-------
and outreach available to tribes. Some regions hold an annual GAP conference at which GAP
administrative training may or may not be provided, while other regions routinely offer GAP-
specific workshops. One region indicated that it has had more success with assisting tribes with
the fiscal administration of GAP on a one-on-one basis than through formal training.
B. Tribes' Use of GAP Resources
Tribes use GAP funds and technical and programmatic resources primarily to establish and
maintain a tribal environmental presence in Indian country, which many tribes define as having a
qualified staff person available on the reservation to respond to environmental issues of concern
to their tribal council and members. In addition, tribes use GAP resources to participate in a
variety of activities that help build their environmental capacity and expand their environmental
presence. We examined the types of activities conducted by the 96 tribes in our sample for
which we were able to obtain activity data from the either the GAP database or file reviews.
Exhibit 3-2 presents the percentage of tribes that participated in different categories of activities.5
Nearly all tribes (98 percent) participated in activities related to the general management and
administration of their environmental programs. A majority of tribes also participated in land
activities (84 percent), water activities (73 percent), and grant writing activities (65 percent). A
smaller proportion of tribes conducted air activities and special emphasis activities.
5 Activities listed in the GAP database are organized into categories that correspond to six main program
areas. Within each category, activities are grouped into more narrow subcategories. For example, land activities
may include activities associated with asbestos, emergency response, Superfund, hazardous waste, lead, pesticides,
solid waste and recycling, or underground storage tanks (UST). Activities conducted within each subcategory may
be further classified by type (in Exhibit 3-3), such as general program development, staffing, communication,
baseline assessment, development of monitoring capacity, development of codes, ordinances, or standards,
developing permitting/licensing authority, development of QAPPs, grant administration, and database development.
For a complete list of categories and subcategories, see Appendix E.
3-5
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Exhibit 3-2: Activities funded by GAP, Organized by Major Category, 2000-2004 (n = 96)
g, 100% -,
&
s
_ 80%
fj
«
a
.=
& ^»0%
•e
u
^
•C
SS 4no/,
s
.Q
L^ 90%
o
1
V
PH 0%
General Land Activities Water Activities Grant Writing Air Activities Special Emphasis
Management and Activities
Administration Category of Activity
Exhibit 3-3 shows tribal participation in activities further classified by activity type. More than
80 percent of tribes participated in program development or establishment, staffing, and
communication activities. Approximately two-thirds of tribes engaged in baseline assessment
and grant writing activities. Considerably fewer tribes conducted activities associated with
media-specific programs, such as the development of Quality Assurance Project Plans (QAPPs)
and monitoring capacity; the development of legal tools such as codes, ordinances, standards,
and permitting authority; and the administration of grants received in support of these programs.
Only two tribes participated in database development activities.
3-6
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Exhibit 3-3: Activities funded by GAP, Organized by Activity Type, 2000-2004 (n = 96)
100% -,
13
u
-S 60% -
w
^g
^
•-C
u
£
*£ 9n%
H
=g 0% J
1
n n n n
II II II II 1 1
1 |5l 1 1 | 1 ^ S * °si^c^cg a gg
£ £s| | i i £ is |i| |& |l.^ i it
ill I j a 1 ft ill P 111 1 ^
S | Q§Q^° ig
Activity Type
We also asked tribes directly for details about the activities they conduct with GAP funding. The
activities tribes mentioned are consistent with the categories and activity types described above,
although many also reflect the specific interests and environmental priorities of individual tribes.
For example, one tribe performed an assessment of medicinal plant species on the reservation.
Another has conducted environmental education integrated with tribal culture and language.
Noting the subsistence diet of its members, another tribe used GAP funds to address water
quality and increased mortality rates potentially linked to the consumption of contaminated fish.
A number of tribes have also used GAP to participate in training and planning activities for
emergency response programs that include natural disaster assistance, such as forest fire
prevention.
The range of activities conducted by tribes suggests both the depth and breadth of capacity-
building within and across program areas. One example is water quality programs. Tribes
recalled using GAP funds for wetlands surveys, riparian zone protection activities, surface water
and well monitoring, and obtaining staff certifications for drinking water and wastewater
treatment systems. A few tribes mentioned using GAP to hire contractors to conduct specialized
activities including hazardous waste cleanups, water sampling and analysis, program planning
for solid waste and emergency management, and electronics recycling.
Under the general program management and administration category, tribes have engaged in
activities to further establish their legal and enforcement capability. These activities include the
3-7
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development of ordinances for solid waste and recycling, open burning, zoning, and underground
storage tanks, as well as the establishment of water quality standards. GAP has enabled at least
one tribe to issue wetlands permits and conduct its own inspections to ensure compliance with
tribal regulations. For tribes that do not have permitting or enforcement authority for programs
such as UST, Underground Injection Control (UIC), or the National Permit Discharge
Elimination System (NPDES), GAP provides funds for tribal environmental staff to accompany
federal inspectors and gain knowledge and expertise.
C. Expectations for Grants Management, Execution of Administrative Functions, and
Carrying Out Proposed Activities
The award of GAP grants brings with it EPA's expectation that tribes will fulfill the
requirements of GAP for demonstrating accountability in the utilization of funds as well as for
grants management and performance reporting, detailed in the 2000 GAP Guidelines.6 The
Guidelines also specify requirements for the preparation of work plans, financial reports, and
performance reports that demonstrate progress toward the achievement of deliverables stated in
the grant work plans.
Based on our interviews with regional POs, we found that, overall, tribes are meeting regional
expectations for grants management, the execution of administrative functions, and carrying out
proposed activities. When asked to rate tribal fulfillment of regional expectations along a five-
point Lei chart scale, POs said that tribes almost always or often meet their region's expectations
for grants management and the execution of administrative functions, and almost always
complete the activities proposed in their work plans. According to POs, tribes continue to
improve the timeliness of their GAP work plans and progress reports. Currently, most tribes in a
majority of regions are submitting their work plans and progress reports on time. In one region,
however, only 20 percent of tribes are submitting timely work plans and progress reports. POs
attribute significant improvements in the timeliness of tribal submittals in part to efforts
undertaken by regional staff to improve their ability to track submittals and to raise tribes'
understanding of reporting expectations. They also acknowledge that timeliness tends to
improve as tribes gain experience preparing work plans and progress reports, although setbacks
can occur when there is high turnover among tribal environmental directors. Delays in work
plan submittal may also occur when EPA does not announce award amounts until late in the
year. Because GAP has traditionally received its appropriation toward the end of the second
quarter, the time period tribes have for preparing and submitting work plans is often extended.
One region addressed this problem by establishing a timetable for tribes that specifies when their
work plans would be due and when regional staff would respond to them. This region
emphasized to tribes that their GAP awards could be jeopardized if they did not submit their
work plan by the deadline.
The quality and completeness of GAP work plans and progress reports has improved
concurrently with submission timeliness. POs indicated that while most tribes submit quality
work plans initially, regions must still enter into subsequent negotiations with some tribes to
improve both the quality and completeness of their work plans. One PO said that only 10
percent of the tribes in the region submit initial work plans of sufficient quality; however,
6 Available online at www.epa.gov/indian/pdfs/gap2000.pdf. Last accessed May 2007.
3-8
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approximately 90 percent show quality improvements in subsequent submittals. In addition,
work plans and progress reports may fulfill the basic criteria for completeness but still lack
adequate detail. Work plan and report templates have contributed to this problem in one region.
A few POs view the use of the standard work plan format recently implemented nationally by
EPA as having positively influenced quality, but others report that the new format has caused
some declines in quality due to the need for time to become familiar with the new format, as well
as tribal concern over changing expectations. Negotiations conducted with tribes during the
development of earlier standard formats in two regions have facilitated tribal acceptance of the
new formats, and have helped ease the transition to using them. As with timeliness, the quality
and completeness of work plans and progress reports has continued to improve with the
increased experience and stability of tribal environmental staff.
To further assess tribal execution of administrative functions, we examined the length of time
tribes took to close out their GAP grants after the date the grants ended. Our assumption, based
on prior interviews with EPA staff, is that tribes that close out their GAP grants relatively
quickly after the end of the grant period have fewer administrative requirements to address at the
end of the grant, and demonstrate greater capability to execute administrative functions. Of the
754 GAP grants awarded to the 111 tribes in our sample from 1994 through 2004, EPA's GICS
database indicates that tribes closed out 175 grants (23 percent) during this period. The amount
of time that passed between the end date and final closeout date for each grant ranged from
approximately minus 3 months (i.e., the grant was closed out prior to the grant's end date) to 51
months. On average, it took tribes about a year (13 months) to close out their GAP grants.
We also examined the results of A-133 audits conducted for the 111 tribes in the sample to
assess tribes' ability to execute administrative functions.7 As illustrated in Exhibit 3-4,
approximately 25 percent of the 111 tribes in our sample had been audited during the period
1997-2004. Of these 27 tribes, the audits for 24 resulted in at least one reportable condition,
material weakness, or material noncompliance outcome.8 Exhibit 3-5 presents the proportion of
tribes with any of these three major audit findings organized by region. The greatest number of
tribes audited was in Region 10, followed by Regions 9, 8, and 6. Audits that resulted in a
Reportable Condition also resulted in a Material Weakness. All the tribes audited in Regions 7,
8, and 9 had audit findings in these categories. Fewer tribes had audits that resulted in Material
Non-Compliance. Note that because participation in an A-133 audit is required only when a
tribe's total annual expenditures of federal funds exceed a high threshold, most of the tribes in
our sample would not likely have to undergo such an audit. As a result, the tribes in our sample
that were audited and cited with a reportable condition, material weakness, or a material non-
compliance may not be representative of the ability of the tribes not audited to execute
administrative functions pertaining to GAP grants. It may also be the case that since A-133
7 In accordance with Office of Management and Budget (OMB) Circular No. A-133 (68 FR 38401), non-
federal entities that expended $300,000 (or $500,000 for fiscal years ending after December 31, 2003) or more in a
year of federal awards, such as grants, are required to have a single or program-specific audit conducted on an
annual basis. Available from: http://www.whitehouse.gov/omb/circulars/al33/al33.html. Accessed April 2007.
8 Reportable conditions, as defined in the OMB Circular No. A-133 (68 FR 38401), constitute deficiencies
in internal control over major programs. Reportable conditions may be individually or cumulatively material
weaknesses. Material noncompliance means noncompliance with the "provisions of laws, regulations, contracts, or
grant agreements related to a major program."
3-9
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audits include a review of all federal expenditures for a tribe, the findings recorded in the Audit
Database for tribes in our sample may not be related to tribal fiscal performance under GAP.
Exhibit 3-4: A-133 Audit Findings, 1997-2004 (n = 111)
Tribes Audited but no
Problems Identified
3%
Tribes Not Audited
76%
Tribes Reporting a Material
Weakness, Reportable Condition, or
Material Non-Compliance
22%
Exhibit 3-5: A-133 Audit Findings by Region, 1997-2004 (n = 111)
EPA
Region
1
2
4
5
6
7
8
9
10
Number of
Tribes in
Sample
2
1
1
7
14
2
6
30
48
Percent of
Tribes in the
Sample that
were Audited
0%
0%
0%
29%
29%
50%
83%
20%
19%
Percent of Tribes
Audited with a
Reportable
Condition
-
-
-
50%
75%
100%
100%
100%
78%
Percent of Tribes
Audited with a
Material
Weakness
-
-
-
50%
75%
100%
100%
100%
78%
Percent of Tribes
Audited with a
Material Non-
compliance
-
-
-
50%
50%
0%
60%
50%
33%
Percent of Tribes
Audited with no
problems
reported
-
-
-
50%
0%
0%
0%
0%
22%
3-10
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Regional POs identified only a few tribes that had received a major finding on an A133 audit.
POs said these audit findings mainly cited problems with tribes' practices in tracking and
documenting expenditures, such as incomplete time and attendance records for environmental
staff on the GAP payroll. In addition, audits revealed some concerns about tribes' ability to
track the non-Federal share of their funding and the use of GAP funds when those funds were
combined with other grants (e.g., when GAP funds and other grants were pooled to purchase
equipment). At the regional level, the grants administration office often assumes responsibility
for reviewing tribes' management of GAP grants while POs focus their reviews of grantee
progress on activities funded by GAP. For regional on-site GAP grant management reviews,
POs report that a majority of tribes receive positive reviews, but in the small number of instances
where problems are identified, the regions work directly with the tribes to correct them. In one
region where GAP grants are incorporated into tribal PPGs, all regional program staff involved
in the PPG, including senior managers, participate in the reviews and the development of follow-
up action items with the tribes.
D. How Participation in GAP Influences Understanding of the Process Required to
Develop a Tribal Environmental Program
In addition to assessing the direct resource outputs provided by GAP, the evaluation seeks to
discern how tribal participation in GAP and utilization of GAP resources has influenced, 1)
tribes' understanding of the process required to develop an environmental program, and, 2) the
way tribes approach the various administrative and programmatic functions associated with the
development process. Tribal representatives emphasize that instead of changing tribal
understanding of how to develop an environmental program, GAP facilitates tribes' ability to
develop a program that is responsive to each tribe's unique environmental conditions and
priorities. GAP resources enable tribes to establish an environmental presence, which in turn
provides the foundation upon which each tribe can build an environmental program tailored to
meet its needs. From EPA's perspective, however, GAP may influence and clarify tribal
priorities as tribal environmental staff acquire training, learn about specific environmental
conditions on tribal lands, and become more aware of concrete program opportunities through
their interactions with EPA regional tribal and media program contacts.
Although tribes' maintain the view that GAP has not directly changed their environmental
priorities or their understanding of what is needed to achieve them, they acknowledge that on a
practical level, GAP has helped them develop a planning perspective, specifically, establishing
and refining the annual goals in their work plans to support their priorities. One tribe noted that
the progress made toward the goals outlined in its GAP work plan in a given year influences the
priorities it establishes for the next year. As another tribe observed, however, the goals EPA
establishes for GAP in a given year might target an emerging EPA priority, such as children's
health, which may not correspond with tribal environmental priorities.9 Under these
circumstances, tribes may enter into negotiations with EPA to resolve differences but end up
modifying their approach to align with the GAP goals in order to secure needed funding.
9 The divergence between tribal and EPA goals may be more of an issue for tribes seeking media-specific
funds from EPA, rather than GAP funding, since GAP funds may be used to address tribal priorities.
3-11
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With regard to the influence of GAP on the administration of tribal environmental programs,
tribes stress that the continuity of GAP funding provides them with the means to hire, train, and
keep qualified, environmental professionals. Retaining a qualified, knowledgeable staff person
allows tribes to effectively manage their GAP funds, carry out activities proposed in their work
plans, and seek opportunities to further expand and diversify their environmental programming
in response to tribal priorities. GAP facilitates tribes' awareness of the broader environmental
resources and infrastructure available to assist them. Through contact with GAP POs and other
personnel in each region's tribal office, tribal environmental staff learn about the media-specific
programs within EPA and external to EPA that can provide funding and technical assistance to
complement GAP activities.
GAP also facilitates the creation of partnerships among tribes, and between tribes, and outside
agencies and organizations, that can give tribes a voice in addressing environmental concerns on
and off the reservation. Most tribal representatives assert that in addition to promoting external
communication, GAP has influenced how tribes communicate internally to tribal members and
council about environmental concerns. Tribes use GAP funds to develop environmental and
cultural education programs for tribal youth and prepare outreach materials, such as monthly
newsletters and radio announcements. The education and outreach conducted by tribal
environmental staff helps to build community recognition for environmental activities on the
reservation and raises the credibility of the tribal environmental program and its
accomplishments. For example, one tribal representative mentioned that GAP assistance helped
the tribe gain recognition in the community for its environmental leadership. The environmental
director and staff formed committees to raise awareness among tribal members and involve them
in establishing environmental priorities on the reservation.
