United States
Environmental
Protection Agency
Office of Policy
(1807T)
March 2011
EPA-100-F-11-019
 Evaluation of the Drinking
 Water and Clean Water

 Infrastructure Tribal Set-
 Aside Grant Programs

 Final Report - Appendices
 Promoting Environmental Results
 <                        >
 Through Evaluation

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   EVALUATION OF Til	IE               AND            INFRASTRUCTURE TRIBAL SET-ASIDE
TABLE  OF CONTENTS
Appendix A. DWIG-TSAand CWISA PRogram Evaluation Logic Model	1
Appendix B.   Interview Guides	2
       Common Introduction: A Note to Interviewees	2
       EPA Headquarters	2
       EPA Regions	4
       IMS Headquarters	6
       IMS Area Offices	8
       Tribal Government Staff	10
Appendix C.   DWIG-TSA Regional Implementation Processes	12
Appendix D.   Results of Correlation Analyses	14
Appendix E.   Detailed Data Tables	19
       DWIG-TSA Implementation	19
       DWIG-TSA Project Selection	20
       CWISA Implementation	25
       Project Selection	27
       Project Completion and Duration Information	30
       ARRA Implementation	36
Appendix F.   Information Sources	38
Evaluation Report - March 2011                                                                Appendices

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                                  EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
       APPENDIX A.  DWIG-TSA  AND CWISA PROGRAM EVALUATION LOGIC  MODEL

       Goal of Programs: To improve access to  drinking water  and basic sanitation in  Indian country and to improve compliance of community water systems with
       applicable health-based standards.
                                                                                   SHORT TERM OUTCOMES*
                                                                                     MEDIUM TERM OUTCOMES*
                                                                                           LONG TERM OUTCOMES*
EPA Inputs
    EPA HQ Staff
    1.5 FTE DW
    1.0 FTE CW
•   EPA Regional Staff
•   Program Guidances
    (CWA, SDWA, EPA HQ
    Guidance, EPA
    Regional Guidance,
    ARRA Guidance)
•   Information on
    Infrastructure Need:
    IMS SDS List
•   Drinking Water
    Infrastructure Needs
    Survey
•   Applications/Response
    to Regional
    Solicitations
•   Other Regional
    Information and
    Knowledge
•   Program Funding from
    Congress

Other Inputs
    IMS Staff (HQ and Area)
    Tribal Staff
HQ Program
•   Set program goals and
    mission
•   Allocate funding
    according to formula/
    need
•   Collect/analyze project
    data
•   ARRA IA Administration
•   Monitor and report on
    measures

Regional Programs
•   Project solicitations,
    ranking, & selection
•   Provide funding
•   Monitor and report on
    project progress
•   Consult with Tribes and
    IMS to confirm accuracy
    of need

IHS and Tribes
•   Submit applications
•   Implement projects and
    report on progress
•   Conduct Tribal Needs
    Survey and annual
    summary of needs
HQ Program
•   Funding to Regions
•   Reports on program
    progress for accountability
    reports
•   Annual Guidances

Regional Programs
•   Ranked list and selected
    projects
•   Number of projects funded
•   Reports on project and
    program progress to HQ
    through tracking
    spreadsheets, etc.
•   Suggested changes or
    additions to SDS List

IHS and Tribes
•   Project Work plans
•   Project outputs (e.g.,
    changes in deficiency
    levels, new infrastructure)
•   Reports on project progress
    to EPA Regions (through
    reports or STARS)
•   Changes to SDS list based
    on input
Regions fund projects that
best address program
goals and tribal needs
(Regional project selection
information)
HQ funds Regions with
highest demonstrated
programmatic need on
tribal lands (EPA Allocation
Formula)
Through FY2011, in
coordination with other
federal agencies, provide
safe drinking water access to
100,700 AI/AN homes and
basic sanitation access to
52,300 AI/AN homes (STARS)
By 2011, 86 percent of the
population in Indian country
served by CWSs will receive
drinking water that meets all
applicable health-based
drinking water standards
(SDWIS)
By 2015, in coordination with
other federal agencies,
reduce by 50 percent the
number of homes on tribal
lands lacking access to safe
drinking water and access to
basic sanitation (STARS)
100 percent of the
population in Indian country
served by PWSs receives
water that is compliant with
the NPDWRs (SDWIS)
Full access to basic
sanitation to serviceable
homes in Indian country
(STARS)
       * Data Source for measuring outcome in parentheses; + These medium-term outcomes reflect the programs' strategic measures identified in 2010 in the FY2011-2015 EPA Strategic Plan, but also include
       the strategic targets from the FY2006-2011 EPA Strategic Plan, for historical purposes.
       Evaluation Report-March 2011
                                                                                                                        Appendix A - Page 1

