applications to different agencies. USDA officials said they have  since worked with other agencies to develop an online version of the  preliminary engineering report that is accessible to task force members  and others to further improve collaboration.

However, according to agency officials involved with the task force, there  may be additional opportunities to improve the efficiency of their  collaboration at the national level. For example, in 2011, a workgroup of  the task force identified a series of 10 options to increase the efficiency of  collaboration by streamlining their application processes. As of  November 2017, according to agency officials, the task force had not  acted on most of the options. One such option was for agencies to better  align their different funding and application cycles where possible.  Several tribal officials and representatives from a tribal organization we  interviewed cited challenges with complying with the agencies’ different  application requirements. For example, they said that doing so can be  resource intensive and can make it difficult to obtain funds for one project.  Other tribal officials we interviewed also identified ways that agencies could improve their collaboration that would benefit tribal applicants and  that the task force did not identify in its 2011 report. For example, various  tribal officials suggested that agencies standardize federal program  application processes and coordinate their outreach to tribes to discuss  agency programs and their requirements.

According to an agency official involved with the task force, when the  group considered which options from the 2011 report to implement,  member agencies focused their efforts on implementing those that were  most achievable given the agencies’ limited resources. Other officials  also said that it would be worthwhile to reconsider some of the options  identified in the report. As stated in the task force’s 2013 memorandum of  understanding, one of its purposes is to enhance the member agencies’  efficient leveraging of funds. By reviewing the 2011 task force report and  identifying and implementing additional actions to help increase their  collaboration, the task force member agencies could improve their ability  to leverage limited program funds.

Federal Agencies’ Regional Offices Collaborated to Varying Extents within Six Selected States and Reported That Additional Collaboration Would Be Beneficial

The regional offices of the seven federal agencies we surveyed  collaborated with each other to varying extents in the six selected states  (Alaska, Arizona, California, New York, Oklahoma, and South Dakota).  In the 2013 memorandum of understanding, the tribal infrastructure task  force member agencies—IHS, EPA, USDA, HUD, and Reclamation— agreed that they are expected to collaborate at the regional level to  achieve a common goal of providing safe drinking water and basic  sanitation for tribes. However, based on our review of agency survey  responses, these agencies did not always collaborate in each of the six  states. We measured agency collaboration in terms of the number of  instances in which one agency regional office reported using a  collaborative mechanism with another agency. These collaborative  mechanisms include state- or project-level working groups,  memorandums of understanding, and shared databases, among others.  In responses to our survey, we found that the number of instances of  agency regional offices reporting that they used one or more collaborative  mechanism with other agencies varied across the six states. For  example, the agencies’ regional offices collaborated the most in Alaska  and the least in New York and Oklahoma. Figure 2 shows the  percentage of instances where an agency reported using a collaborative  mechanism with another agency when jointly working on tribal drinking  water and wastewater activities in the six states, out of the total possible  instances. Appendix II contains additional details about our survey and  agency responses.

In responses to our survey, certain agencies’ regional offices reported  collaborating with each other in some states but not in other states. For example, EPA and USDA regional offices both reported working together  in Alaska, Arizona, and California, but not in New York, Oklahoma, or  South Dakota. IHS and HUD reported collaborating with each other in  three states but not in the other states. Not all agencies work with tribes in  every state. For example, Reclamation does not operate in Alaska or New  York, so we did not survey the agency in those states. The Corps’  regional offices responded that they are not authorized to work on  drinking water or wastewater infrastructure with tribes in two of the six  states. In contrast, IHS and EPA regional offices reported collaborating  with each other in all six states, the most of any agency pair.

In their responses to our survey and in interviews, the seven federal  agencies’ regional offices most frequently identified three key factors that  limited how much they collaborated in the six states. Specifically:  Incompatibility of agency policies and missions. Agencies’  regional offices reported that having incompatible policies or agency  missions was a factor that had hindered their collaboration with other  agencies. For example, IHS and HUD regional offices in four states  reported that a restriction on IHS’s ability to serve new homes  constructed with grants from HUD’s housing programs limited their  collaboration. Several agencies’ regional offices reported that  having compatible policies helped their collaboration. For example,  IHS and USDA regional offices in Alaska responded that multiple  agencies’ use of IHS’s SDS list as a common source for identifying  potential projects to fund has helped collaboration. We previously  found that adopting compatible policies and procedures is one way for  agencies to establish means of operating across agency  boundaries.

Insufficient resources. An additional factor that hindered agencies’  collaboration was insufficient staff and financial resources. For  example, HUD and IHS regional officials we interviewed in Arizona  said that a state-level tribal infrastructure working group they were  involved in became inactive in 2016, after the lead agency determined  it was unable to continue dedicating staff resources to that role and  none of the other agencies picked up the lead. In contrast, several  IHS and EPA regional offices reported that the existence of standard  interagency agreements that facilitate transferring EPA funds to IHS  helped them collaborate and leverage funding for projects that each  agency would not have funded on its own. Identifying and leveraging  the resources needed to initiate or sustain a collaborative effort is a  key consideration for implementing the interagency collaborative  mechanisms we previously identified.

Absence of personal relationships. Agencies’ regional offices also  reported that the absence of relationships with staff from other  agencies hindered their collaboration. In contrast, agencies’ regional  offices reported that having good working relationships with staff from  other agencies helped their collaboration. For example, USDA’s  regional office and the State of Alaska reported that their strong  relationships with each other and other agencies in Alaska helped  their collaboration, and that these relationships were enhanced by  agency staff’s frequent communication through regular meetings. We  previously found that having positive working relationships can bridge  organizational cultures and build trust.

In their responses to the survey and in interviews, several agencies’  regional offices identified examples of inefficiencies that have occurred  when they did not collaborate, including inefficient use of their limited  resources. For example, officials from one EPA region we interviewed  said that there have been years when EPA staff spent time developing a  project only to learn that USDA had already funded the same project. The  officials stated that this inefficiency could have been avoided if they had  been communicating with their USDA counterparts about the projects that  each agency was considering to fund. Also, in two states, EPA’s regional  office reported that EPA and USDA may be missing opportunities to  leverage funding for individual projects by not sharing information about  projects.

In all six states, nearly all of the federal agency regional offices  responded that it would be beneficial to increase their collaboration.  Specifically, more than 90 percent of the federal agency respondents  identified at least one collaborative mechanism that would be beneficial  for them to begin using with another agency. The specific mechanisms  that the agencies identified appeared to relate to the amount of  collaboration in which they had already engaged. For example, agency  regional offices that reported not having collaborated with another agency  most frequently said that it would be beneficial to begin having informal  communications with their counterparts in other agencies and to start  sharing project-specific documents such as preliminary engineering  reports. Alternatively, agency regional offices that reported having  collaborated with another agency most frequently responded that it would  be beneficial to begin using a memorandum of understanding as an  additional mechanism for collaborating where they had not already done  so. In the tribal infrastructure task force’s 2013 memorandum of  understanding, the member agencies—IHS, EPA, USDA, HUD, and  Reclamation—agreed that they are expected to collaborate at the  regional level to provide safe drinking water and basic sanitation for tribes  and to more efficiently leverage program funds. By directing their regional  offices to identify and pursue additional mechanisms to increase their  collaboration, the task force member agencies would have better  assurance that their regional offices are efficiently leveraging limited  program funds and following through on the commitment to collaborate.