III. INDICATORS OF TRIBAL ENVIRONMENTAL CAPACITY
An important objective of the evaluation is to determine how effective GAP has been in building
tribal environmental capacity among tribes receiving GAP funds. For the purpose of this
evaluation, we are using a definition based on EPA's 2000 GAP Guidelines: "environmental
capacity" means that a tribe has established the administrative, legal, technical, and enforcement
capability necessary to develop and implement a tribal environmental program, as well as the
communications capability to work with federal, state, local, tribal, and other environmental
officials. This section attempts to answer this question in detail by: 1) identifying the indicators
of environmental capacity, as defined by GAP, tribes, and regional POs; 2) assessing the extent
to which tribes have "achieved" environmental capacity given the presence of these indicators;
3) identifying other factors that may influence the development of tribal environmental
programs; and 4) determining how GAP has contributed to tribal environmental capacity relative
to these other factors.
A. Tribal and Regional Perspectives on Indicators of Environmental Capacity
Not withstanding the GAP definition of environmental capacity and the five indicators
incorporated within, we asked tribal representatives and regional POs to provide their
perspective on what it means for a tribe to have attained environmental capacity. Tribes tend to
define environmental capacity more generally than GAP and equate it with a variety of key
3-12
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indicators, as shown in Exhibit 3-6. Many of the tribal definitions of capacity and indicators fall
within the GAP category of technical capability, e.g., the hiring and training of qualified
environmental professionals and the expansion of tribal environmental programming efforts to
include media-specific components. A few tribes linked environmental capacity with legal or
enforcement capability. One tribal representative equated environmental capacity with three
broad indicators: 1) the ability of tribes to recognize environmental problems, 2) the ability of
tribes to address the problem and take immediate action to protect health and the environment,
and, 3) the ability (i.e., knowledge and capability) of tribes to prevent the problem from
happening again. By that person's estimation, 90 percent of tribes have met the first indicator,
35-50 percent have met the second, and only 10 percent have met the third.
Exhibit 3-6: Tribal Definitions of Environmental Capacity and Key Indicators
Definitions
Key Indicators
Having an environmental presence - the ability to
respond quickly to environmental issues and
implement environmental initiatives in response to
tribal concerns as they arise.
The ability to attract, hire, train, and sustain
qualified environmental staff to regulate tribal
environmental programs across all media areas.
The ability to build tribal awareness and
understanding of environmental conditions on tribal
lands.
The ability to carry out environmental protection via
the development of codes and ordinances.
The ability to enforce environmental permits and
conduct compliance actions on reservation lands.
Progression over time from a single multi-media
program with one staff person to multiple program
areas with support staff.
Trained staff and growth of programs with media
grants.
The degree of institutionalization of environmental
programs and the reliance of the tribe on the
technical expertise of its environmental director and
staff.
A functioning environmental program with all five
individual components - administrative, legal,
technical, enforcement, and communications.
Establishing a water quality system and standards,
receiving Treatment As a State (TAS), and being
able to run the program efficiently for the
betterment of the tribe.
Convergence of the tribe's environmental program
with its economic development strategy.
Protection of tribes' sovereign right to protect water,
land, air.
Regional POs identified many of the same key indicators of capacity as tribes, such as tribes'
ability to establish an environmental presence; retain qualified, knowledgeable staff over the
long-term; and diversify their environmental programming. These POs see the longevity and
expertise of staff as the primary means by which tribes achieve success. Seasoned staff are adept
at finding solutions to environmental problems, they participate more fully in regional
networking opportunities (e.g., RTOC calls), they provide mentoring to other tribes, and they are
likely to have comprehensive programs funded by multiple grants. POs also pointed to the
development of legal and enforcement capability as an important indicator; one PO
acknowledged, however, that while many tribes have developed codes and ordinances, few have
the capability to enforce them. Another PO cited direct positive results, such as when a tribe's
efforts lead to a demonstrable change in behavior or environmental outcomes for tribal members,
as an important indicator.
3-13
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B. The Extent to Which Tribes Have Achieved Environmental Capacity
In order to determine the extent to which tribes in our sample have achieved environmental
capacity as defined by GAP, we examined tribal capability in each of the five indicator areas -
technical, legal, enforcement, administrative, and communication. We identified a set of coded
activity types for each indicator and equated tribal capability in that area with a tribe's
participation in one or more related activity. Exhibit 3-7 lists the activity types selected to
demonstrate tribal capability for each indicator and the proportion of the 96 tribes that
participated in activities within each type during 2000-2004. For legal capability, we identified
three activity types: activities to increase legal capability and the development and/or adoption of
codes, ordinances, and standards.10 For enforcement and administrative capability, we identified
only one activity type for each: activities to increase enforcement capability and activities to
increase fiscal administrative capability, respectively.11 For technical capability we identified
four activity types: the hiring of a professional employee, and participation in water, waste, or
air activities.12 For communications capability we identified three activity categories: general,
internal, and external communication activities.
Exhibit 3-7: Tribal Achievement of Environmental Capacity, 2000-2004 (n = 96)
Type of Tribal
Capacity
Legal
Enforcement
Technical
Administrative
Communications
Indicator of Environmental Capacity
Developed a Code, Ordinance, or Standard
Participated in an Activity to Increase Legal Capacity
Adopted a Code, Ordinance, or Standard
Participated in an Activity to Increase Enforcement Capacity
Hired a Professional Employee
Participated in Water Activities
Participated in Waste Activities
Participated in Air Activities
Participated in an Activity to Increase Fiscal Administration Capacity
Participated in Internal Communication Activities
Participated in External Communication Activities
Participated in General Communication Activities
Number
of Tribes
25
24
7
25
86
70
70
47
15
68
66
28
Percent of
Tribes
26%
25%
7%
26%
90%
73%
73%
49%
16%
71%
69%
29%
10 The development of codes, ordinances, and standards includes the development of permitting/licensing
authority and water quality standards.
11 Enforcement activities include all activity descriptions containing the keywords "enforce" or "inspect."
Activities to increase fiscal administration capability comprise activities related to the development of standards for
property management, procurement, and general fiscal administration.
12 Water activities include ground water, non-point source, point source, source water protection, UIC,
watershed, and wetlands. Waste activities include hazardous waste, recycling, and solid waste. Air activities
include external and indoor air.
3-14
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Exhibit 3-8 presents the number and percent of tribes that achieved at least one indicator for each
category of environmental capacity during the period 2000-2004. For example, in Region 1, one
of the two tribes in the region achieved at least one indicator of technical capacity, while in
Regions 10, 33 of the 34 tribes in the region achieved at least one indicator of technical capacity.
This exhibit shows that, overall, the vast majority tribes have achieved at least one measure of
capacity in the areas of technical and communications capability. Approximately one-third of
tribes have achieved at least one measure of legal capability, while fewer tribes have achieved
enforcement and administrative capacity.
Exhibit 3-9 shows the number and proportion of tribes that demonstrated capability in multiple
categories of capacity during the same time period. For example, in Region 1, one of the two
tribes did not demonstrate capability in any of the indicator categories (legal, enforcement,
technical, administrative, or communications capability). The second tribe in the region
demonstrated capability in only one of these categories. Forty-four percent of tribes
demonstrated capability in two categories of capacity, 24 percent demonstrated capability in
three categories, and 21 percent demonstrated capability in four categories of capacity.
3-15
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Exhibit 3-8: Number and Percent of Tribes that Achieved at Least One Indicator for Each Category of Environmental Capacity,
by Region, 2000-2004 (n = 96)
Region
1
2
4
5
6
7
8
9
10
Total
No. Tribes in
Sample with
Data
2
1
1
7
14
2
6
29
34
96
Legal
Number
0
0
1
2
2
0
2
12
14
33
Percent
0%
0%
100%
29%
14%
0%
33%
41%
41%
34%
Enforcement
Number
0
1
1
4
3
0
2
10
4
25
Percent
0%
100%
100%
57%
21%
0%
33%
35%
11%
26%
Technical
Number
1
1
1
7
14
2
6
29
33
94
Percent
50%
100%
100%
100%
100%
100%
100%
100%
97%
98%
Administrative
Number
0
0
0
0
0
1
1
9
4
15
Percent
0%
0%
0%
0%
0%
50%
17%
31%
12%
16%
Communications
Number
0
1
1
4
10
1
4
27
32
80
Percent
0%
100%
100%
57%
71%
50%
67%
93%
94%
83%
Exhibit 3-9: Number of Categories of Environmental Capacity for which Tribes Achieved at Least One Indicator, by Region, 2000-2004 (n = 96)
Region
1
2
4
5
6
7
8
9
10
Total
No. Tribes in
Region with
Data
2
1
1
7
14
2
6
29
34
96
Zero
Number
1
0
0
0
0
0
0
0
0
1
Percent
50%
0%
0%
0%
0%
0%
0%
0%
0%
1%
One
Number
1
0
0
0
2
1
1
1
3
9
Percent
50%
0%
0%
0%
14%
50%
17%
3%
9%
9%
Two
Number
0
0
0
4
10
0
3
9
16
42
Percent
0%
0%
0%
57%
71%
0%
50%
31%
47%
44%
Three
Number
0
1
0
3
1
1
0
8
9
23
Percent
0%
100%
0%
43%
7%
50%
0%
28%
27%
24%
Four
Number
0
0
1
0
1
0
2
11
5
20
Percent
0%
0%
100%
0%
7%
0%
33%
38%
15%
21%
Five
Number
0
0
0
0
0
0
0
0
1
1
Percent
0%
0%
0%
0%
0%
0%
0%
0%
3%
1%
3-16
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Technical Capability
Ninety-eight percent of the 96 tribes in our sample participated in activity types associated with
technical capability. Within this indicator category, 90 percent of the 66 tribes for which we had
GAP position data hired at least one professional or technical employee with GAP funding.
Exhibit 3-10 presents the number of professional and technical full-time equivalent (FTE) staff
supported by GAP. Tribes hired more professional staff (an average of 0.8 FTEs), which
included environmental program directors or managers, than technical staff (an average of 0.4
FTEs). These results suggest that tribes depend primarily on GAP funding to hire full-time
environmental directors and managers but may rely on GAP in combination with other funding
sources to hire technical personnel for specific programs or to perform discrete tasks.
Exhibit 3-10: Number of Full Time Equivalent Positions (FTEs) funded by GAP,
2000-2004 (n = 66)
Category
Professional
Technical
Total Professional and
Technical FTEs
Total FTEs provided by GAP
53.4
27.7
81.2
FTEs per Tribe
0.8
0.4
1.2
To assess the scope of tribal technical capability supported by GAP, we examined tribes'
participation in activities in three media-specific program areas. As shown in Exhibit 3-11,
nearly three-quarters (73 percent) of the 96 tribes participated in either a water or waste activity.
Approximately half participated in an air activity. Exhibit 3-12 displays the number and
proportion of tribes in each region that participated in these media-specific areas. Regions 2, 5,
6, 8, 9 and 10 had tribes that participated in activities in all three media areas; Regions 2 and 5
had the highest rates of tribal participation across the three areas. The rates of tribal participation
in Regions 1, 2, 4, and 7 may be a function of the small number of tribes included in the sample
for each region.
Exhibit 3-11: Number and Percent of Tribes with Media-Specific Activities,
2000-2004 (n = 96)
Media Area
Water
Waste
Air
Number of Tribes
70
70
47
Percent of Tribes
73%
73%
49%
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Exhibit 3-12: Number and Percent of Tribes Participating in Activities in Each Media Area,
by Region, 2000-2004 (n = 96)
Region
1
2
4
5
6
7
8
9
10
Number of Tribes
with Activity
Information
2
1
1
7
14
2
6
29
34
Water Activities
Number
1
1
1
6
10
2
6
21
22
Percent
50%
100%
100%
86%
71%
100%
100%
72%
65%
Waste Activities
Number
0
1
0
7
8
0
4
22
28
Percent
0%
100%
0%
100%
57%
0%
67%
76%
82%
Air Activities
Number
1
1
0
6
7
1
4
12
15
Percent
50%
100%
0%
86%
50%
50%
67%
41%
44%
Tribes engage in many activities specific to the media program areas, although there appears to
be a greater diversity of activities in the water and waste categories than in the air activity
category. Exhibit 3-13 lists examples of the kinds of activities conducted in each area, as
described by tribal representatives.
Exhibit 3-13: Examples of Media-Specific Program Activities Conducted by Tribes with GAP Funding
Water Activities
Waste Activities
Air Activities
Water quality planning
Development of water quality
standards
Surface water monitoring
Well monitoring and
compliance
Water sample analysis
Riparian zone protection
Sewage treatment permitting
Wetlands - survey, permitting
Mercury testing in fish
Certification of staff
QA/QC for macroinvertebrate
identification
Development of solid waste,
recycling, and burn barrel
ordinances
Solid waste - open dump
cleanup; waste inventory
Recycling - electronics, motor
oil
School chemical cleanup
Hazardous spill cleanup
Indoor air quality monitoring
Communications Capability
Eighty-three percent of tribes in our sample participated in one or more activity types associated
with communication capability (Exhibit 3-9). As shown in Exhibit 3-8, 71 percent of tribes
participated in internal communication activities, (e.g., with the tribal council, tribal members,
schools, and other tribal offices). A nearly equal proportion, 69 percent, participated in external
communication activities (e.g. with other tribes, EPA, other Federal and non-federal agencies,
and non-governmental organizations). Only about 30 percent of tribes reported participating in
general communication activities that could not be specified as either internal or external
communication. Regions 1, 4, 9, and 10 had the highest rates of tribal participation in activities
3-18
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associated with communications capability. Neither tribe in our sample from Region 1
participated in these types of activities. As discussed in Section II.D., GAP supports a range of
internal and external communications activities, from developing partnerships with federal
agencies to preparing outreach materials for tribal youth.
Legal and Enforcement Capability
Approximately a third of tribes (34 percent) in our sample met at least one indicator of legal
capability (see Exhibit 3-8). While approximately a quarter of tribes participated in general
activities to increase legal capacity or developed a code, ordinance, or standard, far fewer (7
percent) actually adopted a code, ordinance, or standard (see Exhibit 3-7). Regions 4, 9, and 10
had the highest proportion of tribes in our sample that demonstrated legal capability. Regions 1,
2, and 7 had no tribes that demonstrated this capability. That fewer tribes in our sample had
demonstrated legal capability compared to other indicators runs counter to the experience of
tribal representatives who participated in the panel discussions. Many tribes said they had
developed codes and ordinances for solid waste and water quality, among other programs, with
assistance from GAP. The difference may be a function of the limited time period, 2000-2004,
for which data were available on tribal activities. Depending on when tribes in the sample first
received GAP funding, they may have conducted activities related to legal capability,
particularly the development of tribal codes and standards, either prior to the start or after the
conclusion of this period. Tribes may have also participated in legal activities, including code
and standards development with support provided from non-GAP funding sources. According to
one tribal representative, the tribe provides its own legal staff to assist the environmental
program with its legal activities.
Fewer tribes in our sample demonstrated enforcement capability than legal capability. As shown
in Exhibit 3-7, just over a quarter of tribes participated in inspections or other enforcement-
related activities. Regions 2, 4, and 5 had the highest proportion of tribes that participated in
these activities. No tribes in Regions 1 or 7 participated in activities associated with the
development of enforcement capability from 2000-2004. Section II.B. describes some of
enforcement activities conducted by tribes with support from GAP. Tribal enforcement
capability may be a function of tribes' ability to develop and adopt their own codes, ordinances,
and standards. While the proportion of tribes shown to have demonstrated enforcement
capability is consistent with the assessments of POs, it is possible that tribes may have conducted
enforcement activities or inspections outside the period for which GAP activity data were
available or may have funded these activities with non-GAP support.
Administrative Capability
Only 16 percent of tribes in our sample participated in activities related to administrative
capability (Exhibit 3-8). Fewer tribes have demonstrated capability in the administrative area
than any other indicator. As mentioned above, for the purposes of this analysis we defined
administrative capacity as tribal participation in activities related only to fiscal administrative
capability, including the development of procurement and property management standards.