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              OF THE               AND
APPENDIX B.  INTERVIEW GUIDES
Common Introduction: A Note to Interviewees

A Ross & Associates evaluator will ask the questions in this guide during your telephone interview. The interview is
not intended to be a test of your knowledge, and you do not need to prepare your responses in advance of the
interview.   If you have any questions about the interview or evaluation, please contact Anna Williams or Amy
Wheeless,  Ross  &  Associates, by  phone at 206-447-1805  or  by  email  at  anna.williams@ross-assoc.com /
amy.wheeless@ross-assoc.com.
The interviews will be  anonymous—the evaluators will  not be sharing our notes or attributing comments to
particular individuals.  However, we will be identifying trends and themes, and may give noteworthy examples
from the different organizational perspectives (primarily EPA, IMS, and tribal staff).  For this reason, and given the
small number of people involved at  EPA with these programs and who will be interviewed, it may be possible in
some instances to deduce who shared what views.
Unless noted otherwise, the questions below are referring to the typical annual selection process, and project
selected through that process, not the ARRA projects or process.

EPA Headquarters

Program Implementation

i.   Please describe your role with EPA and its tribal water infrastructure grant programs.
2.   As you understand  it, please briefly describe EPA Headquarters's communication and coordination with the
    following parties around project  selection, management, implementation, reporting, etc.
3.   EPA Regions
4.   IMS Area Offices
5.   IMS Headquarters
6.   Tribes
7.   Other  (e.g., other agencies)
8.   Are there ways in  which you think communication and coordination could improve with the parties listed
    above for these infrastructure grant programs?
9.   Has the ARRA program  implementation  differed  in  ways that  you think would  enhance or inhibit
    project/program performance? Are there insights or lessons from the ARRA process that can inform, or set an
    example, for the more routine annual program implementation?

Program Achievements and Performance Measurement

10.  For the questions below, please  refer to Attachment I, which lists EPA's historic and current program strategic
    goals and measures.
11.  Do you think that  the "real story"  of progress and achievements enabled by the DWIG-TSA and CWISA
    programs is accurately reflected  by the nationally reported strategic targets?
12.  If not,  why not?
Evaluation Report - March 2011                                                            Appendix B - Page 2

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    EVALUATION OF THE DRINKING       AND              INFRASTRUCTURE TRIBAL SET-ASIDE
is.  Which, if any, of the following factors do you think could be influencing EPA's ability to help meet the water
    infrastructure needs in Indian Country?
        EPA mandate, scope, and regulatory authority (e.g., relative to IHS's)
        Funding levels (e.g., overall project funding, funding provided by EPA, funding provided  by community
        itself)
        Project duration
        Accuracy, completeness, and currency of information on infrastructure needs in Indian Country
        Accuracy, completeness, and currency of information in the IMS STARS system  (e.g., deficiency levels, SDS
        ranking)
        Tribal capacity
        Operation and maintenance costs associated with infrastructure projects
        Grant type (interagency agreement or direct grant)
        Population density (people per square mile)
        Landscape / ecosystem factors
        Implementation of new rules
        Type of infrastructure project; i.e., new/replacement and centralized/decentralized
        Age of existing infrastructure
        Role of existing guidelines (e.g., helping or hindering progress)
        Available tools for assessing technical, managerial, and financial capacity of water systems
        Other factors

Program Improvements
14.  Please share your thoughts on changes (if not  already covered) that could be made at  EPA, IMS or another
    party to improve water infrastructure grant program effectiveness.  Feel free to reflect on the following topics
    or others that are not on this list:
        Program mission and goals (please explain why a  change from the current would be desirable)
        Program implementation
        Determining tribal needs
        Allocating  resources
        Selecting projects
        Implementing projects
        Coordination and communication
        Performance measures
        Tracking and reporting
is.  Is there anything else on water infrastructure grant programs that you would like to share with us today?
16.  Would you like to share any feedback for us about the evaluation?
Evaluation Report - March 2011                                                                 Appendix B - Page 3

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                OF THE                 AND

EPA Regions

Grant Program Implementation

i.   [DWIG-TSA] How does your region identify, prioritize, and select DWIG-TSA projects?  (See Attachment I with
    the information we have already gathered on your region's selection process. Please elaborate on, or, if
    needed, correct the information in this table.)