Identifying and addressing drinking water and wastewater infrastructure  needs in Indian country is a difficult undertaking. IHS dedicates a  significant effort each year to working with tribes to identify their existing  drinking water and wastewater infrastructure needs. However, one of  IHS’s systems—HITS—may be missing tens of thousands of eligible  Indian homes, an unknown number of which may have existing sanitation  deficiencies. Additionally, some homes’ deficiency levels in HITS are  inaccurate. By implementing a targeted, resource-efficient method to  identify additional eligible Indian homes that may have existing sanitation  deficiencies to include in HITS, IHS could have better assurance that it  has more complete information to help improve its estimate of the number  of eligible Indian homes that may need sanitation facilities assistance.  Also, IHS officials said that improving the system’s accuracy would be  beneficial. By implementing a mechanism to indicate in HITS whether  each home with a deficiency level of 0 has been assessed, IHS could  also have more efficient ways to take steps to address the deficiencies  of the homes contained in HITS.

IHS and USDA funded some projects to address the most severe  sanitation deficiencies, but residents of many Indian homes remain  without safe drinking water or wastewater disposal as the agencies also  prioritized and funded projects that addressed other needs. We recognize  that IHS faces trade-offs when selecting tribal infrastructure projects to  fund. By reassessing the point distribution across the SDS scoring factors  as part of IHS’s program guidelines update, in light of trade-offs between  funding projects that address the most severe sanitation deficiencies and  projects that meet other needs, IHS may have better assurance that its  projects address the most severe sanitation deficiencies in Indian  communities. Also, by USDA implementing a scoring factor similar to the  one in its Colonias program—that is, one that awards points for proposed  projects that address health risks from a lack of access to safe drinking  water and wastewater disposal—for the Native American program, USDA  would have more assurance that it is evaluating project applications  consistently and funding projects to address the most severe sanitation  deficiencies in Indian communities, consistent with the program’s goal.

USDA has provided thousands of Alaska Natives with safe drinking water  and wastewater infrastructure through its Rural Alaska Village Grant  program. However, USDA awarded some grants to recipients not  authorized by statute. By ensuring that all Rural Alaska Village grants are  awarded only to recipients authorized by statute, USDA will have  assurance that it is complying with the law. If USDA wants to award Rural  Alaska Village grants to municipalities and Alaska Native villages, it  should seek authority to do so as it did to award these grants to the  Alaska Native Tribal Health Consortium. Also, until USDA amends the  Rural Alaska Village Grant program regulations to be consistent with  USDA’s authority, the agency’s regulations will continue to recognize  recipients not authorized by statute.

The five agencies that participate in the national tribal infrastructure task  force have committed to working together at the national and regional  levels to increase tribes’ access to safe drinking water and basic  sanitation. In our previous work, we have found that achieving important  national outcomes, such as providing access to safe drinking water and  wastewater disposal, often requires collaborative efforts by a number of  programs across the federal government. At the national level, the task  force has not acted on most of the options it previously identified to  improve member agencies’ collaboration. By reviewing the 2011 task  force report and identifying and implementing additional actions to help  increase their collaboration, the task force member agencies could  improve their ability to leverage limited program funds. At the regional  level, we found that the task force member agencies had not fulfilled their  commitment to collaborate in all of the six states we reviewed. Responses  to our survey also indicated that there is unrealized potential for the task  force member agencies’ regional offices to increase the extent of their  collaboration. By directing their regional offices to identify and pursue  additional mechanisms to increase their collaboration, the task force  member agencies would have better assurance that their regional offices  are leveraging limited program funds and following through on their  commitment to collaborate.

We are making 16 recommendations—two to IHS to improve information  in HITS; one each to IHS and USDA to review their project selection  processes; two to USDA to address issues with its Rural Alaska Village  Grant program; and two each to IHS, USDA, EPA, HUD, and  Reclamation to increase collaboration at the national and regional levels.

The Director of IHS should implement a targeted, resource-efficient  method to identify additional eligible Indian homes that may have  existing deficiencies to include in HITS. (Recommendation 1)

The Director of IHS should implement a mechanism to indicate in  HITS whether each home with a deficiency level of 0 has been  assessed. (Recommendation 2)

The Director of IHS should reassess the point distribution across the  SDS scoring factors as part of its program guidelines update, in light  of trade-offs between funding projects that address the most severe  sanitation deficiencies and projects that meet other needs.  (Recommendation 3)

The Assistant to the Secretary of Agriculture for Rural Development  should implement a scoring factor that awards points for proposed  Native American program grant projects that address health risks from  a lack of access to safe drinking water and wastewater disposal, as it  does with the Colonias grant program. (Recommendation 4)

The Assistant to the Secretary of Agriculture for Rural Development  should ensure that all Rural Alaska Village grants are awarded only  to recipients authorized by law or seek authority to award grants to  municipalities and Alaska Native villages. (Recommendation 5)

The Assistant to the Secretary of Agriculture for Rural Development  should amend the Rural Alaska Village Grant program regulations so  that they are consistent with USDA’s authority. (Recommendation 6)

The Director of IHS, in cooperation with other members of the tribal  infrastructure task force, should review the 2011 task force report and  identify and implement additional actions to help increase the task  force’s collaboration at the national level. (Recommendation 7)

The Administrator of EPA, in cooperation with other members of the  tribal infrastructure task force, should review the 2011 task force  report and identify and implement additional actions to help increase  the task force’s collaboration at the national level.  (Recommendation 8)

The Assistant to the Secretary of Agriculture for Rural Development,  in cooperation with other members of the tribal infrastructure task  force, should review the 2011 task force report and identify and  implement additional actions to help increase the task force’s  collaboration at the national level. (Recommendation 9)

The Deputy Assistant Secretary of the Department of Housing and  Urban Development’s Office of Native American Programs, in  cooperation with other members of the tribal infrastructure task force,  should review the 2011 task force report and identify and implement  additional actions to help increase the task force’s collaboration at the  national level. (Recommendation 10)

The Commissioner of Reclamation, in cooperation with other  members of the tribal infrastructure task force, should review the 2011  task force report and identify and implement additional actions to help  increase the task force’s collaboration at the national level.  (Recommendation 11)

The Director of IHS, in cooperation with other members of the tribal  infrastructure task force, should direct IHS area offices to identify and  pursue additional mechanisms to increase their collaboration.  (Recommendation 12)