Our narrow focus on fiscal administrative capability likely omitted tribal participation in other
administrative activities, such as grants administration, which tribes may have conducted as a
component of their media-specific programs. The observations of the regional POs discussed in
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Section II.C. regarding the extent to which tribes are meeting expectations for grants
management and execution of administrative functions suggest that contrary to this finding,
tribes have increased their administrative capability over time.
C. Factors that Contribute to the Achievement of Environmental Capacity
In addition to requesting tribal and regional input on the most important indicators of tribal
environmental capacity, we asked tribes and POs to identify factors that impact environmental
capacity and describe how they influence tribal efforts. We found considerable overlap between
the key indicators of capacity identified by tribes and POs and the factors they cited, which
influence capacity. For example, the ability of a tribe to hire and retain knowledgeable
environmental staff is considered to be both a factor influencing capacity and an indicator of
tribal environmental capacity. In other words, tribes need committed, trained professionals to
develop their environmental programs, and tribes with established environmental programs are
more likely to have a stable, qualified staff.
We presented POs with a list of potential factors and asked them to rank each on a Liechart scale
according to the degree to which it influences the ability of tribes in their respective regions to
attain environmental capacity. Exhibit 3-14 lists the factors that a majority of POs identified as
more (almost always or often) and less (sometimes., seldom, or almost never) influential. The
rankings suggest that the tribal council's relationship with a tribe's environmental program and
its director, demonstrated by the level of support and clarity of direction it provides, significantly
impacts a tribe's ability to attain environmental capacity. POs reported that stable funding is the
most critical factor affecting the longevity of tribal environmental staff, but emphasized that the
actions of tribal council can also lead to staff turnover when there is a lack of communication
between a tribe's environmental director and council members, or when tribal elections result in
a change in leadership. The frequent departure or replacement of trained tribal environmental
staff can deprive tribes of the institutional expertise needed to sustain continuity and grow their
environmental programs. Staff turnover can also diminish other factors that build capacity, such
as information sharing among tribes, communication with EPA, and access to non-GAP funding.
Historically, POs report that the term of employment for a tribal environmental director has
varied across tribes, ranging from a low of <1 year to a high of 20 years, with an average of
approximately 2 to 10 years, depending on the region.
Another potential measure of a tribal council's support for the tribe's environmental program is
its commitment of tribal funding. According to one PO, a tribe's willingness to support the
environmental program with its own money means the tribe values the program enough to help it
succeed. For example, a tribe in the region conducted extensive community outreach among
tribal members to obtain their ideas for a creek restoration project. The tribal council's
investment of discretionary funds, in addition to their official endorsement, was critical in
providing the environmental program with the means to sustain community participation in its
planning and restoration efforts.
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Exhibit 3-14: Factors that Project Officers Said Influence Tribal Environmental Capacity
(in descending order of importance)
More Influential (Almost Always or Often):
• Tribal council support for environmental programs
• Qualifications of tribal environmental director and/or staff
• Turnover rate of tribal environmental director and/or staff
• Clear tribal environmental priorities
• Degree of information sharing among tribes
• Access to funding outside of GAP
• Experience, knowledge, and longevity of EPA POs
• Rate of change in tribal government leadership (e.g., council members)
• Frequency with which tribes request information from EPA
Less Influential (Sometimes, Seldom, or Almost Never):
• Year-to-year shifts in funding priorities due to changing priorities at EPA
• Cohesiveness of a tribe's land base
• Planning documents prepared by tribes (e.g., five year plans)
• Extent to which the regions consult with tribes
• Changes in the GAP funding process
• Different perceptions about funding priorities between tribes and EPA
• Status of tribal office in region (e.g., its location in the organizational chart)
The factors tribal representatives consider most influential correspond with many of the factors
that POs identified as affecting tribes' ability to build capacity, including the stability of
knowledgeable tribal environmental staff, effective communication between tribes and EPA
regions, and the support of tribal council for planning and funding environmental programs
relative to other tribal priorities (e.g., healthcare and economic development). Tribes also
identified factors related to EPA's activities that influence tribes' environmental capacity,
including the need of EPA regional tribal office staff to clearly convey their expectations for
GAP, provide timely responses to grant applications and requests for assistance, and be proactive
in consulting with other EPA media programs. Additional factors mentioned by tribes that
influence capacity include the existing tribal infrastructure and history of successful
implementation of tribal programs, jurisdictional issues, and the length of time a tribe has been
federally recognized.
Tribes stressed that consistent access to funding across a range of media areas is critical to their
ability to build environmental capacity and expand their programming to respond to tribal needs.
Since GAP does not fund implementation activities and many media-specific grants are
competitive, tribes cannot be assured that they will have the funds to maintain their programs
from year to year. One tribe indicated that the ability of EPA to find ways to fit a broader array
of tribal environmental activities within the GAP guidelines is one way to address funding
consistency and help tribes attain environmental capacity. Another suggested that the Treatment
as a State (TAS) designation, if tied to sustained funding such as states receive, could help
ameliorate this problem.
A number of the most influential factors, such as the level and consistency of GAP funding
available to sustain and train tribal environmental staff, the timely provision of technical
3-21
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assistance, access to non-GAP EPA funding, and effective communication with tribes, remain
within the purview of EPA. Other factors related to a tribe's internal structure and leadership,
including the clarity of tribal environmental priorities, the rate of change of tribal leaders, and the
support provided by tribal council for planning and funding environmental programs, are,
however, generally beyond EPA's direct control. Yet, given the significant role of GAP and
other EPA support in building, promoting, and sustaining tribal environmental programs, EPA
may still have the ability to indirectly influence these internal tribal factors.
D. Relative Contribution of GAP Toward Achieving Environmental Capacity
As discussed above, there are many factors that can potentially affect tribes' achievement of
environmental capacity such as GAP funding and technical assistance, the stability of tribal
leadership and staffing, and the degree to which Tribal council members focus on environmental
concerns. Another potential factor is tribal access to other sources of funding (e.g., EPA media
programs, other federal and state agencies, and tribes themselves).
Interviews with tribal representatives and POs make clear that they perceive GAP funding as
essential to achieving environmental capacity. Many tribes say that without GAP funding, they
would be able to do very little environmental work. They stress that GAP is the foundation for
their environmental programs, and GAP resources enable them to establish a basic program
infrastructure, through which they can apply for other types of environmental funding. This
view supports a basic premise of the GAP program, namely, that as GAP helps tribes build their
environmental capacity, tribes will be able to access other sources of funding to support their
environmental programs.
If this view is correct, it should be evident from the data on the types of grants tribes are
accessing to support their environmental programs. We would expect tribes that had accessed
GAP for a longer period of time would have built environmental capacity to a greater degree,
would have more established environmental programs, and as a result would be more able to
obtain greater amounts of non-GAP funding than tribes that had accessed GAP over a short time
period. To test this hypothesis, we conducted an analysis of the amount of non-GAP grants
receive by tribes in our sample. Note that because we only had access to data for EPA grants,
this analysis does not include any non-EPA grants (such as water resources funding available
through other federal agencies like the Bureau of Indian Affairs). Out of the 111 tribes in our
sample, 69 (62 percent) received at least one non-GAP EPA grant. Exhibit 3-15 lists the number
of non-GAP EPA grants in each category awarded to tribes in our sample (in descending order),
along with the total amount of funding awarded in each category, the number of tribes in our
sample that received each type of grant, the average grant amount awarded, the average
cumulative amount awarded to each tribe that received a grant, and the average number of grants
awarded to tribes in each category. Tribes in our sample received a total of $89,251,881 in non-
GAP EPA grant funding from 1994-2004. They most often received grants in the general water,
multimedia, and air categories. On average, individual tribes received the most total funding
from general water, water point-source, and multimedia grants. Appendix J lists examples of the
non-GAP EPA programs and other federal agencies identified by tribes that provided funding
and/or technical support.
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Exhibit 3-15: Number and Dollar Amount of Non-GAP EPA Grants Awarded to Tribes,
by Grant Category, 1994-2004 (n=lll)*
Category
Water
Multimedia
Air
Land
Land
Water
Land
Water
Land
Air
Water
Other
Special
Emphasis
Land
Other
Land
Water
Land
Special
Emphasis
Land
Land
Subcategory
Pesticides
Superfund
Wetlands
Lead
NFS
Solid Waste
IAQ
Source water
protection
Education
Environmental
Justice
UST
Brownfields
Point Source
Emergency
Response
Pollution
Prevention
Hazardous Waste
Persistent
Organic
Pollutants
Number of
Grants
386
198
93
93
59
57
52
52
43
41
36
28
26
24
23
7
7
6
6
4
1
Total Funding
Awarded
$28,349,377
$15,856,844
$8,559,419
$3,217,600
$4,824,484
$3,773,206
$2,887,537
$3,648,428
$1,237,792
$1,968,785
$5,998,683
$1,496,762
$737,370
$1,132,701
$1,283,880
$1,360,939
$2,271,025
$145,975
$207,889
$243,185
$50,000
Number of
Tribes with
Grant
56
41
24
16
19
29
19
13
20
13
16
16
19
8
10
6
5
6
4
2
1
Average
Grant
Amount
$73,444
$80,085
$92,037
$34,598
$81,771
$66,197
$55,530
$70,162
$28,786
$48,019
$166,630
$53,456
$28,360
$47,196
$55,821
$194,420
$324,432
$24,329
$34,648
$60,796
$50,000
Average
Total
Amount
Awarded per
Tribe
$506,239
$386,753
$356,642
$201,100
$253,920
$130,110
$151,976
$280,648
$61,890
$151,445
$374,918
$93,548
$38,809
$141,588
$128,388
$226,823
$454,205
$24,329
$51,972
$121,592
$50,000
Average
Number of
Grants per
Tribe
6.9
4.8
3.9
5.8
3.1
2.0
2.7
4.0
2.2
3.2
2.3
1.8
1.4
3.0
2.3
1.2
1.4
1.0
1.5
2.0
1.0
*Funding amounts are rounded to the nearest whole dollar.
We then analyzed the sequence of GAP and non-GAP EPA funding between 1994 and 2004 for
the 111 tribes in the sample. Based on our hypothesis, we anticipated that tribes would access
GAP funds first, followed by non-GAP funds. We found, however, that GAP funds tend to be
accessed year after year, and therefore, a majority of tribes in our sample (90 percent), received
non-GAP EPA funds concurrently with GAP funding. For the remaining tribes that did not
receive non-GAP EPA funds concurrently with GAP funds, about four percent them received
GAP funding first, while about seven percent received non-GAP EPA funding first.13 With
These figures do not add to 100 percent because of rounding error.
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regard to the sequencing of GAP and non-GAP EPA funding, one PO noted that non-GAP EPA
funding was the first type of funding available to tribes. Specifically, Clean Water Act 106 funds
became available in 1989, and this funding was the first grant program accessed by many tribes.
Once GAP became available in 1994, GAP began to offer more money to tribes than other
program funds. This may also explain, in part, why tribes have accessed significantly more
water-related grants than other types of non-GAP EPA grant. Another explanation for the large
number of water-related grants awarded to tribes may be the greater amount and variety of grants
offered by EPA's water programs relative to other media programs.
Since our analysis of the sequence of grants was not informative for the majority of tribes that
received GAP and non-GAP EPA funding concurrently, we conducted an additional analysis to
compare funding patterns for tribes that received GAP early in the program's existence (from
1994 to 1999), to tribes that received GAP later (from 2000 to 2004).14 Specifically, we would
expect tribes that began receiving GAP during the earlier period ("early adopters") to have
accessed a greater percentage of funding from non-GAP EPA sources compared to tribes that
began receiving GAP during the latter period ("late adopters"). If true, this would support the
claim that as tribes receive GAP funds over time, they are able to build environmental capacity
and basic program infrastructure, and then apply for and receive other EPA funds to support their
programs. Note that the small number of late adopters in our sample limits the degree to which
we can make inferences from this analysis, since it is possible that this sample of tribes may not
be representative of the overall population of tribes that received GAP funding from 2000 to
2004.
Our comparison of early vs. late adopters of GAP shows that in fact early adopters have received
a greater percentage of their funding from non-GAP EPA sources. Specifically, as presented in
Exhibit 3-16, only 44 percent of early adopters' total EPA funding between 1994 and 2004 came
from GAP, compared to 80 percent of GAP funding for late adopters. Moreover, there is a
marked increase (1,549 percent) in the amount of non-GAP EPA funding awarded to late
adopters after they received GAP, compared to before they received GAP. This supports the
view that GAP is helping tribes expand their sources of environmental funding, which suggests
that tribes have increased their environmental capacity accordingly.
14 Based on AIEO's suggestion, we have excluded Alaskan tribes from this analysis, because the Alaska
Native Claims Settlement Act treats Alaskan tribes differently than other tribes, and they do not have access to the
same funding as other tribes. When the Alaskan tribes are removed, the sample size is reduced to 70 tribes.
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Exhibit 3-16: Comparison of GAP and Non-GAP EPA Grant Funding for
Early vs. Late Adopting Tribes, 1994-2004 (n=70)*
Number of Tribes
Number of GAP Awards
Number of Non-GAP Awards
Amount of GAP Funding
Amount of Non-GAP Funding
Percent of Total Funding from GAP Grants
Percent of Total Funding from Non-GAP Grants
Average Non-GAP Funding Per Tribe
Median Non-GAP Funding Per Tribe
Total Amount of Non-GAP Funding Received Before
GAP
Amount of Non-GAP Funding received After GAP
Percent Change in Non-GAP Funding
Early Adopters (1994-1999)
61
563
1218
$69,161,568
$87,670,474
44%
56%
$1,437,221
$707,896
N/A
N/A
N/A
Late Adopters (2000-2004)
9
31
12
$3,426,273
$874,395
80%
20%
$97,155
$40,000
$50,000
$824,395
1,549%
*The percent change in non-GAP funding is calculated only for late adopters since data were not available on early adopter receipt of
non-GAP grants for the years preceding 1994.
We also compared achievement of specified indicators of environmental capacity between early
vs. late adopters (Exhibit 3-17). This analysis shows that for five indicators of environmental
capacity (those shown in bold in Exhibit 3-17), a greater percentage of early adopters had
achieved the indicators of capacity compared to late adopters. For example, more early adopters
are participating in waste and water activities, which are both indicators of technical capacity,
compared to late adopters. However, for the remaining seven indicators of capacity, a greater
percentage of late adopters had achieved the indicators. In some cases, this is consistent with our
understanding of how GAP is intended to work. For example, more late adopters than early
adopters have hired a professional employee with GAP funds. This may be because early
adopters are now using other grants to fund salaries for professional employees. In general,
however, the results of this analysis run counter to our hypothesis that tribes that have had GAP
funding for a longer period of time would be further along in the process of developing
environmental capacity, compared to tribes that had received GAP funding for a shorter period
of time.
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Exhibit 3-17: Comparison of Achievement of Environmental Capacity
Early vs. Late Adopting Tribes, 2000-2004 (n=70)*
Type of Tribal
Capacity
Legal
Enforcement
Technical
Administrative
Communications
Indicator of Environmental
Capacity
Developed a Code, Ordinance, or
Standard
Participated in an Activity to
Increase Legal Capacity
Implemented a Code, Ordinance,
or Standard
Participated in an Activity to
Increase Enforcement Capacity
Hired a Professional Employee
Participated in Water Activities
Participated in Waste Activities
Participated in Air Activities
Participated in an Activity to
Increase Fiscal Administration
Capacity
Participated in Internal
Communication Activities
Participated in External
Communication Activities
Participated in General
Communication Activities
Early Adopters (1994-1999)
Number of
Tribes
12
12
1
21
47
43
41
29
7
38
31
24
Percent of
Tribes
(out of 57)
21%
21%
2%
37%
82%
75%
72%
51%
12%
67%
54%
42%
Late Adopters (2000-2004)
Number of
Tribes
2
0
1
2
9
6
o
J
5
4
7
8
3
Percent of
Tribes
(out of 9)
22%
0%
11%
22%
100%
67%
33%
56%
44%
78%
89%
33%
IV. GAP PROCESS OUTPUTS TO ACHIEVE TRIBAL GOALS AND PRIORITIES
Many of the tribal representatives interviewed stated that a key goal for tribes is having an
environmental presence on tribal land, i.e., a qualified staff person who can coordinate the tribe's
environmental programs, maintain a cohesive program, and be a point of contact for members of
the tribal community and neighboring communities. GAP enables tribes to establish this
environmental presence by providing the funds to hire, train, and retain professional and
technical environmental staff. As discussed in the previous section, GAP funds the salary of the
environmental director or manager, and thus enables the coordination of all environmental
program work. One tribe noted that GAP funds the salaries of environmental specialists who
conduct virtually all of the tribe's permitting work, as well as training tribal staff in specialized
topics such as GIS and Autocad. In some cases, GAP is the primary source of funding for tribal
programs. In other cases, GAP funds only a portion of environmental programs (e.g., 25 percent
of environmental programs for two tribes in EPA Region 5); however, even in these cases, tribes
consider GAP funding essential.