2.   [CWISA] Has your region exercised any discretion when selecting projects (other than in rank order from
    the  SDS priority list)?   If so, please  explain.  (See also, the  following question  on  factors  influencing
    project selection.)
                                                 Scale of Influence
       0   =   Not at all influential
       1   =   Rarely influential - other factors are much more important and influential
       2   =   Occasionally influential - other factors are more or more frequently influential
       3   =   Frequently influential-along with other factors
       4   =   Very influential-other factors are much less influential
       5   =   Extremely influential-other factors are not factored in at all
       DK  =   Don't know
3.   On a scale of 0-5 below, please rank the influence of each of the following factors on project selection for your
    program(s):
    National guidelines1
    Long-term infrastructure sustainability
    Tribal financial, technical, and managerial capacity
    Input from the Tribes
    Input from IMS staff
    SDS ranking information from the IMS STARS database
    Information from the IMS STARS database other than the SDS ranking information
    Input from other parties (please identify who)
    The December 2009 Drinking Water Enforcement Response Policy2
    Other national Agency goals, guidances, priorities, etc. (e.g., Administrator goals and priorities, National Program
    Manager (NPM) guidances
    Regional guidance (please specify)
    Other regional priorities or factors (please give examples)
    Other factors (please identify)
4.   Has the project selection process changed over the years? If so, why and (roughly) when?
1 For Drinking Water: EPA Office of Water. Drinking Water Infrastructure Grants: Tribal Set-Aside Program. EPA, October 1998 816-R-98-020.
For Clean Water: EPA Office of Water. Guidelines and Requirements for Applying for Grants from the Indian Set-Aside Program. April 1989,
WH-546
EPA Office of Water. Notice of Change: Indian Set-Aside Program National Project Priority List. Memorandum from Stephen Allbee, Chief,
Municipal Assistance Branch to Regional Construction Grant Program Managers. March 21, 1995.
2 See: http://www.epa.gov/compliance/resources/policies/civil/sdwa/drinking_water_erp_2009.pdf

Evaluation Report - March 2011                                                                     Appendix B - Page 4

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    EVALUATION OF THE                AND
5.   Please  describe your communication and  coordination with the following parties around project selection,
    management, implementation, reporting, etc.   Are there ways  in which  you think communication  and
    coordination could improve with each of these parties?
6.   EPA Headquarters
7.   IMS
8.   Tribes
9.   Other (e.g., internally within the region; other agencies)
10.  Approximately how much staff time (in FTE) does your region spend on the DWIG-TSAand CWISA programs?
11.  Across  how many individuals and offices are these responsibilities spread (for each program)?
12.  Please summarize the staff roles and responsibilities (for both DWIG-TSA and CWISA staff)
is.  Has  the  ARRA program  implementation differed  in  ways that  you  think would enhance  or inhibit
    project/program performance? Are there insights or lessons from the ARRA process that can inform, or set an
    example, for the more routine annual program implementation?

Grant Program Achievements/Performance, Factors Underlying  Performance,  and  Performance
Measurement
14.  Are you familiar with nationally reported progress on achieving the national DWIG-TSA / CWISA goals?
is.  If yes to question 10, where do you access or receive information on national progress?
16.  If yes to question 10, do you  think that the "real story" of progress and achievements enabled by the DWIG-
    TSA and CWISA programs is accurately reflected by the nationally reported information?
17.  If not, why not?
is.  What underlying factors do you think are (or could be) influencing program progress and results?
        (See list below of possible influencing factors.)
19.  [DWIG-TSA] With regard to providing drinking water infrastructure
20.  [DWIG-TSA] With regard to public water systems meeting health-based drinking water standards
21.  [CWISA] With regard to providing access to wastewater/sanitation infrastructure
    Factors that could influence program results and progress:
        EPA mandate, scope, and regulatory authority (e.g., relative to IHS's)
        Funding levels  (e.g., overall project funding, funding provided by EPA, funding  provided by community
        itself)
        Project duration
        Accuracy, completeness, and currency  of information on infrastructure needs in Indian Country
        Accuracy, completeness, and currency of information in the IMS STARS system (e.g., deficiency levels, SDS
        ranking)
        Tribal capacity
        Operation and maintenance costs associated with infrastructure projects
        Grant type (interagency agreement or direct grant)
        Population density (people per square  mile)
        Landscape / ecosystem factors
Evaluation Report - March 2011                                                               Appendix B - Page 5

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    EVALUATION OF Til	IE                AND CLEAN        INFRASTRUCTURE TRIBAL SET-ASIDE
        Implementation of new rules
        Type of infrastructure project; i.e., new/replacement and centralized/decentralized
        Age of existing infrastructure
        Role of existing guidelines (e.g., helping or hindering progress)
        Available tools for assessing technical, managerial, and financial capacity of water systems
        Other factors
22.  Do you think that the current (FY 2010) and proposed (FY 2011) program goals and indicators are the right
    ones? (See Attachment II for a list of the goals and indicators)
23.  If not, why not, and what goals/indicators do you think would be preferable? Are there barriers to making the
    changes you would recommend?