The Assistant to the Secretary of Agriculture for Rural Development,  in cooperation with other members of the tribal infrastructure task  force, should direct USDA state offices to identify and pursue  additional mechanisms to increase their collaboration.  (Recommendation 13)

The Administrator of EPA, in cooperation with other members of the  tribal infrastructure task force, should direct EPA regional offices to  identify and pursue additional mechanisms to increase their  collaboration. (Recommendation 14)

The Deputy Assistant Secretary of the Department of Housing and  Urban Development’s Office of Native American Programs, in  cooperation with other members of the tribal infrastructure task force,  should direct HUD regional offices to identify and pursue additional  mechanisms to increase their collaboration. (Recommendation 15)

The Commissioner of Reclamation, in cooperation with other  members of the tribal infrastructure task force, should direct  Reclamation regional offices to identify and pursue additional  mechanisms to increase their collaboration. (Recommendation 16)

We provided a draft of this report for review and comment to the  Department of Health and Human Services (for IHS), HUD, the  Department of the Interior (for Reclamation), EPA, USDA, the Department  of Defense (for the Corps), and the Department of Commerce (for EDA).  Of the five agencies to which we directed recommendations, three— Health and Human Services, HUD, and Interior—agreed with the  recommendations directed to them. The fourth agency, EPA, agreed with  one of the recommendations and agreed with the intent of the second  recommendation but proposed revised language, as discussed below.  The Acting Director of Grants Evaluation for HUD’s Office of Native  American Programs provided comments by e-mail, and Health and  Human Services, Interior, and EPA provided written comments that are  reproduced in appendixes V, VI, and VII, respectively. The fifth agency to  which we directed recommendations, USDA, disagreed with the two  recommendations regarding the Rural Alaska Village Grant program and  neither agreed nor disagreed with the other three recommendations  directed to it, although the agency proposed alternative language for two  of these recommendations in its written comments, reproduced in  appendix VIII. Of the two agencies to which we did not direct  recommendations, Defense provided a letter, reproduced in appendix IX,  in which it indicated the agency had no comments on the report, and  Commerce’s Audit Liaison stated in an e-mail that Commerce would not  send a formal comment letter. In addition, Health and Human Services,  USDA, and EDA (for Commerce) provided technical comments, which we  incorporated in the report as appropriate.

In its written comments, EPA requested that we revise the language of  the recommendation that the members of the tribal infrastructure task  force direct their regional, state, or area offices to identify and pursue  additional mechanisms to increase their collaboration. EPA stated that it  agreed with the intent of the recommendation but that it was concerned  that, as worded, the recommendation may not achieve the intended goal.  Instead, EPA stated that it can accomplish increased regional  collaboration through multiple avenues and as such, provided revised  language that would remove reference to its regional offices taking the  recommended action. We encourage EPA to take advantage of  increasing regional collaboration through all avenues it sees fit. However,  because EPA’s regional offices are the entities that collaborate with other  agencies in the various regions, we continue to believe it is important for  these offices to participate in identifying and implementing the means for  increasing collaboration in their respective regions. As a result, we did not  modify the recommendation language in response to EPA’s comment.

In its written comments, USDA stated it disagreed with our statements  concerning the Rural Alaska Village Grant program and asked that we  remove the two corresponding recommendations from our report.  Specifically, USDA stated that our recommendations are unnecessary  because the agency is operating within its authorities. USDA stated that it  believes providing grants directly to parties other than the state— including Alaska Native villages and municipalities—under the 2011  memorandum of agreement is consistent with the purpose of section  306D of the Consolidated Farm and Rural Development Act and  appropriations made for the program. As we state in the report, we agree  that the State of Alaska can choose to make subgrants once it receives  the Rural Alaska Village grant. We also state in the report that we did not  see any evidence of grants being used for other than their intended  purposes during the course of our review. However, the language of  section 306D only authorizes USDA to award grants to the State of  Alaska and not directly to other entities. Therefore, we believe that our  recommendations are necessary. If USDA wants to make Rural Alaska  Village grants to municipalities and Alaska Native villages, it should seek  authority to do so as it did to award such grants to the Alaska Native  Tribal Health Consortium.

Regarding our fourth recommendation that USDA implement a scoring  factor that awards points for proposed Native American program projects  that address health risks, USDA stated that it would like clarification as to  what form of scoring factor would be acceptable to address this  recommendation. USDA stated that it would prefer to use its discretionary  points under the program’s existing regulations to award additional points  to give a higher priority to projects that address a lack of access to safe  drinking water and wastewater disposal, and that the agency could  implement this change at the start of fiscal year 2019 or sooner. In  contrast, USDA stated that changing the program’s regulations to  implement the scoring factor could take 18 months or longer. USDA also  stated that this approach would only have a programmatic effect in fiscal  years when demand for Native American program grant funds exceeds  the available funding. Our intent for the recommendation as written is to  provide USDA with the flexibility to best determine how to implement it. If  USDA has determined that using its discretionary points under the  program’s existing regulations gives greater priority to addressing health  risks faced by Native American communities, and that such an approach  is consistent with applicable law, such an approach could meet the intent  of our recommendation.

USDA also requested in its written comments that we modify the  language of the ninth recommendation aimed at increasing collaboration  at the national level by removing reference to increasing national  collaboration and that we modify the thirteenth recommendation aimed at  increasing regional collaboration by removing reference to the agency’s  state offices and regional level collaboration. USDA did not provide a  clear rationale for its requested change for either recommendation. We  continue to believe that implementing these recommendations, as  worded, would help improve collaboration at the national and regional  levels. Therefore, we did not modify the language in response to USDA’s  comments.

In several places in its written comments, USDA stated that our draft  either omitted information or contained inaccurate information and  requested that we make modifications. Specifically, USDA stated that we  omitted statutory language for the Native American program in a few  places in the report. In response, we added additional language from and  about the Native American program’s authorizing statute in several  places. USDA also stated the report is missing information about the  scope of some of its programs, including its Technical Assistance and  Training program. In response, we added more information about this  program, including obligations made to non-profit organizations that work  on behalf of tribes. Further, USDA stated that we did not accurately  characterize certain activities that USDA conducts under some of its  programs, including identifying tribal needs and conducting operations  and maintenance. In response, we modified language to reflect additional  information about how USDA identifies tribal needs and to indicate that  the Native American program is not authorized to fund operations and  maintenance. Regarding the Rural Alaska Village Grant program, USDA  stated that we did not accurately represent information shared by a USDA  official and information about the number of grants made to the  Consortium. We revised language attributed to the official and clarified  information about the number of grants awarded based on additional  information that USDA provided by e-mail after submitting its written  comments.