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Tribes emphasize how GAP provides a foundation for tribal environmental programs. One
important way that GAP does this is by providing the framework to leverage and coordinate
other resources, such as other EPA grants. GAP also provides continuity for tribal
environmental programs over time, while at the same time allowing tribes to address new and
emerging environmental issues. Tribes stress the importance of GAP's flexibility: several tribes
perceive that GAP funding has fewer "strings attached" than other sources of funding, and
therefore can be used to address tribal priorities. One tribal representative compared
environmental capacity to a bush, growing in many different directions. The branches are the
various components of a tribes environmental programs and GAP is the root.
While tribal representatives state that GAP funding is vital for establishing and maintaining an
environmental presence, many perceive current levels of GAP funding as insufficient. Several
tribes say that they have received static levels of GAP funding since the inception of the GAP
program, even as they develop new environmental programs and carry out ever more diverse
environmental program activities. For example, one tribe notes that it wants to take on issues
like recycling, green buildings, and pollution prevention, but existing funding is not sufficient to
address these emerging areas of environmental concern. One Eastern tribal representative
expressed the view that GAP funding is primarily going to tribes in the West. This leads to
insufficient funding for the tribe, which results in one staff person having to assume multiple
responsibilities, and ultimately, limits the tribe's ability to maintain environmental capacity.
When asked about additional resources tribes need to develop their environmental programs,
several tribes indicate that above all else, they need sustained, consistent funding over time to
enable them to hire and retain sufficient qualified staff, and thereby retain institutional
knowledge. GAP provides an important source of sustained funding, although some tribes note
that the requirement to re-apply for GAP funding every year takes away from the stability of the
GAP program and the staff that GAP supports. In addition to funding, tribes say they need
infrastructure (especially for water and wastewater), equipment (e.g., computers, vehicles, and
sampling equipment), and more staff to develop their environmental programs. Several tribes
also mention the need for more support from EPA on enforcement programs, including both
funding and technical support. One tribe mentioned that it would be helpful if EPA regions had
more staff available to assist tribes with enforcement and developing codes and ordinances. A
few tribes noted the difficulties of preparing TAS applications, and one tribe asked for EPA to
speed its review of these applications. Another tribe explained that it needed help in preparing
environmental assessments or environmental impact statements under NEPA.
Tribes sometimes have goals and priorities that GAP does not address, either because GAP
funding is insufficient to meet these goals, or because these goals involve implementation of
environmental programs. For example, one tribe mentioned that it has a goal of establishing
regulatory programs, and tribal staff are looking for additional funding beyond GAP to support
this goal. Another tribe said that it has goals and ordinances in place, and has trained staff, but
now needs to start implementing its environmental programs and taking enforcement actions
where needed. Overall, most tribes interviewed say that in order to meet tribal goals, they need
to be able to use GAP funding for program implementation and maintenance, and they need
additional funding to support this additional effort.
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While most tribes perceive overall consistency between GAP goals and tribal priorities, they also
pointed out that it is difficult to mesh the cultural and traditional values of the tribes with the
bureaucratic and regulatory guidelines and definitions established by GAP. For example, some
of the terms GAP uses, such as a "Tribal Environmental Agreement," carry historical and
cultural connotations that raise concerns for tribes (e.g., concerns about signing a formal
agreement with the U.S. Government). Some tribal representatives are concerned that EPA's
interest in measuring tribal capacity will create a "gold standard" that EPA is expecting tribes to
meet, and this may interfere with tribal sovereignty. One tribe recommended that EPA hire more
American Indian POs, and suggested that POs visit the tribes and tribal councils more often to
learn about their culture and the differences among the different tribes. Tribes also point out
that EPA sometimes prioritizes specific programs (e.g., brownfields) that are not in response to a
tribal priority or that tribes are not yet ready to address.15 In other cases, tribal councils want
their environmental programs to do more than what is allowed under GAP funding. For
example, one tribe noted that GAP does not support a tribe's priority to protect sacred and
historical sites from development using NEPA. Tribes emphasize that tribal sovereignty is a
critical issue. While many tribal representatives say that EPA tries hard to address tribes' needs
and priorities, others feel that EPA is seeking "manifest destiny," and is trying to change Indian
ideals and erode tribal sovereignty. Finally, many tribal representatives emphasized that EPA
has a trust responsibility with regard to tribes, and the federal government has the responsibility
to help Tribal programs grow and fulfill their potential.
V. GAP SUPPORT FOR EPA'S STRATEGIC GOAL OF INCREASING TRIBES'
ABILITY TO BUILD ENVIRONMENTAL PROGRAM CAPACITY
EPA's 2003 - 2008 Strategic Plan includes Objective 5.3, which is to build tribal capacity.
Specifically, EPA seeks to "Assist all federally recognized tribes in assessing the condition of
their environment, help in building their capacity to implement environmental programs where
needed to improve tribal health and environments, and implement programs in Indian country
where needed to address environmental issues."16 The strategic plan discusses means and
strategies for achieving Objective 5.3, and mentions the GAP program as part of this discussion.
It specifically states that "EPA will continue to distribute Indian General Assistance Program
capacity building grants with the goal of establishing an environmental presence in all 57217
federally recognized tribes in the United States." AIEO has tracked progress towards this goal in
its Goal 5, Objective 5.3 Reporting System,18 and reports that the percentage of tribes that "had
access to an environmental presence," increased from 36 percent in 1996 to an estimated 90.4
percent in FY 2006, with a peak of 97 percent in FY 2004. Note that access to an environmental
15 It is not clear whether this comment was made specifically regarding GAP, or EPA funding sources in
general.
16 The 2003 - 2008 Strategic Plan is available online at http://www.epa.gov/ocfo/plan/2003sp.pdf. Last
accessed April 2007.
17 The number of federally recognized tribes has changed since the publication of the Strategic Plan: as of
this writing there are 561 such tribes.
18 The Goal 5, Objective 5.3 Reporting System is available online at https://oasint.rtpnc.epa.gov/TATS/
tats_prv/entry_page. Last accessed April 2007.
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presence is defined as an annual dollar value of GAP funding that AIEO determines is needed to
establish an environmental presence. That dollar value equaled $75,000 in FY 1996 - 1997, and
thereafter increased to $110,000. EPA calculates the percentage of tribes with access to an
environmental presence as the total amount of GAP funding awarded to all tribes divided by the
product of the number of federally recognized tribes and the allocation needed to establish an
environmental presence (i.e., $110,000 or $75,000, depending on the year).
EPA's updated 2006 - 2011 Strategic Plan includes an updated Objective 5.3 to "improve human
health and the environment in Indian country." Specifically, EPA is working to, "protect human
health and the environment on tribal lands by assisting federally-recognized tribes to build
environmental management capacity, assess environmental conditions and measure results, and
implement environmental programs in Indian country."19 EPA has modified its strategic targets
in light of this new goal. Of the three strategic targets in the updated plan, one relates directly to
implementation of environmental programs: increasing the percent of tribes implementing
federal environmental programs in Indian country. The other two strategic targets could
potentially be addressed through GAP:
• By 2011, increase the percent of tribes conducting EPA-approved environmental
monitoring and assessment activities in Indian country to 26 percent. (FY 2005 baseline:
20 percent of 572 tribes.)
• By 2011, increase the percent of tribes with an environmental program to 67 percent. (FY
2005 baseline: 54 percent of 572 tribes.)
The strategic plan notes that, "A tribe is counted as having an environmental program for the
purposes of this measure if the tribal government has taken at least one of the following actions,
in combination with having an organizational structure which includes EPA-funded
environmental office or coordinator that has been staffed in the most recent year:
(a) Complete a Tier III TEA, as evidenced by a document signed by the tribal
government and EPA.
(b) Establish environmental laws, codes, regulations, ordinances, resolutions, policies, or
environmental compliance programs, as evidenced by a document signed by the tribal
government.
(c) Complete solid and/or hazardous waste implementation activities.
(d) Complete an inter-governmental environmental agreement (e.g., state-tribe MOA,
federal-tribe MO A, etc)."
19 The 2006 - 2011 Strategic Plan is available online at http://www.epa.gov/ocfo/plan/plan.htm. Last
accessed April 2007.
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While we do not have data to assess progress toward all aspects of these strategic targets,20 we
can say that during the period 2000-2003, 26 percent of the 96 tribes in our sample for which
have GAP activity data developed a code, ordinance, or standard, although these activities may
not be evidenced by a document signed by the tribal government. We also know that during the
same time period, 73 percent of these tribes participated in waste activities, although these may
or may not have included implementation activities.
As part of this evaluation, we asked regional POs about the extent to which they believe that
GAP's goals, objectives, and activities align with or diverge from EPA's strategic goal for tribal
environmental programs.21 Most POs responded that the GAP program is aligned with EPA's
strategic goals for tribes, in that both GAP and EPA's strategic goals seek to build tribal
environmental capacity, and GAP funds activities that are the building blocks of environmental
capacity. GAP supports four common activities that support environmental programs: outreach,
education, enforcement, and training, although the emphasis placed on any of these types of
activities will vary depending on the specific region and the tribe. GAP also enables greater
tribal participation in state and EPA environmental processes that lead to sounder environmental
decisions. For example, in the state of Washington, tribal input and data led EPA to conclude
that state-proposed water quality standards were not sufficiently protective of salmon, and EPA
ultimately required the state to revise its standard.
POs expressed concern about the limitations of GAP that restrict funding to only capacity-
building activities. In addition to building tribal program capacity, many POs believe it is
necessary for EPA to support maintenance of mature tribal environmental programs, otherwise
such programs will cease to operate, and it will be necessary to re-build program capacity. Some
POs pointed out that EPA's strategic goals for Indian country include program implementation,
but such implementation is not supported by GAP, an observation echoed by tribes. One tribe
noted that it can acquire non-GAP grants to develop multi-media programs, but the question of
whether the tribe can sustain these programs with non-GAP funds remains unanswered. Another
tribe identified the apparent contradiction between EPA's strategic performance measures, which
are tied to implementation outputs, and the focus of the GAP guidelines on core program
development and capacity building.
In addition to raising concerns about the issue of program implementation, POs identified other
challenges resulting from using GAP to meet EPA's strategic goals. One PO raised the concern
that it will be difficult for some tribes to ever have delegated authority for environmental
programs, given the frequent turnover of tribal staff. In addition, for tribes that have
"checkerboard" land holdings and non-tribal residents living within the boundaries of
reservations, tribes that seek to develop and enforce codes and ordinances may face fierce
resistance from non-tribal residents that do not accept the tribe's jurisdiction. Many POs report
that tribal needs and concerns vary widely. One PO expressed concern that regional allocations
of GAP funds do not sufficiently align with tribal needs. Since all regions get the same amount
of funding per tribe, a greater share of funding is not being distributed to those tribes with more
20 This evaluation was designed prior to the release of the 2006 - 2011 Strategic Plan, therefore it was not
tailored to measure progress toward strategic targets under this updated plan.
21 During the interview, the interviewer referred to the 2003 - 2008 Strategic Plan Objective 5.3.
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pressing environmental concerns. Another PO pointed to the difficulty of quantifying the impact
of the GAP program for a tribe, particularly the value of having a qualified staff person and
environmental presence, and demonstrating the program's contributions to EPA's strategic goals.
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CHAPTER 4: CONCLUSIONS AND RECOMMENDATIONS
The results of this evaluation clearly establish that GAP has been effective in building the
foundation of environmental capacity among tribes, defined as capability in one or more of the
five indicator areas - technical, legal, enforcement, administrative, and communications. This
capability, in turn, has allowed tribes to achieve an environmental presence in Indian country.
Many tribes consider having an environmental presence, i.e., the ability to respond promptly and
effectively to tribal environmental concerns as they arise, as the overarching indicator of
environmental capacity.
To conclude, our review of data from fiscal years 2000 - 2003, along with recent interviews and
discussions with EPA regional project officers (POs) and tribal representatives, suggests that:
• The extent of capacity-building varies across indicator areas for tribes receiving
GAP grants. All but one tribe studied has demonstrated capability for at least one
indicator; the largest proportion of tribes (44 percent) has demonstrated capability for two
indictors. Only one tribe (1 percent) demonstrated capability for all five indicators.
• Tribes receiving GAP have relatively well-developed technical and communications
capabilities. A majority (90 percent) of tribes studied have hired a professional
employee, and most have participated in water and waste activities (73 percent), as well
as internal and external communications activities (71 and 69 percent, respectively).
Tribes use GAP funding to access the training and technical assistance needed to develop
staff expertise and establish an environmental presence. GAP facilitates tribes' ability to
network with other tribes, participate in regional partnerships, and communicate
effectively with tribal Council and the reservation community about tribal environmental
priorities and initiatives.
• Tribes receiving GAP have less developed legal, enforcement, and administrative
capacity compared to the other two indicators. A quarter (26 percent) of tribes have
developed codes, ordinances, or standards with assistance from GAP, but only a few
(seven percent) have gone on to adopt them. An equal number of tribes (26 percent) have
the ability to conduct inspections or other enforcement activities. Among the tribes
studied, only 16 percent demonstrated fiscal administrative capability specific to the
development of property and procurement standards. The results of A133 audits and
regional GAP grant reviews suggest that a few tribes have experienced difficulty with
executing fiscal administrative functions, such as tracking and documenting expenditures
paid for by GAP, and tracking how GAP funds are spent when they are pooled with other
grants. Note that the data that leads to this conclusion is now several years out of date, as
with all of the other indicator data. Interviews with EPA POs suggests that tribal
administrative capacity may have increased in recent years, as described below.
• GAP has done much in recent years to clarify grant expectations and administrative
requirements for tribes, and tribes in turn are increasingly meeting these
expectations and requirements. For example, EPA has developed a standard GAP
work plan format for tribes to use, and has offered GAP management workshops. With
continued outreach and assistance from GAP POs, tribes have significantly improved
their ability to fulfill regional expectations for grants management, such as the timely
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submittal of quality work plans and progress reports. Currently, a majority of tribes in
most regions are submitting their work plans and progress reports on time. Apart from
isolated instances where fiscal problems have been documented, tribes overall almost
always or often meet their region's expectations for the execution of administrative
functions under GAP.
• Tribes report that restrictions on GAP funding that preclude using GAP grants for
program implementation are now hindering tribal environmental program
development. Tribes say that while such restrictions made sense at the outset of GAP,
the situation of tribal programs has evolved. Even though most tribes have more to do to
develop the full complement of capabilities envisioned under GAP (as evidenced by the
fact that only one percent of tribes studied have demonstrated capability for all five
indicators of environmental capacity), some tribes feel that they have already built
sufficient program capacity. These tribes now want to use their GAP funds to address
other pressing needs for program maintenance and implementation. POs agree that tribes
with mature programs have met the limits of capacity building and need funds to sustain
what has been built with GAP.
• Tribes perceive that GAP funding is essential to achieving their environmental
goals, but current levels of funding are insufficient to address tribal priorities.