In other cases where USDA requested revisions to the draft in its written  comments, we did not make suggested changes because they did not  align with the scope of our review. Specifically, in addition to its Technical  Assistance and Training program, USDA asked that we add information  about tribal obligations under its Solid Waste Management program.  Since federal agency efforts to fund solid waste management projects are  outside the scope of this review, we did not make this revision. In  addition, USDA requested that we limit our discussion of Rural Alaska  Village Grant awards to fiscal year 2011 and forward. We did not make  this change because USDA’s grants to municipalities and Native villages  prior to 2011 are directly relevant to our findings and are within the scope  of this review. Finally, USDA asked that we edit our description of the  findings of a 2010 report to Congress by citing a different report instead.  We did not make this change because the original report contained  relevant information for our findings.

As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees, the Secretary of Agriculture, the Secretary of  Commerce, the Secretary of Defense, the Secretary of Health and  Human Services, the Secretary of Housing and Urban Development, the  Secretary of the Interior, the Administrator of the Environmental  Protection Agency, and other interested parties. In addition, the report will  be available at no charge on the GAO website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact  Anne-Marie Fennell at (202) 512-3841 or fennella@gao.gov or J. Alfredo  Gómez at (202) 512-3841 or gomezj@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made key contributions to this  report are listed in appendix X.

Appendix I: Objectives, Scope, and Methodology

The objectives of our review were to examine the extent to which the  seven federal agencies, as applicable, (1) identified Indian tribes’ drinking  water and wastewater infrastructure needs; (2) funded tribal drinking  water and wastewater infrastructure projects, including projects to  address the most severe sanitation deficiencies; and (3) collaborated to  meet Indian tribes’ drinking water and wastewater infrastructure needs.

To address these objectives, we reviewed our previous reports, other  agency reports, and agency obligations to identify the federal agencies  that provide financial or other assistance to Indian tribes for drinking water  and wastewater infrastructure. We identified seven agencies, as shown in  table 4. We identified the Indian Health Service (IHS), Environmental  Protection Agency (EPA), and U.S. Department of Agriculture (USDA) as  federal agencies that have drinking water and wastewater infrastructure  programs specifically targeted to provide financial assistance for planning  and construction to address Indian tribes’ needs. According to IHS  documentation, such needs arise from a sanitation deficiency in existing  drinking water or wastewater infrastructure (or lack thereof) that can  negatively affect public health. In addition, the Department of Housing  and Urban Development (HUD), the Department of the Interior’s Bureau  of Reclamation, the Department of Commerce’s Economic Development  Administration (EDA), and the U.S. Army Corps of Engineers administer  programs that may assist tribes with drinking water and wastewater  infrastructure planning and construction. The types of assistance these  agencies provide vary by program, and each program has its own  eligibility requirements and authorities.

To determine the extent to which these federal agencies identified Indian  tribes’ drinking water and wastewater infrastructure needs, we identified  requirements for IHS and EPA to collect and report information on needs,  but we did not identify such requirements for the other agencies. We  reviewed IHS’s project-level tribal drinking water and wastewater  infrastructure needs data from the Sanitation Deficiency System (SDS) for  fiscal year 2016, the most recent year of data available at the time of our  review. The SDS contains information about proposed drinking water and  wastewater infrastructure projects, including each project’s estimated  cost. IHS policy directs area staff to invite all federally recognized tribes to  identify potential projects each year. Area staff then work with interested  tribes to develop projects and enter project information into standard  fields in the SDS. As of the end of fiscal year 2016, the SDS included  more than 2,000 projects for 373 tribes. We also reviewed IHS’s most  recent reports describing tribal drinking water and wastewater needs.  In addition, we reviewed information about tribal public drinking water  systems reported in EPA’s 2013 Drinking Water Infrastructure Needs  Survey and Assessment report. EPA assesses and reports on the  nation’s public water systems’ capital improvement needs every 4 years,  including needs of tribally owned or operated drinking water systems. For  its 2013 report, EPA assessed tribal water system needs by administering  a survey to a statistical sample of 306 tribal water systems out of  956 identified tribal public drinking water systems.

We assessed the reliability of SDS project-level needs data and  information from EPA’s 2013 Drinking Water Infrastructure Needs Survey  and Assessment report by reviewing our previous related work regarding  the use of these data and documentation from IHS and EPA. We also  interviewed IHS and EPA officials involved with identifying tribal water  needs from headquarters and all 12 IHS areas and 9 EPA regions that  administered the drinking water and clean water set-aside programs,  discussing the data and any of its limitations. We tested the data for  accuracy and completeness by identifying any duplicate, missing, or  invalid records and cross-referencing with relevant datasets. We  determined that IHS’s SDS project-level needs data and information  from EPA’s 2013 report were sufficiently reliable to provide descriptive  information on tribes’ needs for drinking water and wastewater  infrastructure projects for this report.

Further, we reviewed documentation on the Home Inventory Tracking  System (HITS)—IHS’s database containing home-specific information  that the agency also uses in administering the Sanitation Facilities  Construction program. The information in HITS includes each home’s  geographic location and individual sanitation deficiency, and IHS officials  said in February 2018 that the system contained a total of 405,986  homes. We also interviewed IHS headquarters and area officials about  this system’s contents, uses, and limitations, and we compared this  information to the agency’s implementation plan and other documentation  for HITS. We identified issues with the information contained in the  system related to its completeness (whether it contains the correct  number of homes in light of its purpose) and related to the accuracy of  homes identified as having no deficiency, as we discuss in the report.  These issues were sufficient for us to determine that the number of  homes in the system was incomplete and that deficiency level information  was not accurate for all homes in the system. As a result, we did not  assess the reliability of other information in HITS that was not relevant to  our review. We also interviewed officials from the other five agencies  regarding any efforts to collect information on tribal drinking water and  wastewater infrastructure needs.

To determine the extent to which the agencies funded tribal drinking  water and wastewater infrastructure projects, we analyzed data from the  seven agencies administering programs that provide assistance to tribes  for drinking water and wastewater infrastructure—IHS, EPA, USDA, HUD,  Reclamation, EDA, and Corps. Specifically, we obtained and analyzed  obligations data for drinking water and wastewater projects under  programs that are specifically for or available to tribes. Generally, we  reviewed each agency’s obligations data for fiscal years 2012 through  2016, the most recent 5 years of data available at the time of our review.  Corps provided us with information on obligations for projects that  involved tribal drinking water or wastewater infrastructure, but none of  these obligations were in fiscal years 2012 through 2016. We assessed  the reliability of the other agencies’ data by reviewing our previous related  work regarding the use of these data and any available documentation  from each agency; interviewing knowledgeable agency officials involved  with collecting or analyzing these data; and testing data for accuracy and  completeness by identifying any duplicate, missing, or invalid records. We  present more details about each agency’s data, any limitations, and how  we addressed those limitations below. On the basis of these efforts, we  determined that the data obtained from these agencies were sufficiently  reliable for our descriptive purposes unless otherwise noted below.

IHS. IHS provided us with project-level obligations data from fiscal  years 2012 through 2016 for tribal drinking water and wastewater  infrastructure projects from its Project Data System. In reviewing  these data, we found data reliability issues that posed challenges to  accurately reporting IHS’s project obligations separate from other  agencies’ contributions to projects, which IHS also tracks in the  system. We determined that the project-level obligations data from the  Project Data System were not sufficiently reliable for the purposes of  this objective. However, we determined that using IHS’s information  on allocations to areas for the same time frame would introduce fewer  limitations to our reporting. IHS provided us with information from  fiscal years 2012 through 2016 on allocations to each of its 12 areas  by Sanitation Facilities Program activity (i.e., sanitation deficiencies,  new housing, and emergency and special projects). IHS officials  stated that the IHS Director of the Division of Sanitation Facilities  Construction determines the area allocations amounts annually, and  that IHS obligated all of its area allocations each fiscal year. IHS did  not separate the area allocations information by drinking water,  wastewater, or solid waste projects; therefore, we report total  obligations with solid waste projects included.

EPA. EPA provided us with project-level obligations data from fiscal  years 2012 through 2016 from each of its three tribal-specific  programs listed in table 4. EPA uses its Tribal Direct Implementation  Nexus system to track project obligations for the Clean Water Indian  Set-Aside and Drinking Water Infrastructure Grants Tribal Set-Aside  programs, but the agency relies on the State of Alaska to provide  similar project-level information for its Alaska Native Villages and  Rural Community Water Grant program. In reviewing EPA’s data,  we found several duplicate project records. We confirmed the issue  with EPA officials and deleted those duplicate records to accurately  aggregate EPA’s obligations by fiscal year for our report.

USDA. USDA provided us with grant and loan obligations data from  fiscal years 2012 through 2016 for all of its programs specifically for  or available to tribes from its Community Program Application  Processing system. First, we removed solid waste and landfill projects  that were indicated as such in the project name. To determine the  project obligations for programs specifically for tribes, we included all  obligations from USDA’s Native American and Rural Alaska Village  Grant programs. USDA also awarded grants and loans to tribes or  non-profit organizations working on behalf of tribes from non-tribal  specific programs such as from its Water and Waste Disposal  program as well as the Section 306C Colonias, Emergency  Community Water Assistance Grant, Predevelopment Planning  Grants, Special Evaluation Assistance for Rural Communities and  Households, and Technical Assistance and Training programs. To  determine the project obligations for those programs, we included  projects that had an applicant or customer type as a tribe or tribal  entity (e.g., an organization working on behalf of a tribe or tribes such  as tribal health consortia or tribal utility authorities) and projects that  served a population of at least 50 percent tribal users. For these  awards, we included the full amount of the award regardless of the  percent of tribal users served.

HUD. HUD provided us with project-level obligations data from fiscal  years 2012 through 2016 for its Indian Community Development Block  Grant program from its Performance Tracking Database. We worked  with HUD officials to identify projects that included drinking water and  wastewater infrastructure and to identify the amount of the obligations  used for those purposes to determine HUD’s overall fiscal year project  obligations for tribal water infrastructure.

Reclamation. Reclamation provided us with project-level obligations  data from fiscal years 2012 through 2016 for the tribal portions of  authorized water system projects, including projects authorized by  enacted Indian water rights settlements. For the Indian water rights  settlement project obligations, Reclamation provided both mandatory  and discretionary amounts. We included both rural water system  projects and Indian water rights settlements projects in reporting  Reclamation’s overall fiscal year obligations.

EDA. EDA provided us with project-level obligations data from fiscal  years 2012 through 2016 for tribal projects funded by its Public  Works, Economic Adjustment Assistance, and Planning programs  from its Operations Planning and Control System. To determine  whether the EDA projects included drinking water or wastewater  infrastructure, we reviewed each project’s description or scope of  work for mention of a drinking water or wastewater infrastructure  component. If we determined that the project included water  infrastructure, we included the entire project’s obligation amount for  each fiscal year we report.

In addition, to determine the extent to which agencies’ funding addressed  the most severe sanitation deficiencies, we identified programs that have  documented goals in regulation and policy to fund projects that meet  these needs, which the programs identify as the absence of safe drinking  water or wastewater disposal facilities. These selected programs included  IHS’s Sanitation Facilities Construction program, EPA’s clean water set- aside program, and USDA’s Native American program. For these  programs, we compared the number of funded projects to address the  most severe sanitation deficiencies with the number of funded projects  that met other needs for fiscal year 2016. Specifically, for IHS and EPA,  we calculated the percentage of projects for each deficiency level that the  agencies and other entities selected to fund from the fiscal year 2016  SDS list. For USDA, we reviewed the list of Native American program  project obligations in fiscal year 2016 and determined the number of  projects where USDA reported the purpose as new, replacement,  renovation, or expansion. We also reviewed documentation of the  agencies’ project identification and selection methods to determine  whether these methods aligned with stated goals. We interviewed IHS  and EPA officials from headquarters and all area and regional offices that  administer these programs, and USDA officials from headquarters and six  state-level offices (see below for state selection information), regarding  their administration of these programs. Additionally, we analyzed IHS’s  data from the SDS from fiscal years 2005 through 2016 to identify  projects that remained unfunded and that were in the SDS for more than  5 years. We did not review the extent to which EPA’s drinking water set- aside program addressed the most severe sanitation deficiencies  because EPA regions implement the program using a variety of different  processes.

During the course of evaluating the extent to which federal agencies have  provided funding for tribal drinking water and wastewater infrastructure  projects, we identified issues with USDA’s Rural Alaska Village Grant  program. We reviewed obligations data in light of the program’s  authorizing statute, implementing regulations, and relevant provisions in  USDA appropriations acts. USDA provided us with the Rural Alaska  Village Grant program’s award amounts for fiscal years 1997 through  2016, and we determined whether the grant recipients were eligible or  ineligible at the time of the award. We interviewed agency officials who  manage the program and from USDA’s Office of the General Counsel.

To determine the extent to which the federal agencies collaborated to  meet tribal water needs, we reviewed documentation of national-level  collaboration, including federal program and interagency documents,  such as national-level memorandums of understanding and interagency  agreements. We interviewed headquarters officials from the seven  agencies about their interagency collaboration. We compared the  agencies’ actions to the key features of interagency collaboration that we  have previously identified. We reviewed agencies’ collaboration at the  regional level by surveying the seven agencies about their joint actions on  activities related to tribal drinking water and wastewater in six states— Alaska, Arizona, California, New York, Oklahoma, and South Dakota— and by conducting a network analysis using the survey responses. We  selected agency regional offices within these six states as the unit of  analysis because the federal agencies organize their field structures  differently, with some using region, district, area, or state offices to work  with tribes—we refer to all of these office types as regional offices. We  selected the nonprobability sample of six states to include a large  percentage of the number of federally recognized tribes, to obtain a range  in the total federal obligations to tribes and identified needs of tribes in the  SDS, and for geographic diversity. The sample of states is not  generalizable, and the results of our work do not apply to all states where  Indian tribes are located. However, reviewing federal agency  collaboration in these states provides illustrative examples of interagency  collaboration within the six selected states, which include about  70 percent of the 573 federally recognized tribes. We compared the  agencies’ reported collaboration with a national-level memorandum of  understanding that contained commitments for collaborating at the  regional level. For a detailed description of our survey methodology  and the analysis of our results, see appendix II.