Consistent, stable, and sufficient funding is a key concern of tribes, since such funding is
viewed as essential for maintaining a trained environmental staff that can respond to
tribal environmental concerns. Tribes have successfully leveraged GAP resources to
acquire additional grant funding from EPA media programs and non-EPA federal
agencies; however, tribes caution that non-GAP grants are extremely competitive and
often have more administrative requirements than GAP. These grants may come with
limits on the type of programs and activities they support and may require substantially
more matching funds than GAP. Tribes expressed concerns about relying on these grants
to implement their environmental programs when their availability and level of funding
can fluctuate from year to year.
Based on the results of our analysis and conversations with tribes, regional POs, and staff at EPA
headquarters, we offer the following recommendations to EPA's American Indian
Environmental Office for ways that EPA can enhance GAP to further support tribes' ability to
establish and sustain their environmental programs.
RECOMMENDATIONS TO EPA
Recommendation 1: Consider developing a mechanism to support Tribal program
implementation. EPA could pursue this in a number of different ways. As an initial step, EPA
headquarters and regions could continue to promote and expand the use of Performance
Partnership Grants (PPGs) by tribes. By combining GAP and other media-specific funds into
one grant, PPGs afford tribes with the flexibility to allocate funding for programs and
implementation activities that most effectively address tribal needs. They also improve
efficiency by streamlining administrative requirements for tribes, such as the preparation of work
plans and progress reports. AIEO has been encouraging use of PPGs in recent years, although
relatively few tribes are currently using them. The relatively infrequent use of PPGs is partially
due to regional preferences, but mainly a result of tribes' perception that PPGs are difficult to put
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in place and administer. Further work with tribes to communicate and possibly simplify the PPG
process could potentially increase the use of PPGs.
Note that since PPGs comprise grants that are subject to variations in funding levels and
availability, this may not be a sustainable option for tribes over the long-term. For this reason,
AIEO could eventually establish a second tier of GAP funding - "GAP plus" - to fund program
implementation for those Tribes that show they have met key indicators of capacity under GAP.
Another approach could be to establish a block grant for tribes similar to those established for
U.S. territories. In the case of a second-tier GAP grant or block grant, the guaranteed availability
of funds for implementation would alleviate the uncertainty currently associated with individual
media grants. This approach would also provide tribes with funding for program activities not
covered under the 20 grants now eligible for incorporation into a PPG. Finally, a second tier
GAP or inclusive block grant would reduce the administrative burden on tribes associated with
applying for and managing numerous grants.
Recommendation 2: Consider working with tribes and regions to enhance administrative,
legal, and enforcement capacity. To help tribes build administrative capacity, EPA could
coordinate more directly with regions to ensure that the frequency and level of programmatic
resources provided, such as GAP training and support for tribal grants management, keep pace
with tribal needs, particularly as new tribal administrative personnel are hired. For tribes that
do not have sufficient funding through GAP or other sources to develop legal services, EPA
regions could offer legal support to help tribes enact their own codes, ordinances, and standards.
In cases where tribes feel that they cannot or do not wish to implement their own environmental
laws and regulations, AIEO should coordinate directly with tribes and clarify roles between tribal
environmental programs and EPA. Although EPA considers tribal delegation of environmental
programs as an important long-term objective, TAS may not be desired or feasible for many
tribes. In these instances, AIEO should consider developing a coherent plan for working with
tribes to protect the environment, while respecting tribal sovereignty.
Recommendation 3: Raise awareness of innovative environmental policy approaches to
complement traditional codes and standards.1 For example, some tribes may benefit from a
greater emphasis on pollution prevention education, self-certification, and compliance assistance
inspections, rather than solely focusing on writing codes, conducting inspections, and taking
enforcement actions. For example, tribes may wish to consider using pollution prevention
materials that have been developed for particular sectors of concern (see, for example, materials
on sectors such as medical facilities, schools, and auto repair shops available from the Pollution
Prevention Resource Exchange2). Tribes may also wish to consider using Environmental Results
Programs (ERP), such as those that have been funded under the EPA State Innovation Grant
program, or adopting elements of ERP.3 To the extent that tribes undertake innovative
1 Innovative policy approaches could potentially used in place of traditional regulatory and enforcement
programs, if such approaches could ensure environmental protection. Innovative policy approaches could also be
used as an interim step, to be used until such time as tribes have traditional regulatory programs in place.
2 Available online at http://www.p2rx.org/P2InfoNexpert/TopicHubs 2.cfm. Last accessed April 2007.
3 Information about State Innovation Grants, including ERPs, is available online at http://www.epa.gov/
innovation/stategrants/. Note that State Innovation Grant funding is not currently available directly for tribes (but
could be available to a tribe in partnership with a state).
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approaches to preventing pollution and encouraging environmental stewardship, it would make
sense for tribes to leverage the considerable experience of EPA and states in developing
innovative policy tools and approaches, as well as specific outreach materials such as pollution
prevention and compliance assistance fact sheets. Tribes may also benefit from working together
to implement innovative approaches. For example, if tribes were interested in exploring ERP as
a potential policy approach, it may make sense for multiple tribes in a region or in neighboring
regions to work together to develop an ERP for a sector of concern. AIEO and regions could
help tribes by raising awareness of innovative policy approaches, readily available materials, and
potential funding sources.
Recommendation 4: Acknowledge cross-cultural differences, and continue working with
tribes to maintain a respectful dialog. A key difference in perspective is that tribes see GAP
funding as a right - an extension of the trust responsibility that EPA has to tribal nations. EPA
views tribes as grantees that must meet certain requirements, particularly administrative
requirements, to show that tribes are accountable for funds that have been spent. Because tribes
vary considerably in their population, land base, wealth, needs, and priorities, they feel that
environmental performance measures should be couched in terms of measuring tribes' progress
toward their goals and not achieving a single "gold standard." There is inherent tension in the
differences between tribal and EPA perspectives, but opportunities to bridge these differences
exist. From the tribes' perspective, one way to strengthen understanding is to hire more Native
Americans to serve as regional POs and tribal coordinators. More frequent site visits to tribes by
AIEO and EPA regional program staff would also help to underscore the diversity of tribal
perspective, priorities, and approaches to environmental protection.
Recommendation 5: Track progress toward achievement of the new 2006-2011 strategic
goals and targets. With the addition of new strategic targets aimed at measuring tribes
implementation of monitoring and assessment activities, EPA needs to develop indicators that
support these goals and targets (e.g., number of tribes that have completed a Tier III TEA,
number of tribes that have completed an inter-governmental environmental agreement (MOAs),
etc.), and regularly track how many tribes are meeting these indicators. At a fundamental level,
AIEO will need to ensure that its data collection systems allow for the effective capture and
tracking of indicators related to these targets. In establishing future strategic goals and targets,
AIEO will also need to consider the degree to which its proposed performance measures align
with tribal priorities and perspectives and the feasibility of tribes' of achieving them. For
example, given the reluctance of many tribes to enter into TEAs and MO As because of concerns
over tribal sovereignty, the selection of these agreements as indicators of tribal performance may
not provide the most accurate estimation of a tribe's environmental capacity or the degree to
which it has successfully implemented specific program components. Further, AIEO needs to
consider that its five-year cycle for setting strategic goals and targets may be too short to
effectively track and measure tribal progress, given that tribal environmental priorities and
abilities may necessitate implementation of programs over a longer time period.
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Appendix A
GAP EVALUATION QUESTIONS
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APPENDIX A
EVALUATION QUESTIONS
la. Is GAP being accessed by all federally recognized tribes?
Ib. Why are some tribes not involved in GAP?
Ic. Are there tribes that received GAP grants at one time but which
no longer receive GAP grants? If so, why?
2a. Are tribal governments using the resources (technical, fiscal, and
programmatic) provided as a component of GAP? How often are
GAP resources accessed?
2b. How are tribes using GAP resources?
2c. To what extent have tribes met program expectations for grants
management, execution of administrative functions, and carrying out
proposed activities?
INFORMATION THAT CAN HELP ANSWER QUESTION
• Number and percentage of federally recognized tribes that have ever received GAP funds
• Regional coordinators' perceptions as to why tribes may not seek GAP funding (these
may include having access to other sources of funds, the perception that participation in
GAP is too onerous, etc.)
• Regional coordinators' perceptions as to why tribes may have dropped of GAP grant
rolls.
• Number and type of GAP resources that have been delivered to tribes:
A GAP funding provided to tribes (i.e., fiscal resources)
A Technical assistance and media specific trainings (i.e., technical resources)
A Grants management training (i.e., programmatic resources)
• Tribal access of GAP resources:
A Tribal participation in technical and media-specific trainings
A Tribal participation in grants management training
• Tribal staff and activities funded through GAP (include solid waste implementation)
• Regional coordinators' perceptions about the quality, timeliness, and completeness of
work plans and progress reports received
• Timing of grant end date vs. final close out of the grant - this is an indicator of the degree
to which the grantee met program expectations - the shorter the period of time between
grant end date and final closeout, the more likely that tribes met expectations.
• Results of administrative post award monitoring audits
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EVALUATION QUESTIONS
INFORMATION THAT CAN HELP ANSWER QUESTION
2d. How does participation in GAP increase understanding of how to
develop a tribal environmental program?
• Self reported increase in knowledge and understanding about the necessary steps in
developing a tribal environmental program
• Self-reported increase in skills needed to develop tribal environmental programs
• Self-reported change in awareness and commitment to environmental programs in tribes
3a. What indicators of tribal environmental capacity exist?
3b. To what extent have tribes achieved environmental capacity as
suggested by the presence of these indicators?
Overarching Indicator of Tribal Environmental Capacity:
• Number of GAP recipients that secured ongoing funding from other EPA
sources. [Note that availability of other sources of funding may be a limiting
factor unrelated tribes' environmental capacity.}
• Legal Capability
• Number of GAP recipients that have developed tribal codes, standards, and/or
enforcement programs to control pollution
• Enforcement Capability
• Presence of tribal environmental staff person(s) charged with enforcement duties
• Technical Capability
• Number of GAP recipients with one or more staff specifically tasked with
managing environmental programs (e.g., Environmental Director)
• Size and composition of tribal environmental staff
• Number of environmental programs being carried out in different media annually
by tribes.
• Number of GAP recipients that have taken environmental training
• Communications Capability
• Percent of GAP recipients that have conducted community education and
outreach, based on the grant work plan
• Number of GAP recipients that have executed agreements with other
jurisdictions for management of on- or off-reservation resources
• Tribal participation in EPA or tribal workgroups and/or Task Forces
• Extent of tribal environmental staffs communication of with tribal Council
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EVALUATION QUESTIONS
INFORMATION THAT CAN HELP ANSWER QUESTION
Administrative Capability
• How long has person tasked with managing environmental programs (e.g.
Environmental Director) been in that position
• Number of major findings on A133 audits (which are conducted for any tribe
that spends $500K or more)
• On-site grants management review
3c. What factors contribute to the achievement of environmental
capacity, and what is the impact of each factor?
Tribal Priorities
Tribal Staffing
Tribal Funding
Commun ication
Degree of tribal Council support for environmental programs
Does tribe have clear environmental priorities?
Rate of change in tribal governments - how often do Council members change?
Turnover rate of tribal Environmental Director and/or staff
Qualifications of tribal Environmental Director and/or staff
Tribal Environmental Staff and/or Director salary levels
GAP funding amounts
GAP funding consistency over time (e.g., number of consecutive GAP grants awarded
over time, range and average number of consecutive GAP grants received by tribes over
time)
Tribe's ability to secure funding beyond GAP (Note, securing funding is both an
indicator of tribal environmental capacity and a factor influencing achievement of
environmental capacity - through interview discussions, try to understand whether
securing other sources of funding is more a cause or effect of success in the GAP
program.)
Degree of information sharing among tribes
Degree to which tribes request information from EPA
Degree to which EPA provides information to tribes ~ specifically extent to which tribes
receiving hands-on technical assistance, oversight, or on-site visits.
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EVALUATION QUESTIONS
INFORMATION THAT CAN HELP ANSWER QUESTION
Regional Activities
• Structure of EPA regional office - specifically, at what level the tribal office located (in
the administrators office or elsewhere - the hypothesis is that the higher the level, the
more likely it is that tribal issues will receive attention and resources).
• Experience and longevity of EPA project officers and technical contacts
• Grantee caseload for EPA project officers
3d. What is the relative contribution of GAP toward achieving
capacity?
• Sequence of grants received by tribes (i.e., do tribes receive GAP grants before other
grants? If so, this would suggest that GAP may contribute to ability to receive other
grants)
• Use of non-GAP funding
(Note - both of these indicators are limited by data on other sources of funds outside of EPA,
e.g. grants from BIA or tribes' internal funds.)
4. Is the GAP providing adequate outputs to achieve tribal goals and
priorities?
• Tribes' perceptions about whether GAP is providing the type and amount of resources
that they need to meet their environmental goals and priorities
• Are there additional resources that tribes feel they would need to have in order to address
their goals and priorities?
• Is environmental capacity building a priority for tribes receiving GAP grants?
5. To what degree does GAP support EPA's strategic goal of
increasing tribes' ability to build environmental program capacity?
• How do GAP's goals currently align with or diverge from EPA's
strategic goal for GAP and other multi-media programs?
• How do GAP's objectives align with or diverge from EPA's strategic
goal for GAP and other multi-media programs?
• How do tribal GAP activities align with or diverge from EPA's
strategic goal for GAP and other multi-media programs?
• Summary of GAP goals and objectives
• Summary of EPA's strategic goals and objectives
• Summary of tribal activities funded by GAP, and other outcomes assessed through the
evaluation
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Appendix B
INTERVIEW GUIDE FOR REGIONAL GAP PROJECT OFFICERS
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APPENDIX B
Interview Guide for GAP Regional Project Officers
[Introductions] Thank you for agreeing to talk with us today. As you may know,
this interview is part of a broader evaluation of the GAP program that we are conducting
at the request of EPA's American Indian Environmental Office (AIEO). The EPA
General Assistance Program (GAP) as envisioned by Congress includes two key
elements:
1) To provide general assistance grants to build capacity to administer environmental
regulatory programs.
2) To provide technical assistance from EPA to tribal governments and intertribal
consortia in the development of multimedia programs to address environmental issues
on tribal lands.
While tribes and EPA focus on the funding aspects of GAP, technical assistance is
a substantial and significant component of the Program. Examples of assistance include:
• EPA linking tribal staff with the appropriate EPA contacts.
• EPA-sponsored training on administrative or technical skills needed for establishing
tribal multimedia programs.
• EPA review of tribal proposals for establishing programmatic capability, such as
codes, ordinances, and management plans.
• EPA site visits to review and assist tribes with programmatic and administrative
decision making.
The purpose of this interview is to gather your perspective regarding the
effectiveness of the GAP program and how GAP supports EPA's strategic goals of
increasing Tribes' ability to build environmental capacity. Your participation in this
interview, along with input from Tribes and our initial database research, will enhance
our understanding of GAP and will form an important source of information for this
evaluation. Because "environmental capacity" is such a key concept for this evaluation,
we are using a definition based on EPA's 2000 GAP guidelines. For this evaluation,
"environmental capacity" means that a Tribe has established the administrative, legal,
technical and enforcement capability necessary to develop and implement a Tribal
environmental program, as well as the communications capability to work with Federal,
State, Local, Tribal, and other environmental officials. We ask that you base your
answers to questions about environmental capacity on this statutory definition.
We have completed our analysis of data from several EPA databases that contain
information about Tribal grants and will ask you for your insights on these preliminary
findings during this interview. Upon completion of the data collection and analysis phase
of the evaluation, we will compile the results and our conclusions in a report to AIEO,
which will be available for you to review. We anticipate that the results of this
evaluation will help AIEO demonstrate the successes of the Tribal GAP to stakeholders
and identify opportunities for improvement. Finally, we will maintain the confidentiality
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of your responses to the interview questions; any data obtained through this interview
will be analyzed in aggregate with other interview data.
Do you have any questions to ask before I start the interview?
Interview questions
1. To begin, please describe how you are involved with GAP grants in your current
position with EPA.
Evaluation Questions: (la) Is GAP being accessed by all federally recognized
Tribes? (Ib) Why are some Tribes not involved in GAP? (Ic) Are there Tribes that
received GAP grants at one time but which no longer receive GAP grants? If so,
why?
The next two questions in this interview pertain to Tribes' participation in GAP in your
Region:
2. To your knowledge, are there any federally recognized Tribes in your Region that
have not received GAP grants since 1994? If yes, what do you think is the reason
that these Tribes have not received GAP grants (choose all that apply):
a They have not applied for GAP grants. If so, why do you think they have not
applied?
a Their applications have not been accepted. If so, what led them to be not
accepted?
a They have adopted a policy of not accepting Federal grant money.
a Other reasons. (Please explain)
3. To your knowledge, are there any federally recognized Tribes in your Region that
have received GAP grants since 1994, but no longer have a GAP grant? If so,
what do you believe caused the Tribe to drop off of the GAP grant rolls?
4. For Tribes that did not receive GAP grants, do you think the lack of GAP grants
has hindered these Tribes' development of environmental programs? How?
Evaluation Question: (2a) Are Tribal governments using the resources (technical,
fiscal, and programmatic) provided through the GAP? How often are GAP
resources accessed?
According to statute, GAP was established to provide general assistance to Tribes in the
form of monetary support to build environmental capacity as well as technical assistance
for developing multimedia environmental programs on Indian lands. This next question
pertains to Tribes' utilization of all the resources -fiscal, technical, and programmatic -
provided directly and indirectly through the GAP.
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5. Overall, would you say Tribes in your Region utilize the resources (e.g., technical
assistance and training, grants management training) provided as a component of
GAP? If yes, which resources do Tribes most frequently access? Which
resources do Tribes least frequently access?
Evaluation Question: (2c) To what extent have Tribes met program expectations
for grants management, execution of administrative functions, and carrying out
proposed activities?
The next set of questions pertains to the administration of GAP grants by Tribes in your
Region for which you have oversight:
6. To what extent have Tribes in your Region met expectations established by your
region for GAP for each of the following areas?
Grants management
Execution of
administrative
functions
Carrying out
proposed activities
Almost
always
Often
Sometimes
Seldom
Almost
never
Don't
Know
7. To your knowledge, what proportion of Tribes in your Region submits GAP work
plans and progress reports on time?
8. What trends have you seen in the timeliness of GAP work plans and progress
reports submitted by Tribes in your Region over time?
9. To your knowledge, what proportion of Tribes in your Region submits GAP work
plans and progress reports that are complete?
10. What trends have you seen in the completeness of GAP work plans and progress
reports submitted by Tribes in your Region over time?
11. To your knowledge, what proportion of Tribes in your Region submits quality
GAP work plans and progress reports?
12. What trends have you seen in the quality of Tribes' GAP work plans and progress
reports over time?
Evaluation Questions: (3a) What indicators of Tribal environmental capacity exist?
(3b) To what extent have Tribes achieved environmental capacity as suggested by
these indicators? (3c) What factors contribute to the achievement of environmental
capacity, and what is the impact of each factor?
B-3
-------
13. In your experience, what is the best indicator that a Tribe is achieving
environmental capacity?
14. To your knowledge, to what extent are Tribes in your Region achieving
environmental capacity as defined by this indicator?
a Almost never
a Seldom
a Sometimes
a Often
a Almost always
15. What proportion of Tribes in your Region would you say have received funding
for environmental programs from sources other than GAP?
16. In your experience, when a Tribe secures funding from sources outside of GAP,
does that indicate that the Tribe has been successful in using its GAP grant to
develop environmental capacity?
[Provide summary of findings from database analysis of legal, enforcement, technical
and communications capabilities, and ask for comments.]
The next set of questions pertains to administrative capability achieved by Tribes in your
Region that have received GAP funding. We are considering administrative capability as
one element of environmental capacity.
17. What would you say, historically, is the average length of time for a Tribal
environmental manager or director to remain in his or her position?
18. Do you know if there have been any major findings on audits (e.g., A133, IG,
etc.) conducted for Tribes in your Region? If yes, please describe.
19. What information do you have about the results of on-site GAP grants
management reviews for Tribes in your Region?
The next set of questions pertains to factors that may influence the achievement of
environmental capacity:
20. What factors would you say are the most important contributors to Tribes' ability
to achieve environmental capacity? Please describe how these factors influence
Tribe's achievement of environmental capacity.
21. Next, I am going to read you a list of factors that may influence Tribes ability to
achieve environmental capacity. Based on your knowledge and experience, to
B-4
-------
what degree would you say each factor influences Tribes' ability to achieve
environmental capacity?
For each factor where the interviewee indicates it almost always has an influence on
environmental capacity, follow up by asking how the indicator influences
environmental capacity.
Access to funding outside
of GAP
Tribal Council support
for environmental
programs
Clear Tribal
environmental priorities
Planning documents
prepared by Tribes (e.g.,
five year plans)
Rate of change in Tribal
government leadership
(e.g., Council members)
Turnover rate of Tribal
Environmental Director
and/or staff.
Qualifications of Tribal
Environmental Director
and/or staff
Degree of information
sharing among Tribes
Frequency with which
Tribes request
information from EPA
Cohesiveness of a Tribe's
land base
The status of the Tribal
Office in your Region
(e.g., its location in the
organizational chart)
Experience, knowledge,
and longevity of EPA
project officers
Year-to-year shifts in
funding priorities due to
Almost
always
Often
Sometimes
Seldom
Almost
never
Don't
Know
B-5
-------
changing priorities at
EPA
Different perceptions
about funding priorities
between Tribes and EPA
Extent to which the
Regions consult with the
Tribes
Changes in the GAP
funding process
Almost
always
Often
Sometimes
Seldom
Almost
never
Don't
Know
Evaluation Question: (5) To what degree does GAP support EPA's strategic goal of
increasing Tribes' ability to build environmental program capacity?
The final three questions pertain EPA's strategic goal of building Tribal environmental
capacity under Goal 5.3 of its 2003-2008 Strategic Plan:
22. Based on your understanding of GAP, how do you think GAP's goals and
objectives align with or diverge from EPA's strategic goal for Tribal
environmental programs?
23. Based on your understanding of GAP, how do you think Tribal GAP activities
align with or diverge from EPA's strategic goal for Tribal environmental
programs?
24. Based on your experience, how would you change GAP to improve support for
EPA's strategic goals for Tribal environmental programs? How would you
change GAP to improve support for Tribal goals and priorities?
B-6
-------
Appendix C
DISCUSSION GUIDE FOR TRIBES
-------
Appendix C
Discussion Guide and Proposed Questions for Tribal Panel Discussion
Thank you for joining us today. This panel discussion is part of a broader evaluation of
the General Assistance Program (GAP) that we are conducting at the request of EPA's American
Indian Environmental Office (AIEO). We are conducting this discussion to solicit information
about Tribes' environmental goals and your opinions on how GAP has supported your Tribe's
environmental programming efforts. Your participation on the panel will enhance our
understanding of GAP and will form an important source of information for this evaluation.
Upon completion of the data collection and analysis phase of the evaluation, we will compile the
results and our conclusions in a report to AIEO, which will be available for you to review.
As you may know, from EPA's perspective the primary purpose of the GAP is to help
federally recognized Tribes and intertribal consortia build the basic components of a Tribal
environmental program, which may include planning, developing, and establishing the
administrative, technical, legal, enforcement, communication, and outreach infrastructure. The
primary purpose of this evaluation is to determine how effective GAP has been in building Tribal
environmental capacity among those Tribes receiving funds. Since "environmental capacity" is
such a key concept for this evaluation and we want to very clear about its meaning when we ask
about it in our questions, we are providing a definition based on EPA's 2000 GAP guidelines.
For the purpose of this evaluation, "environmental capacity" means that a Tribe has
established the administrative, legal, technical and enforcement capability necessary to develop
and implement a Tribal environmental program, as well as the communications capability to
work with Federal, State, Local, Tribal, and other environmental officials.
You may also be aware that the EPA General Assistance Program (GAP) as envisioned
by Congress includes two key elements:
1) To provide general assistance grants to build capacity to administer environmental
regulatory programs.
2) To provide technical assistance from EPA to Tribal governments and intertribal consortia
in the development of multimedia programs to address environmental issues on Tribal
lands.
While Tribes and EPA focus on the funding aspects of GAP, technical assistance is a
substantial and significant component of the Program. Examples of assistance include:
• EPA linking Tribal staff with the appropriate EPA contacts.
• EPA-sponsored training on administrative or technical skills needed for establishing
Tribal multimedia programs.
• EPA review of Tribal proposals for establishing programmatic capability, such as codes,
ordinances, and management plans.
C-l
-------
• EPA site visits to review and assist Tribes with programmatic and administrative
decision-making.
Note that this is an evaluation of the GAP program, not the Tribes. Where we ask
questions about Tribes' achievements in building environmental capacity, or barriers to those
achievements, the purpose of our question is to understand whether EPA's GAP program is
working for its intended purpose for the wide array of Tribes that receive GAP grants, and how it
could be improved. This evaluation is not intended as a critique of Tribes' environmental
achievements or a comparison of achievements across Tribes.
We will begin our conversation with introductions and then proceed with a discussion of
Tribal environmental programs and your Tribes' participation in and experiences with GAP, per
the questions below.
Introductory Questions:
Let's begin with questions about Tribes' environmental goals and priorities and their
relationship to GAP and environmental capacity. While Question 2, below, asks for Tribal
definitions of environmental capacity, we ask that you base your answers to all subsequent
questions about environmental capacity on the statutory definition provided.
A. Tribal Environmental Capacity
1. Based on your understanding of GAP, how do the program's goals compare with the
environmental goals and priorities of your Tribe?
2. How does your Tribe define environmental capacity?
3. What is the most important indicator of a Tribe's environmental capacity, as defined by
GAP?
B. Contributors to Environmental Capacity Development
4. Which factors influence environmental capacity attained by Tribes (for example, specific
characteristics of Regional EPA offices or of Tribes)?
5. How have other program areas within EPA, e.g., media programs, helped your Tribe
build environmental capacity?
6. How have non-EPA entities, e.g., other federal agencies, state agencies, and NGOs,
helped your Tribe build environmental capacity?
C-2
-------
Transitional Questions:
Next let's discuss GAP grants and their overall impact on Tribes' level of resources and
environmental programming efforts.
C. GAP Funding Support
7. In thinking about your Tribe's funding over time, how has GAP supported your Tribe's
environmental goals and priorities compared to other funding sources?
8. Which resources provided by GAP (e.g., funds, technical assistance, training) have been
most helpful to your Tribe's environmental programming efforts? Which GAP resources
have not been particularly helpful?
D. Other Sources of Support
9. What other kind of funding has your Tribe received in support of your Tribe's
environmental goals and priorities?
10. What additional resources does your Tribe need to develop your environmental
programs?
Key Questions:
Now let's talk about specific ways in which GAP has influenced Tribes' ability to carry out
environmental programs.
E. GAP Influence on Tribal Approach to Environmental Programming
11. How has GAP influenced your Tribes approach to developing and sustaining Tribal
environmental programs?
12. How has GAP influenced the way you, Tribal members, and particularly members of
your Tribal Council:
a. Establish priorities and plan your environmental programs?
b. Administer your Tribe's environmental programs, (e.g., hiring, training, funding)?
c. Communicate to others within and outside your Tribe about environmental issues of
importance to your Tribe?
C-3
-------
F. Environmental Programs Funded by GAP
13. What kinds of activities or program elements have been funded through your Tribe's
GAP grants? How does this compare to the activities or program elements funded
through other funding sources your Tribe has received?
14. Which of your environmental programs have benefited most from GAP? Which of these
programs have benefited least from GAP?
Final Questions:
15. Considering everything we have discussed so far, how would you change GAP to support
your Tribe's goals and priorities?
16. Have we missed anything?
C-4
-------
Appendix D
LIST OF TRIBES IN EVALUATION SAMPLE
-------
Appendix D
Tribes Selected for GAP Sample
EPA
Region
1
1
2
4
5
5
5
5
5
5
5
6
6
6
6
6
6
6
6
6
6
6
6
6
6
7
7
8
8
8
8
8
8
Tribe Name1
Aroostook Band of Micmac Indians of Maine
Penobscot Tribe of Maine
Seneca Nation of New York2
Miccosukee Tribe of Indians of Florida
Bad River Band of the Lake Superior Tribe of Chippewa Indians of the Bad River
Reservation, Wisconsin
Fond du Lac Band
Grand Portage Band
Grand Traverse Band of Ottawa and Chippewa Indians, Michigan (previously listed as
the Grand Traverse Band of Ottawa & Chippewa Indians of Michigan)
Keweenaw Bay Indian Community, Michigan
Lower Sioux Indian Community in the State of Minnesota
Oneida Tribe of Indians of Wisconsin
Absentee-Shawnee Tribe of Indians of Oklahoma
Cherokee Nation, Oklahoma
Kaw Nation, Oklahoma
Muscogee (Creek) Nation, Oklahoma
Otoe-Missouria Tribe of Indians, Oklahoma
Pueblo of Laguna, New Mexico
Pueblo of Picuris, New Mexico
Pueblo of San Felipe, New Mexico
Pueblo of Taos, New Mexico
Seminole Nation of Oklahoma
Shawnee Tribe, Oklahoma
Tonkawa Tribe of Indians of Oklahoma
Wichita and Affiliated Tribes (Wichita, Keechi, Waco & Tawakonie), Oklahoma
Ysleta Del Sur Pueblo of Texas
Prairie Band of Potawatomi Nation, Kansas
Sac & Fox Tribe of the Mississippi in Iowa
Sisseton-Wahpeton Oyate of the Lake Traverse Reservation, South Dakota (formerly
the Sisseton-Wahpeton Sioux Tribe of the Lake Traverse Reservation)
Skull Valley Band of Goshute Indians of Utah
Southern Ute Indian Tribe of the Southern Ute Reservation, Colorado
Standing Rock Sioux Tribe of North & South Dakota
Three Affiliated Tribes of the Fort Berthold Reservation, North Dakota
Ute Mountain Tribe of the Ute Mountain Reservation, Colorado New Mexico & Utah
In GAP
Database
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Tribes
per
Region
2
1
1
7
14
2
6
1 Per the BIA List published in 70 FR 71194 (11/25/05).
2Although limited data for the Seneca Nation of New York are included in the GAP Activity table for the
years 2000-2003, there are no data for the tribe included in the GAP Position table. For this reason, we did not list
this tribe with the other for which data are available in both the Activity and Position tables. We used data for this
tribe obtained from file reviews to complement the limited data included in the GAP database.