We also interviewed federal agency and State of Alaska officials to  discuss the extent to which their drinking water and wastewater  assistance programs collaborate with other agencies to meet tribal  needs in the six selected states. We interviewed, either in person or by  telephone, officials from the eight IHS areas, five EPA regions, and six  USDA state offices that work with tribes and other agencies in the six  states. We conducted site visits from February through April 2017 to three  of the six states—Alaska, Arizona, and Oklahoma. During these visits,  we met with tribal officials and staff and federal agency officials, and we  visited tribal water infrastructure project sites. We selected these states  for site visits based on geographic diversity and to obtain a range in the  amount of tribal water infrastructure needs identified in the SDS. We  met with or interviewed by telephone officials from 22 Indian tribes and  representatives from 8 intertribal organizations that represent and work  with tribes on water infrastructure issues to obtain their views about the  water and wastewater infrastructure assistance that they receive from  federal agencies. We judgmentally selected these tribes and  organizations to obtain a range in their geographic locations and the  amount and variety of federal drinking water and wastewater  infrastructure assistance they have received. Our findings are not  generalizable to all tribes but provide illustrative examples of input  provided by tribal officials.

We conducted this performance audit from August 2016 to May 2018  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

Appendix II: GAO Survey of Federal Agency Collaboration on Tribal Water Infrastructure Projects in Six Selected States

This appendix describes how we selected the sample and administered  the survey, designed the survey questionnaire, and conducted the  network analysis for our survey on interagency collaboration regarding  tribal drinking water and wastewater infrastructure projects.

Sample Selection and Survey Administration

To determine the extent to which the selected federal agencies have  collaborated to meet tribal water needs, we surveyed officials at seven  federal agencies: Indian Health Service (IHS), Environmental Protection  Agency (EPA), U.S. Department of Agriculture (USDA), Department of  Housing and Urban Development (HUD), Economic Development  Administration (EDA), Bureau of Reclamation, and the U.S. Army Corps  of Engineers. Specifically, we surveyed agency officials in six states:  Alaska, Arizona, California, New York, Oklahoma, and South Dakota.  Appendix I describes how we selected these agencies and states. The  results of this survey are not generalizable beyond these agencies in  these states.

We reviewed maps of each agency’s regional or state offices and  identified and confirmed the offices that work with tribes and other  agencies in the six selected states. If one state included multiple regions  from the same agency, we administered the survey to officials in all  relevant regional offices. In addition, if one agency’s region covered more  than one of the selected states, we administered a survey to the agency’s  regional office for each state. The federal agencies and regional offices  we included in our survey were:

Corps divisions: Great Lakes & Ohio River, Northwestern, Pacific  Ocean, South Pacific, Southwestern;

EDA regions: Austin, Denver, Philadelphia, Seattle;

EPA regions: 2, 6, 8, 9, 10 (Alaska Operations Office);

HUD regions: Alaska, Eastern Woodlands, Northern Plains, Southern  IHS areas: Alaska, California, Great Plains, Nashville, Navajo,  Oklahoma City, Phoenix, Tucson;

Reclamation regions: Great Plains, Lower Colorado, Mid-Pacific; and

USDA state offices: Alaska, Arizona, California, New York, Oklahoma,  South Dakota.

In Alaska, we also included the Alaska Department of Environmental  Conservation as a respondent because the state provides a 25 percent  match for two federal water infrastructure programs. We did not include  other state agencies because they do not provide a similar match. We  also included the Alaska Native Tribal Health Consortium because it  administers IHS’s Sanitation Facilities Construction program in Alaska.

The practical difficulties of conducting any survey may introduce errors,  commonly referred to as non-sampling errors. For example, respondents  may have difficulty interpreting a question, they may have limited  information to respond to a question, or officials from different agencies  may have different recollections regarding the extent of collaboration on  a particular project. We sought to minimize the impact of non-sampling  error by conducting six pretests of the draft questionnaire with agency  officials; five pretests were conducted by telephone and one pretest was  conducted in person. We selected officials to cover a range of agencies  and locations. During these pretests, we sought to determine whether  (1) the questions were clear and unambiguous, (2) terminology was used  correctly, (3) the questionnaire did not place an undue burden on agency  officials, (4) the information could feasibly be obtained, and (5) the survey  was comprehensive and unbiased. We modified the questionnaire in  response to these pretests. To further minimize the impact of non- sampling error, we conducted a sensitivity analysis.

We customized the questionnaire for each agency regional office so that  we asked each office to respond about its collaboration only with the  other agencies located in its state. We e-mailed these questionnaires to  46 respondents from May 15 through May 17, 2017, and conducted  follow-up as necessary. We received a 100 percent response rate.

In the survey, we asked each agency regional office whether it had jointly  conducted activities related to tribal drinking water or wastewater projects  during the past 3 years with each of the other agencies’ regional offices  within the same state. If an agency regional office responded “yes,” we  then provided a list of tribal drinking water and wastewater activities and  asked the agency regional office if it had jointly conducted any of the  listed activities related to tribal drinking water and wastewater  infrastructure projects in collaboration with the other agency. The  activities included: identifying infrastructure needs, communicating  information to tribes about programs that fund projects, planning and  designing proposed projects, evaluating proposed projects according to  eligibility and scoring criteria, selecting projects to fund, constructing  projects, providing technical assistance for operating and maintaining  water infrastructure, and negotiating or implementing Indian water rights  settlements. We developed the list of activities based on our initial  interviews and pretests with agency officials.

We next provided a list of collaborative mechanisms. For each of these  collaborative mechanisms, we asked the agency regional office if it had  used the mechanism when jointly conducting activities in collaboration  with the other agency related to tribal drinking water and wastewater  infrastructure projects within the same state during the past 3 years. The  mechanisms included: state-, regional-, or project-level memorandum of  understanding or agreement; interagency agreement to transfer funding;  working group, task force, or committee; consulting on project selection;  sharing project documents; geographic co-location; shared database or  other data sharing; conferences or forums; informal or ad hoc  communication; and personnel detailing or sharing. If the agency regional  office responded that it had not used one of the listed mechanisms, we  asked if it would be beneficial to use that mechanism to collaborate in the  future. We identified the list of mechanisms based on our prior work on  interagency collaboration and pretests with agency officials. We also  asked the agency regional office what factors, if any, helped it to  collaborate with the other agency on tribal drinking water and wastewater  infrastructure projects in the state and what factors, if any, hindered it  from collaborating with the other agency. For both questions, we asked  the agency regional office to consider agency policies and procedures,  available resources, leadership, personalities, presence of written  agreements, and accountability measures.