D-l
-------
Tribes Selected for GAP Sample
EPA
Region
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
9
Tribe Name
Agua Caliente Band of Cahuilla Indians of the Agua Caliente Indian Reservation,
California
Buena Vista Rancheria of Me-Wuk Indians of California
Cabazon Band of Mission Indians, California (previously listed as the Cabazon Band
of Cahuilla Mission Indians of the Cabazon Reservation)
Campo Band of Diegueno Mission Indians of the Campo Indian Reservation,
California
Elem Indian Colony of Porno Indians of the Sulphur Bank Rancheria, California
Enterprise Rancheria of Maidu Indians of California
Ewiiaapaayp Band of Kumeyaay Indians, California (formerly the Cuyapaipe
Community of Diegueno Mission Indians of the Cuyapaipe Reservation)
Hopi Tribe of Arizona
Jamul Indian Village of California
Kashia Band of Porno Indians of the Stewarts Point Rancheria, California
La Jolla Band of Luiseno Mission Indians of the La Jolla Reservation, California
La Posta Band of Diegueno Mission Indians of the La Posta Indian Reservation,
California
Manchester Band of Porno Indians of the Manchester-Point Arena Rancheria,
California
Middletown Rancheria of Porno Indians of California
Paiute-Shoshone Indians of the Lone Pine Community of the Lone Pine Reservation,
California
Paiute-Shoshone Tribe of the Fallen Reservation and Colony, Nevada
Pala Band of Luiseno Mission Indians of the Pala Reservation, California
Paskenta Band of Nomlaki Indians of California
Quartz Valley Indian Community of the Quartz Valley Reservation of California
Quechan Tribe of the Fort Yuma Indian Reservation, California & Arizona
Redding Rancheria, California
Santa Rosa Indian Community of the Santa Rosa Rancheria, California
Santa Ynez Band of Chumash Mission Indians of the Santa Ynez Reservation,
California
Scotts Valley Band of Porno Indians of California
Sherwood Valley Rancheria of Porno Indians of California
Tuolumne Band of Me-Wuk Indians of the Tuolumne Rancheria of California
Habematolel Porno of Upper Lake, California (formerly the Upper Lake Band of Porno
Indians of Upper Lake Rancheria of California)
Walker River Paiute Tribe of the Walker River Reservation, Nevada
White Mountain Apache Tribe of the Fort Apache Reservation, Arizona
Yavapai- Apache Nation of the Camp Verde Indian Reservation, Arizona
In GAP
Database
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Tribes
per
Region
30
D-2
-------
Tribes Selected for GAP Sample
EPA
Region
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
Tribe Name
Agdaagux Tribe of King Cove
Arctic Village
Chilkat Indian Village (Klukwan)
Chilkoot Indian Association (Haines)
Chinik Eskimo Community (Golovin)
Circle Native Community
CoeurD'Alene Tribe of the CoeurD'Alene Reservation, Idaho
Confederated Tribes of the Grand Ronde Community of Oregon
Confederated Tribes of the Siletz Reservation, Oregon
Egegik Village
Eklutna Native Village
Emmonak Village
Gulkana Village
Hoonah Indian Association
Inupiat Community of the Arctic Slope
Kenaitze Indian Tribe
Kootenai Tribe of Idaho
McGrath Native Village
Naknek Native Village
Native Village of Ambler
Native Village of Eagle
Native Village of Eyak (Cordova)
Native Village of Kivalina
Native Village of Kongiganak
Native Village of Kotzebue
Native Village of Kwigillingok
Native Village of Napaimute
Native Village of Nightmute
Native Village of Nunapitchuk
Native Village of Point Lay
Native Village of Ruby
Native Village of Selawik
Native Village of Tanacross
Native Village of Tatitlek
Native Village of Tazlina
Newtek Village
Nondalton Village
Northway Village
Organized Village of Kwethluk
Pedro Bay Village
Petersburg Indian Association
Sauk-Suiattle Indian Tribe of Washington
In GAP
Database
Y
Y
Y
No. Tribes
per Region
48
D-3
-------
Tribes Selected for GAP Sample
EPA
Region
10
10
10
10
10
10
Sample
Size
Tribe Name
Shoshone-Bannock Tribes of the Fort Hall Reservation of Idaho
Skokomish Indian Tribe of the Skokomish Reservation, Washington
Twin Hills Village
Village of Aniak
Village of Salamatoff
Yakutat Tlingit Tribe
In GAP
Database
No. Tribes
per Region
111
D-4
-------
Appendix E
GPRA CODES AND ACTIVITY CATEGORIES
-------
Tribe Name:
ACT GPRA 1 CATEGORY
O 383 AIR ACTIVITIES
n 109 AIR ACTIVITIES
O 100 AIR ACTIVITIES
n 101 AIR ACTIVITIES
EH
102 AIR ACTIVITIES
EH
103 AIR ACTIVITIES
EH
104 AIR ACTIVITIES
EH 105 AIR ACTIVITIES
EH 384 AIR ACTIVITIES
EH 106 AIR ACTIVITIES
EH 107 AIR ACTIVITIES
EH
108 AIR ACTIVITIES
EH 119 AIR ACTIVITIES
EH 110 AIR ACTIVITIES
EH 111 AIR ACTIVITIES
EH
112 AIR ACTIVITIES
EH
113 AIR ACTIVITIES
EH
114 AIR ACTIVITIES
EH 115 AIR ACTIVITIES
EH 385 AIR ACTIVITIES
EH 116 AIR ACTIVITIES
EH 117 AIR ACTIVITIES
EH
118 AIR ACTIVITIES
EH GENERAL MANAGEMENT
236 AND ADMINISTRATION
EH GENERAL MANAGEMENT
428 AND ADMINISTRATION
EH
GENERAL MANAGEMENT
421 AND ADMINISTRATION
GENERAL MANAGEMENT
420 AND ADMINISTRATION
SUB1
External Air Quality
External Air Quality
External Air Quality
External Air Quality
External Air Quality
External Air Quality
External Air Quality
External Air Quality
External Air Quality
External Air Quality
External Air Quality
Indoor Air Quality
Indoor Air Quality
Indoor Air Quality
Indoor Air Quality
Indoor Air Quality
Indoor Air Quality
Indoor Air Quality
Indoor Air Quality
Indoor Air Quality
Indoor Air Quality
Indoor Air Quality
Communication
Communication
Communication
Grant Number(s):
SUB2 SUB3 Note
Air Grants Administration
Building Survey
Developing Permitting/Licensing
Authority
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Source Inventory
Source Inventory-T1 4(9005)
Staff Program Capacity
Development
Air Grants Administration
Building Survey
Developing Permitting/Licensing
Authority
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Source Inventory
Source Inventory-T1 4(9005)
Staff Program Capacity
Development
External Communication (e.g.,
with regulated community or other
governments)
Internal Communication (e.g., with
Tribal Executive, community, K-
12, or adult education)
GENERAL MANAGEMENT
382 AND ADMINISTRATION
GENERAL MANAGEMENT
225 AND ADMINISTRATION
Program Establishment
Activities
Program Establishment
Activities
Baseline Environmental
Assessment
Page 1 of 10
-------
Tribe Name:
ACT GPRA I
CATEGORY
SUB1
Grant Number(s):
SUB2
SUB3
Note
GENERAL MANAGEMENT
228 AND ADMINISTRATION
GENERAL MANAGEMENT
229 AND ADMINISTRATION
GENERAL MANAGEMENT
230 AND ADMINISTRATION
Program Establishment
Activities
Program Establishment
Activities
Program Establishment
Activities
Enforcement Capability
Fiscal Administration Capacity
Fiscal Administration Capacity
Standards in
Place
Standards for
Property
Management
GENERAL MANAGEMENT
231 AND ADMINISTRATION
GENERAL MANAGEMENT
232 AND ADMINISTRATION
GENERAL MANAGEMENT
235 AND ADMINISTRATION
GENERAL MANAGEMENT
233 AND ADMINISTRATION
GENERAL MANAGEMENT
234 AND ADMINISTRATION
436 GRANT WRITING
429 GRANT WRITING
430 GRANT WRITING
431 GRANT WRITING
432 GRANT WRITING
433 GRANT WRITING
434 GRANT WRITING
435 GRANT WRITING
381 LAND ACTIVITIES
344 LAND ACTIVITIES
333 LAND ACTIVITIES
339 LAND ACTIVITIES
338 LAND ACTIVITIES
340 LAND ACTIVITIES
341 LAND ACTIVITIES
391 LAND ACTIVITIES
342 LAND ACTIVITIES
343 LAND ACTIVITIES
Program Establishment
Activities
Program Establishment
Activities
Staff
Staff
Staff
Clean Air Quality
Clean Water Activities
Cross Media Activities
Drinking Water Quality
General Management and
Administration
Solid and Hazardous Waste
Activities
Toxic Substances Activities
Asbestos
Asbestos
Asbestos
Asbestos
Asbestos
Asbestos
Asbestos
Asbestos
Asbestos
Standards for
Fiscal Administration Capacity Procurement
Legal Capability
Develop Position Descriptions
Training Program
Baseline Assessment (e.g., Lead
Sources Inventory, Blood Lead
Survey, Field PoPs Survey, or
Building Condition Survey)
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grant Administration
Staff Program Capacity
Development
Page 2 of 10
-------
Tribe Name:
ACT GPRA I
CATEGORY
SUB1
Grant Number(s):
SUB2
SUB3
Note
252 LAND ACTIVITIES
237 LAND ACTIVITIES
247 LAND ACTIVITIES
246 LAND ACTIVITIES
248 LAND ACTIVITIES
249 LAND ACTIVITIES
395 LAND ACTIVITIES
250 LAND ACTIVITIES
251 LAND ACTIVITIES
268 LAND ACTIVITIES
253 LAND ACTIVITIES
263 LAND ACTIVITIES
262 LAND ACTIVITIES
264 LAND ACTIVITIES
265 LAND ACTIVITIES
396 LAND ACTIVITIES
266 LAND ACTIVITIES
267 LAND ACTIVITIES
356 LAND ACTIVITIES
Emergency Response
Emergency Response
Emergency Response
Emergency Response
Emergency Response
Emergency Response
Emergency Response
Emergency Response
Emergency Response
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Hazardous Waste
Lead
Baseline Assessment (e.g.,
Sources Inventory, Superfund Site
Identification, Site Evaluation, Site
Development, Remediation, and
Waste Stream Characterization)
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grant Administration
Staff Program Capacity
Development
Baseline Assessment (e.g.,
Sources Inventory, Superfund Site
Identification, Site Evaluation, Site
Development, Remediation, and
Waste Stream Characterization)
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grant Administration
Staff Program Capacity
Development
345 LAND ACTIVITIES
351 LAND ACTIVITIES
350 LAND ACTIVITIES
352 LAND ACTIVITIES
353 LAND ACTIVITIES
392 LAND ACTIVITIES
Lead
Lead
Lead
Lead
Lead
Lead
Baseline Assessment (e.g., Lead
Sources Inventory, Blood Lead
Survey, Field PoPs Survey, or
Building Condition Survey)
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Page 3 of 10
-------
Tribe Name:
ACT GPRA I
CATEGORY
SUB1
Grant Number(s):
SUB2
SUB3
Note
354 LAND ACTIVITIES
355 LAND ACTIVITIES
368 LAND ACTIVITIES
357 LAND ACTIVITIES
363 LAND ACTIVITIES
362 LAND ACTIVITIES
364 LAND ACTIVITIES
365 LAND ACTIVITIES
393 LAND ACTIVITIES
366 LAND ACTIVITIES
367 LAND ACTIVITIES
380 LAND ACTIVITIES
369 LAND ACTIVITIES
375 LAND ACTIVITIES
374 LAND ACTIVITIES
376 LAND ACTIVITIES
377 LAND ACTIVITIES
394 LAND ACTIVITIES
378 LAND ACTIVITIES
379 LAND ACTIVITIES
284 LAND ACTIVITIES
269 LAND ACTIVITIES
279 LAND ACTIVITIES
278 LAND ACTIVITIES
280 LAND ACTIVITIES
Lead
Lead
Pesticides
Pesticides
Pesticides
Pesticides
Pesticides
Pesticides
Pesticides
Pesticides
Pesticides
PoPs (PCBs, Mercury)
PoPs (PCBs, Mercury)
PoPs (PCBs, Mercury)
PoPs (PCBs, Mercury)
PoPs (PCBs, Mercury)
PoPs (PCBs, Mercury)
PoPs (PCBs, Mercury)
PoPs (PCBs, Mercury)
PoPs (PCBs, Mercury)
Recycling
Recycling
Recycling
Recycling
Recycling
Grant Administration
Staff Program Capacity
Development
Baseline Assessment (e.g., Lead
Sources Inventory, Blood Lead
Survey, Field PoPs Survey, or
Building Condition Survey)
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grant Administration
Staff Program Capacity
Development
Baseline Assessment (e.g., Lead
Sources Inventory, Blood Lead
Survey, Field PoPs Survey, or
Building Condition Survey)
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grant Administration
Staff Program Capacity
Development
Baseline Assessment (e.g.,
Sources Inventory, Superfund Site
Identification, Site Evaluation, Site
Development, Remediation, and
Waste Stream Characterization)
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Page 4 of 10
-------
Tribe Name:
ACT GPRA 1 CATEGORY
O 281 LAND ACTIVITIES
n 397 LAND ACTIVITIES
O 282 LAND ACTIVITIES
EH
283 LAND ACTIVITIES
n 300 LAND ACTIVITIES
285 LAND ACTIVITIES
CH
295 LAND ACTIVITIES
O 294 LAND ACTIVITIES
CH
296 LAND ACTIVITIES
n 297 LAND ACTIVITIES
O 398 LAND ACTIVITIES
n 298 LAND ACTIVITIES
n
299 LAND ACTIVITIES
O 316 LAND ACTIVITIES
301 LAND ACTIVITIES
EH
311 LAND ACTIVITIES
n 310 LAND ACTIVITIES
CH
31 2 LAND ACTIVITIES
O 313 LAND ACTIVITIES
n 399 LAND ACTIVITIES
O 314 LAND ACTIVITIES
EH
315 LAND ACTIVITIES
n 332 LAND ACTIVITIES
SUB1
Recycling
Recycling
Recycling
Recycling
Solid Waste
Solid Waste
Solid Waste
Solid Waste
Solid Waste
Solid Waste
Solid Waste
Solid Waste
Solid Waste
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
Superfund
UST
Grant Number(s):
SUB2 SUB3 Note
Development of QAPPs
General Program Development
Grant Administration
Staff Program Capacity
Development
Baseline Assessment (e.g.,
Sources Inventory, Superfund Site
Identification, Site Evaluation, Site
Development, Remediation, and
Waste Stream Characterization)
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grant Administration
Staff Program Capacity
Development
Baseline Assessment (e.g.,
Sources Inventory, Superfund Site
Identification, Site Evaluation, Site
Development, Remediation, and
Waste Stream Characterization)
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grant Administration
Staff Program Capacity
Development
317 LAND ACTIVITIES
UST
Baseline Assessment (e.g.,
Sources Inventory, Superfund Site
Identification, Site Evaluation, Site
Development, Remediation, and
Waste Stream Characterization)
Page 5 of 10
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Tribe Name:
ACT GPRA 1 CATEGORY
n
327 LAND ACTIVITIES
O 326 LAND ACTIVITIES
EH
328 LAND ACTIVITIES
n 329 LAND ACTIVITIES
O 400 LAND ACTIVITIES
n 330 LAND ACTIVITIES
n
331 LAND ACTIVITIES
O SPECIAL EMPHASIS
205 ACTIVITIES
O SPECIAL EMPHASIS
164 ACTIVITIES
O SPECIAL EMPHASIS
155 ACTIVITIES
O SPECIAL EMPHASIS
158 ACTIVITIES
O SPECIAL EMPHASIS
159 ACTIVITIES
O SPECIAL EMPHASIS
160 ACTIVITIES
O SPECIAL EMPHASIS
161 ACTIVITIES
O SPECIAL EMPHASIS
162 ACTIVITIES
O SPECIAL EMPHASIS
163 ACTIVITIES
O SPECIAL EMPHASIS
174 ACTIVITIES
O SPECIAL EMPHASIS
165 ACTIVITIES
O SPECIAL EMPHASIS
168 ACTIVITIES
O SPECIAL EMPHASIS
169 ACTIVITIES
O SPECIAL EMPHASIS
170 ACTIVITIES
O SPECIAL EMPHASIS
171 ACTIVITIES
O SPECIAL EMPHASIS
172 ACTIVITIES
O SPECIAL EMPHASIS
173 ACTIVITIES
O SPECIAL EMPHASIS
184 ACTIVITIES
SUB^
UST
UST
UST
UST
UST
UST
UST
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Environmental Justice
Environmental Justice
Environmental Justice
Environmental Justice
Environmental Justice
Environmental Justice
Environmental Justice
Environmental Justice
NEPA/TEPA/Cultural
Resources
Grant Number(s):
SUB2 SUB3 Note
Developing Permitting/Licensing
Authority
Development of a Database
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grant Administration
Staff Program Capacity
Development
Baseline Assessment (e.g.,
Sources Inventory, Survey)
Developing Permitting/Licensing
Authority
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
Grants Administration
Wetland Identification and
Delineation
Baseline Assessment (e.g.,
Sources Inventory, Survey)
Developing Permitting/Licensing
Authority