If an agency regional office responded “no” to the initial question of  whether it had jointly conducted activities related to tribal drinking water  or wastewater projects during the past 3 years with another agency’s  regional office, we asked a shorter set of follow-up questions. We  provided the list of collaborative mechanisms and asked if it would be  beneficial for the agency regional office to use any of the listed  mechanisms to collaborate with the other agency on activities related to  tribal drinking water and wastewater infrastructure projects in the future  in the state. We also asked the agency regional office to describe the  factors, if any, that hindered its collaboration with the other agency.

To quantify the extent of interagency collaboration during the past 3 years  and the potential for future collaboration among the federal agencies we  surveyed, we conducted a Network Analysis—a method of analyzing the  patterns of interaction among multiple entities. Specifically, we  aggregated the survey responses to our questions about drinking water  and wastewater activities and collaborative mechanisms for each pair  of agencies in all six states. We configured these aggregated data into  networks representing the pattern of collaboration among the agencies.  We then analyzed these networks to determine how extensively the  agencies have collaborated and the extent to which additional future  collaboration could be beneficial for them. We also analyzed these  networks to assess how the pattern of collaboration varied by state. We  describe the steps of our analysis and agency survey responses below.

Quantifying Collaboration between Pairs of Federal Agencies

To quantify the extent of collaboration among the federal agencies across  the six states during the past 3 years, we aggregated the responses to  our survey by agency pair. The seven federal agencies form 21 possible  agency pairs. For each agency pair, we combined the first agency’s  responses regarding its collaboration with the second agency and the  second agency’s responses regarding its collaboration with the first  agency. We aggregated the agency pair responses in this way for each  of the three measures of collaboration for all six states, specifically:

Drinking water and wastewater activities. We calculated the total  number of instances in which each agency in a pair reported having  worked on an activity with the other agency in that pair during the past  3 years (see column 2 in table 5). We examined this measure to  identify the pairs of agencies that collaborated most and least  extensively. For example, IHS and EPA reported the highest number  of instances of jointly conducting tribal drinking water and wastewater  activities across the six states. In contrast, EDA and IHS reported no  such instances of collaboration.

Use of collaborative mechanisms. We calculated the total number  of instances in which each agency in a pair reported having used a  mechanism to collaborate with the other agency in that pair during the  past 3 years (see column 3 in table 5). We examined this measure to  identify the pairs of agencies that collaborated most and least  extensively. The pattern of collaboration based on this measure is  similar to the pattern based on drinking water and wastewater  activities. For example, IHS and EPA also reported the highest  number of instances of using specific collaborative mechanisms  across the six states.

Potential future collaboration. We calculated the total number of  instances in which each agency in a pair reported that it would be  beneficial to use a mechanism to collaborate with the other agency  in that pair in the future (see column 4 in table 5). We compared this  measure to the number of mechanisms the agency pairs reported  having used during the past 3 years. Each of the agency pairs  reported that it would be beneficial to use additional collaborative  mechanisms in the future, including those pairs that had reported not  collaborating. For example, the agency pairs of EDA-IHS and EDA- Reclamation both reported no instances of using a mechanism to  collaborate with each other and both reported multiple instances in  which use of a collaborative mechanism would be beneficial in the  future.

Quantifying the Potential for Increased Collaboration

To quantify the potential to increase collaboration among the federal  agencies, we configured the agency pair data into two networks. The first  network represented recent collaboration among the agencies—the  instances in which agencies reported having used a mechanism to  collaborate during the past 3 years (based on column 3 in table 5).  The second network represented potential future collaboration among the  agencies (based on the sum of columns 3 and 4 in table 5). As such, it  captures the instances in which agencies reported having used a  mechanism to collaborate during the past 3 years plus the instances in  which they reported it would be beneficial to use an additional mechanism  in the future.

Figure 3 shows a graphical illustration of these two networks. In this  figure, the circles represent agencies and the lines represent  collaboration between the agencies. Specifically, the darkness of the lines  indicates the number of mechanisms used by the corresponding pair of  agencies. The left side of figure 3 illustrates reported use of collaborative  mechanisms during the past 3 years, and the right side of figure 3  illustrates potential future collaboration. The figure shows that overall  collaboration would increase if the agencies began using the additional  mechanisms that they reported would be beneficial.

We quantified the difference between these networks in two ways. First,  we calculated the increase in overall collaboration that would occur if  agencies began using the additional mechanisms that they reported  would be beneficial. Based on this calculation, the number of instances of  agencies using collaborative mechanisms would approximately triple.  Specifically, agencies reported 403 instances of having used a specific  mechanism to collaborate with another agency—this number would  increase to 1,249 if agencies began using all of the identified mechanisms  that they reported would be beneficial. This difference is shown in figure  3, in which the right side of the figure (potential future collaboration) has  a greater number of darker lines connecting the agencies compared with  the left side of the figure (recent collaboration).

Second, we measured how the relative amount of collaboration for each  agency would change if the agencies began using additional mechanisms  they reported would be beneficial. To do this, we aggregated the agency  pair data for each of the agencies. For the network of recent  collaboration, for example, we added (1) the number of instances that  each agency reported using a collaborative mechanism with any of the  other agencies and (2) the number of instances that any of the other  agencies reported using a collaborative mechanism with the first agency.  We performed a similar calculation using the agency pair data for the  network of potential future collaboration. The analysis shows that the use  of collaborative mechanisms during the past 3 years was primarily  centered on three agencies (IHS, EPA, and USDA). If all of the agencies  began using the additional mechanisms that they reported would be  beneficial, however, collaboration would be distributed more evenly  across the entire network of agencies. This difference is also shown in  figure 3, in which agencies such as HUD, Reclamation, and Corps are  connected to other agencies with dashed lines on the left side of the  figure (representing less extensive recent collaboration), but with thick  lines on the right side of the figure (representing more extensive potential  future collaboration).

Quantifying the Variation in Collaboration by State

To quantify the extent of variation in collaboration by state, we  disaggregated the agency pair data reported in table 5 by each of the  states for the three measures of collaboration we asked about in our  survey. In particular, tables 6, 7, and 8 show the number of instances in  which an agency reported collaborating on drinking water and wastewater  infrastructure activities with another agency during the past 3 years  (table 6), using collaborative mechanisms with another agency during  the past 3 years (table 7), and collaborative mechanisms that would be  beneficial to use with another agency in the future (table 8). The totals in  the bottom rows of these tables show the extent of collaboration based on  these measures by state. Specifically, tables 6 and 7 show that agencies  worked together on activities and used collaborative mechanisms most  extensively in Alaska and least extensively in New York and Oklahoma.  Table 8 shows that agencies in New York and Oklahoma reported the  greatest potential for using additional collaborative mechanisms. The  totals in the far right columns of these tables show the extent of reported  collaboration by activity (table 6), collaborative mechanism (table 7), and  the extent of potential future collaboration by collaborative mechanism  (table 8).