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
Grants Administration
Wetland Identification and
Delineation
Page 6 of 10
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Tribe Name:
ACT GPRA 1
CATEGORY
SUB1
Grant Number(s):
SUB2
SUB3
Note
SPECIAL EMPHASIS
175 ACTIVITIES
SPECIAL EMPHASIS
178 ACTIVITIES
SPECIAL EMPHASIS
179 ACTIVITIES
SPECIAL EMPHASIS
180 ACTIVITIES
SPECIAL EMPHASIS
181 ACTIVITIES
SPECIAL EMPHASIS
182 ACTIVITIES
SPECIAL EMPHASIS
183 ACTIVITIES
SPECIAL EMPHASIS
194 ACTIVITIES
SPECIAL EMPHASIS
185 ACTIVITIES
SPECIAL EMPHASIS
188 ACTIVITIES
SPECIAL EMPHASIS
189 ACTIVITIES
SPECIAL EMPHASIS
190 ACTIVITIES
SPECIAL EMPHASIS
191 ACTIVITIES
SPECIAL EMPHASIS
192 ACTIVITIES
SPECIAL EMPHASIS
193 ACTIVITIES
SPECIAL EMPHASIS
204 ACTIVITIES
SPECIAL EMPHASIS
195 ACTIVITIES
SPECIAL EMPHASIS
198 ACTIVITIES
SPECIAL EMPHASIS
199 ACTIVITIES
SPECIAL EMPHASIS
200 ACTIVITIES
SPECIAL EMPHASIS
201 ACTIVITIES
SPECIAL EMPHASIS
202 ACTIVITIES
SPECIAL EMPHASIS
203 ACTIVITIES
154 WATER ACTIVITIES
NEPA/TEPA/Cultural
Resources
NEPA/TEPA/Cultural
Resources
NEPA/TEPA/Cultural
Resources
NEPA/TEPA/Cultural
Resources
NEPA/TEPA/Cultural
Resources
NEPA/TEPA/Cultural
Resources
NEPA/TEPA/Cultural
Resources
Pollution Prevention
Pollution Prevention
Pollution Prevention
Pollution Prevention
Pollution Prevention
Pollution Prevention
Pollution Prevention
Pollution Prevention
Sustainable Development
Sustainable Development
Sustainable Development
Sustainable Development
Sustainable Development
Sustainable Development
Sustainable Development
Sustainable Development
Baseline Assessment (e.g.,
Sources Inventory, Survey)
Developing Permitting/Licensing
Authority
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
Grants Administration
Wetland Identification and
Delineation
Baseline Assessment (e.g.,
Sources Inventory, Survey)
Developing Permitting/Licensing
Authority
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
Grants Administration
Wetland Identification and
Delineation
Baseline Assessment (e.g.,
Sources Inventory, Survey)
Developing Permitting/Licensing
Authority
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
Grants Administration
Wetland Identification and
Delineation
Page 7 of 10
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Tribe Name:
ACT GPRA 1 CATEGORY
O 224 WATER ACTIVITIES
n 401 WATER ACTIVITIES
O 403 WATER ACTIVITIES
n 404 WATER ACTIVITIES
406 WATER ACTIVITIES
407 WATER ACTIVITIES
408 WATER ACTIVITIES
O 409 WATER ACTIVITIES
n 405 WATER ACTIVITIES
410 WATER ACTIVITIES
O 131 WATER ACTIVITIES
n 121 WATER ACTIVITIES
SUB1
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
Ground Water
Non-Point Sources
Non-Point Sources
Grant Number(s):
SUB2 SUB3 Note
Administering EPA Grant
Baseline Assessment
Developing Water Quality
Standards
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Staff Program Capacity
Development
Administering EPA Grant
122 WATER ACTIVITIES
126 WATER ACTIVITIES
127 WATER ACTIVITIES
128 WATER ACTIVITIES
129 WATER ACTIVITIES
386 WATER ACTIVITIES
130 WATER ACTIVITIES
402 WATER ACTIVITIES
412 WATER ACTIVITIES
41 3 WATER ACTIVITIES
41 5 WATER ACTIVITIES
41 6 WATER ACTIVITIES
41 7 WATER ACTIVITIES
418 WATER ACTIVITIES
41 4 WATER ACTIVITIES
41 9 WATER ACTIVITIES
21 4 WATER ACTIVITIES
206 WATER ACTIVITIES
207 WATER ACTIVITIES
Non-Point Sources
Non-Point Sources
Non-Point Sources
Non-Point Sources
Non-Point Sources
Non-Point Sources
Non-Point Sources
Point Sources
Point Sources
Point Sources
Point Sources
Point Sources
Point Sources
Point Sources
Point Sources
Point Sources
Source Water Protection
Source Water Protection
Source Water Protection
Baseline Assessment (e.g., NPS
Source Inventory, Watershed
Inventory)
Developing Water Quality
Standards
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Staff Program Capacity
Development
Administering EPA Grant
Baseline Assessment
Developing Water Quality
Standards
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Staff Program Capacity
Development
Developing Permitting/Licensing
Authority
Development of Codes and
Ordinances
Page 8 of 10
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Tribe Name:
ACT GPRA 1 CATEGORY
n
208 WATER ACTIVITIES
O 209 WATER ACTIVITIES
n 389 WATER ACTIVITIES
O 210 WATER ACTIVITIES
n 211 WATER ACTIVITIES
CH
21 2 WATER ACTIVITIES
CH
213 WATER ACTIVITIES
n 223 WATER ACTIVITIES
CH
21 5 WATER ACTIVITIES
CH
21 6 WATER ACTIVITIES
CH
21 7 WATER ACTIVITIES
O 218 WATER ACTIVITIES
n 390 WATER ACTIVITIES
O 219 WATER ACTIVITIES
n 220 WATER ACTIVITIES
CH
221 WATER ACTIVITIES
CH
222 WATER ACTIVITIES
SUB1
Source Water Protection
Source Water Protection
Source Water Protection
Source Water Protection
Source Water Protection
Source Water Protection
Source Water Protection
Underground Injection Control
Underground Injection Control
Underground Injection Control
Underground Injection Control
Underground Injection Control
Underground Injection Control
Underground Injection Control
Underground Injection Control
Underground Injection Control
Underground Injection Control
Grant Number(s):
SUB2 SUB3 Note
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grants Administration
Source Water Inventory
Staff Program Capacity
Development
Wetland Identification and
Delineation. NOT IN USE.
PLEASE RECLASSIFY
Developing Permitting/Licensing
Authority
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Grants Administration
Source Water Inventory
Staff Program Capacity
Development
Wetland Identification and
Delineation. NOT IN USE.
PLEASE RECLASSIFY
142 WATER ACTIVITIES Watershed
132 WATER ACTIVITIES Watershed
133 WATER ACTIVITIES Watershed
137 WATER ACTIVITIES Watershed
138 WATER ACTIVITIES Watershed
139 WATER ACTIVITIES Watershed
140 WATER ACTIVITIES Watershed
387 WATER ACTIVITIES Watershed
141 WATER ACTIVITIES Watershed
153 WATER ACTIVITIES Wetlands
143 WATER ACTIVITIES Wetlands
144 WATER ACTIVITIES Wetlands
Administering EPA Grant
Baseline Assessment (e.g., NPS
Source Inventory, Watershed
Inventory)
Developing Water Quality
Standards
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Staff Program Capacity
Development
Administering EPA Grant
Baseline Assessment (e.g., NPS
Source Inventory, Watershed
Inventory)
Page 9 of 10
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Tribe Name:
\ ACT GPRA 1
CATEGORY
SUB1
Grant Number(s):
SUB2
SUB3
Wore
p
p
p
n
148 WATER ACTIVITIES Wetlands
149 WATER ACTIVITIES Wetlands
150 WATER ACTIVITIES Wetlands
151 WATER ACTIVITIES Wetlands
388 WATER ACTIVITIES Wetlands
152 WATER ACTIVITIES Wetlands
Developing Water Quality
Standards
Development of Codes and
Ordinances
Development of Monitoring
Capacity
Development of QAPPs
General Program Development
Staff Program Capacity
Development
Page 10 of 10
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Appendix F
TRIBAL POPULATION STATISTICS
-------
APPENDIX F: POPULATION INFERENCES BASED ON SAMPLE DATA
Exhibit 1 below shows confidence intervals for the population proportions of various indicators.
Exhibit 1: Summary of Population Proportions
Indicator*3'
Percent of tribes that participated in activities to
increase legal capacity
Percent of tribes that developed codes,
ordinances, or standards
Percent of tribes that adopted/implemented
codes, ordinances, or standards
Percent of tribes that participated in enforcement
activities
Percent of tribes that have at least one
professional staff member
Percent of tribes participating in water activities
Percent of tribes participating in waste activities
Percent of tribes participating in air activities
Percent of tribes participating in internal
communication activities
Percent of tribes participating in external
communication activities
Percent of tribes participating in general
communication activities
Percent of tribes that took advantage of technical
resources
Percent of tribes that took advantage of
programmatic resources
Percent of non-GAP grants received
concurrently with GAP funding
Percent of tribes receiving non-GAP funding
Sample Proportion
25%
26%
7%
26%
90%
73%
73%
49%
71%
69%
29%
76%
23%
90%
62%
Sample Size(b)
96
96
96
96
96
96
96
96
96
96
96
96
96
1242(c)
111
95 Percent
Confidence Interval
Low
16%
17%
2%
17%
83%
64%
64%
39%
62%
59%
20%
68%
15%
88%
53%
High
34%
35%
12%
35%
96%
82%
82%
59%
80%
78%
38%
85%
31%
91%
71%
(a) We could not calculate population proportions for the percentage of tribes with unfavorable audit results, because
results do not meet the criteria of approximately normal distribution.
(b) Unless otherwise noted, sample size refers to the number of tribes.
(c) In this case, sample size refers to number of grants, rather than number of tribes.
F-l
-------
Exhibit 2 below shows confidence intervals for the population means for various indicators.
Exhibit 2: Summary of Population Means
Indicator
Amount of GAP grant
Number of technical resources accessed
Number of programmatic resources accessed
Number of months between project end and closeout date
Number of professional and technical FTEs hired
Sample Mean
$102,472
4.4
1.2
12.7
1.2
Sample Size(a)
754
96
40
175 (b)
66
95 Percent
Confidence Interval
Low
$ 97,957
3.4
0.8
11.4
1.1
High
$106,986
5.3
1.6
14.0
1.4
(a) Unless otherwise noted, sample size refers to the number of tribes.
(b) In this case, sample size refers to number of grants, rather than number of tribes.
F-2
-------
Appendix G
ACTIVITY COMPARISON ACROSS TRIBE SAMPLE GROUPS
-------
Appendix G
Percent of Tribes with Activities in each Category
100%
0%
General Land Activities Water Grant Writing Air Activities Special
Management Activities Emphasis
and Activities
Administration
D Tribes in Database • Tribes with File Reviews
Percent of Tribes Participating in each Activity Type
100%
O Tribes in Database • Tribes in File Reviews
G-l
-------
Appendix H
REGIONAL GAP PROJECT OFFICERS INTERVIEWED
-------
Appendix H
INTERVIEWEES: REGIONAL PROJECT OFFICERS FOR GAP
EPA Region
Region 1
Region 2
Region 4
Region 5
Region 6
Region 7
Region 8
Region 9
Region 10
Cross-Region/Region 4
Primary Interviewee
Jean Crocker
Christine Yost
Cynthia Nolan
Michael Nishi
Dale Roy
Wolfgang Brandner
Judith Hervig (not completed)
Timothy Wilhite
Alan Moomaw
Dan Clone
H-l
-------
Appendix I
TRIBES PARTICIPATING IN PANEL DISCUSSIONS
-------
Appendix I
United South and Eastern Tribes (USET) 2007 Impact Week Meeting, Arlington, VA1
• Miccosukee Tribe of Indians of Florida (Panelist)
• Poarch Band of Creek Indians of Alabama (Panelist)
• Narragansett Indian Tribe of Rhode Island (Panelist)
EPA Region 5 2007 Indian GAP Conference Week, Chicago, IL
• Forest County Potawatomi Community, Wisconsin (Panelist)
• Little Traverse Bay Bands of Odawa Indians, Michigan (Panelist)
• Grand Traverse Band of Ottawa and Chippewa Indians, Michigan
• Huron Potawatomi, Inc., Michigan
• Lac Courte Oreilles Band of Lake Superior Chippewa Indians of Wisconsin (Panelist)
• Leech Lake Band of Minnesota Chippewa
• Little River Band of Ottawa Indians, Michigan
• Mille Lacs Band of Minnesota Chippewa DNR/E
• Pokagon Band of Potawatomi Indians, Michigan and Indiana
• Quinault Tribe of the Quinault Reservation, Washington
• Saginaw Chippewa Indian Tribe of Michigan
EPA Region 8 Tribal Operations Committee Meeting, Denver, CO
• Ute Mountain Tribe of the Ute Mountain Reservation, Colorado, New Mexico & Utah
(Panelist)
• Turtle Mountain Band of Chippewa Indians of North Dakota (Panelist)
• Confederated Salish & Kootenai Tribes of the Flathead Reservation, Montana (Panelist)
• Assiniboine and Sioux Tribes of the Fort Peck Indian Reservation, Montana
• Blackfeet Tribe of the Blackfeet Indian Reservation of Montana
• Flandreau Santee Sioux Tribe of South Dakota
• Northern Cheyenne Tribe of the Northern Cheyenne Indian Reservation, Montana
• Shoshone Tribe of the Wind River Reservation, Wyoming
• Sisseton-Wahpeton Oyate of the Lake Traverse Reservation, South Dakota
• Southern Ute Indian Tribe of the Southern Ute Reservation, Colorado
• Three Affiliated Tribes of the Fort Berthold Reservation, North Dakota
• Ute Indian Tribe of the Uintah & Ouray Reservation, Utah
1 Due to inclement weather, we were not able to conduct a panel discussion with tribes at this event. We
instead conducted separate interviews with each of the tribal representatives on the panel.
1-1
-------
Appendix J
SOURCES OF NON-GAP FUNDING AND PROGRAM SUPPORT
-------
Appendix J
Sources of Non-GAP Funding and Program Support Received by Tribes
EPA Programs
• Clean Water Act (CWA) Section 106 - water program infrastructure, staffing, water quality standards
development, well-protection plans, water quality lab, and training.
• CWA Section 106b (since cut) - wetland management planning
• CWA Section 319 - non point source pollution, water quality standards development
• Solid waste - solid waste planning, code development, staffing, recycling
• Clean Air Act Section 103 - air program, mercury deposition
• Resource Conservation and Recovery Act (RCRA) Support Agency Cooperative Agreement
• Underground Storage Tanks (UST) and Underground Injection Control (UIC) - Direct Implementation
Tribal Cooperative Agreement (DITCA)
• Public Water Systems Safety (since cut) - water treatment/facilities
• Brownfields
• Pesticides
• Asthma Program
• Environmental Justice
Non-EPA Agencies and Programs
• U.S. Natural Resources Conservation Service (NRCS) - sedimentation issues, road issues, technical data,
forest management, erosion control, soil protection
• U.S. Department of Agriculture (USDA) (Rural development) - solid waste programs, equipment, buildings
• U.S. Fish and Wildlife Service (FWS) - technical assistance, travel funding, forestry, water testing, burning,
wildlife habitat
• U.S. Bureau of Indian Affairs (BIA) - surface water cleaning, land resources, water resources, fish and
wildlife compliance, land use enforcement, forestry, road maintenance, parks, wetlands permits
• U.S. Bureau of Reclamation (BOR) - water activities; septic issues
• U.S. Indian Health Service (HS) - solid waste programs, equipment, buildings
• U.S. Department of Health and Human Services (DHHS) - Administration for Native Americans (ANA)
• U.S. Army Corps of Engineers - land use/wetlands permitting
• State entities - WI Department of Natural Resources
• Non-profits - National Groundwater Assn., North American Waste Management Society, Tip-of-the-Mitt
Watershed Council, WI Assn. Of Lakes, Little Traverse Bay Organization, West Virginia University
J-l
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