Appendix III: Federal Agency Obligations for Tribal Drinking Water and Wastewater Infrastructure Projects, Fiscal Years 2012 through 2016

Appendix III: Federal Agency Obligations for  Tribal Drinking Water and Wastewater  Infrastructure Projects, Fiscal Years 2012  through 2016 According to Environmental Protection Agency officials, obligations listed may not match annual  appropriations because the agency may have de-obligated and re-obligated any unexpended  obligations to other projects.  We determined that the U.S. Department of Agriculture awarded a grant or loan from its non-tribal  specific programs for a tribal drinking water or wastewater infrastructure project if the recipient was a  tribe or tribal entity (for example, an organization working on behalf of a tribe or tribes such as tribal  health consortia or tribal utility authorities) and if the project was to serve a population of at least 50  percent American Indian or Alaska Native.   The Economic Development Administration obligated approximately $34,000 for one project in fiscal  year 2012, which is not reflected in the table due to rounding. We determined that the Economic  Development Administration awarded a grant for a tribal drinking water or wastewater infrastructure  project if the project’s description or scope of work mentioned a drinking water or wastewater  infrastructure component. Obligations are combined from three programs: Public Works, Economic  Adjustment Assistance, and Planning.

Appendix IV: Examples of Tribal Water Infrastructure Projects We Visited

This appendix contains summaries and photographs of selected tribal  drinking water and wastewater infrastructure projects we visited from  February through April 2017 in Alaska, Arizona, and Oklahoma.

Portable Alternative Sanitation System Pilot Project, Native Village of Kivalina, Alaska

The Native Village of Kivalina, located on a barrier island above the Arctic  Circle, is one of approximately 30 communities in Alaska where residents  do not have access to safe drinking water and wastewater disposal  facilities in their homes. Kivalina, a community of 469 residents, has a  community washeteria with washing machines, dryers, and drinking water  available for purchase. Like many Alaska Native villages, the harsh winter  climate, limited revenue, and isolation create challenges for installing and  operating water infrastructure. Erosion due to diminishing sea ice and  other factors threaten Kivalina, and the community is considering  relocation. As such, infrastructure improvements are limited to small  projects consisting of moveable, low-water use infrastructure to provide  interim sanitation improvements. In 2015, the Alaska Native Tribal Health  Consortium installed a pilot sanitation system in nine homes. This system  is called the Portable Alternative Sanitation System and consists of a  bathroom sink, rainwater catchment, in-home water treatment, and a  separating toilet, where liquid waste is collected separate from solid  waste. According to a Consortium report, the system is a low-cost  alternative to traditional piped infrastructure. The total cost was $633,000  to design, install, and monitor the system, with the Indian Health Service  (IHS) and the Consortium contributing to the project. The Consortium  recommended expanding the pilot system to the rest of Kivalina, and a  Consortium official said it is working with IHS to test the system in several  homes in three other unserved communities in Alaska.

Village of Shungopavi Sewer Line Q & Dump Stations Construction Project, Hopi Tribe, Arizona

As of 2015, more than 30 percent of the nearly 80 homes in the Hopi  Village of Shungopavi did not have adequate wastewater disposal. The  Sewer Line Q and Dump Stations construction project included installing  a sewer main to connect nine homes to sewer service. Previously, some  of these homes had discharged wastewater directly onto the ground, and  one had a septic system. The project also involved installing three  honeybucket dump stations in the village and connecting them to the  existing sewer system so that an additional 19 homes could dispose of  raw sewage in an environmentally safe manner. According to IHS  officials, solid rock a few feet beneath the surface made it challenging and  expensive to lay the sewer pipes. The total estimated cost was $666,000,  with the Environmental Protection Agency (EPA), the Village of  Shungopavi, and IHS contributing to the project. According to IHS  officials, the project is expected to be fully constructed in 2018.

Oaks Wastewater Lagoons Construction Project, Cherokee Nation, Oklahoma

The Cherokee Nation’s Oaks Wastewater Lagoons project serves an  estimated 85 Indian-owned homes in the community of Oaks, Oklahoma.  The project consisted of constructing three wastewater lagoons and a  spray irrigation field. According to a tribal official, because the previous  lagoons leaked into the adjacent creek, local residents who used the  creek for swimming, fishing, and other traditional purposes were at high  risk of coming in contact with lagoon leakage. The total cost of the project  was an estimated $1.22 million, and the U.S. Department of Agriculture,  EPA, IHS, the Department of Housing and Urban Development, and the  Oklahoma Water Resources Board made contributions to the project. The  Cherokee Nation completed the project in 2012 under the provisions of its  self-governance compact with IHS.

Drinking Water Pump Station Replacement Project, Sasakwa Rural Water District, Seminole Nation of Oklahoma

The Sasakwa Rural Water District is owned and operated by the  Seminole Nation of Oklahoma and serves 61 households—about  60 percent of which are Indian homes, according to tribal officials. The  Drinking Water Pump Station Replacement project involved drilling new  wells and constructing a new pump station and treatment system. IHS  constructed the original Sasakwa water treatment plant in 1972.  According to an IHS project summary, the problems with the prior system  included (1) recurring leaks in the water transmission line and distribution  system and (2) deterioration of the pump and treatment building and  equipment due to weather, vandalism, and poor water quality. The project  cost approximately $700,000, with EPA funding the project. According to  tribal officials, the replacement water treatment plant became operational  in 2014.

Appendix V: Comments from the Department of Health and Human Services

Appendix VI: Comments from the Department of the Interior

Appendix VII: Comments from the Environmental Protection Agency

Appendix VIII: Comments from the U.S. Department of Agriculture

Appendix IX: Comments from the Department of Defense

Appendix X: GAO Contacts and Staff Acknowledgments

In addition to the contacts named above, Jeffery D. Malcolm (Assistant  Director, in memoriam), Leslie Kaas Pollock (Analyst in Charge), Carolyn  S. Blocker, Mark Braza, John Delicath, David Dornisch, Cynthia Grant,  Susan Iott, Serena Lo, Elizabeth Luke, Micah McMillan, Jon Melhus,  Jeanette Soares, Sara Sullivan, Kiki Theodoropoulos, and Sarah Veale  made key contributions to this report.

Tens of thousands of American Indians and Alaska Natives do not have safe drinking water or wastewater disposal in their homes, which may negatively affect their health.

We found that the Indian Health Service (and other federal agencies that fund tribal water projects) spent about $370 million on these projects in 2016. However, they didn't always prioritize projects in areas that lacked safe drinking water or wastewater disposal.

We recommended that IHS and the Department of Agriculture update their processes to prioritize tribal water infrastructure projects in communities that currently lack safe drinking water and wastewater disposal.