Program Improvements
24.  Please share your thoughts on changes (if not already covered) that could be made to improve DWIG-TSA and
    CWISA program effectiveness.  Feel free to reflect on the following topics or others that are not on this list:
        Program mission and goals (please explain why a change from the current would be desirable)
        Program implementation
        Determining tribal needs
        Allocating resources
        Selecting projects
        Implementing projects
        Coordination and communication
        Performance measures
        Tracking and reporting
25.  Is there anything else on the DWIG-TSA and CWISA programs that you would like to share with us today?
26.  Would you like to share any feedback for us about the evaluation?

IMS Headquarters
Program Implementation
i.   Please describe your role  with IMS and any interaction you have with EPA and its tribal water infrastructure
    grant programs.
2.   Please briefly describe IMS Headquarters's communication and coordination with the following parties around
    project selection, management, implementation, reporting, etc.
3.   EPA Headquarters
4.   EPA Regions
5.   IHS Area Offices
6.   Tribes
7.   Other (e.g., other agencies)
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    EVALUATION OF THE DRINKING WATER AND             INFRASTRUCTURE TRIBAL SET-ASIDE
8.   Are there ways in which you think communication and coordination could improve with the parties listed
    above?
9.   Has the ARRA program implementation differed in ways that you think enhances or inhibits project/program
    performance? Are there insights or lessons from the ARRA process that can inform, or set an example for, the
    more routine annual program implementation?

Program Achievements and Performance Measurement
10.  For the questions  below, please refer to Attachment I, which lists EPA's historic and current program strategic
    goals and measures.
11.  Given your knowledge of project tracking through the IMS STARS database, are the STARS data sufficiently
    suited for gauging EPA program performance with the current/proposed "access" measures?
12.  Please describe any ideas or plans, even  if conceptual and/or far off in the  future, for modifying the STARS
    system and/or  the underlying data that could enable EPA or  any federal  agency to gauge  program
    performance differently in the future.
is.  How do you  define drinking water infrastructure need for tribal homes?
14.  How do you  define wastewater/sanitation infrastructure need for tribal homes?
is.  Which if any of the following factors do you think could be influencing EPA's ability to help meet the water
    infrastructure needs in Indian country:
        EPA mandate, scope, and regulatory authority (e.g., relative to IHS's)
        Funding levels (e.g., overall project funding, funding provided by EPA, funding provided  by community
        itself)
        Project duration
        Accuracy, completeness, and currency of information on infrastructure needs in Indian Country
        Accuracy, completeness, and currency of information  in the IHS STARS system (e.g., deficiency levels, SDS
        ranking)
        Tribal capacity
        Operation and maintenance costs associated with infrastructure projects
        Grant type (interagency agreement or direct grant)
        Population density (people per square mile)
        Landscape/ecosystem factors
        Implementation of new rules
        Type of infrastructure project; i.e., new/replacement and centralized/decentralized
        Age of existing infrastructure
        Role of existing guidelines (e.g., helping or hindering progress)
        Available tools for assessing technical, managerial, and financial capacity of water systems
        Other factors
16.  Do you have any  suggestions for supporting tribal community  compliance with the Safe Drinking Water Act
    given both the different roles and responsibilities of EPA and IHS and the way that drinking water projects are
    chosen and implemented?
Evaluation Report - March 2011                                                                Appendix B - Page 7

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    EVALUATION OF Til	IE                AND CLEAN       INFRASTRUCTURE TRIBAL SET-ASIDE

Program Improvements
17.  Please share your thoughts on changes (if not already covered) that EPA (or EPA together with IMS or another
    party) could make to improve water infrastructure grant program effectiveness.   Feel free to reflect on the
    following topics or others that are not on this list:
        Program mission and goals
        Program implementation
        Determining tribal needs
        Allocating resources
        Selecting  projects
        Implementing projects
        Coordination and communication
        Performance measures
        Tracking and reporting
is.  Is there anything else that you would like to share with us today?
19.  Would you like to share any feedback for us about the evaluation?

IMS Area Offices
Program Implementation
i.   Please describe your role with IMS and any interaction you have with EPA and its tribal water infrastructure
    grant programs.
2.   Please describe your IMS office's communication  and  coordination  with the  following parties around:  (1)
    project prioritization; (2)  project selection; (3) project management and  implementation; and (4)  project
    reporting and  tracking.
3.   EPA Headquarters
4.   EPA Regions
5.   IMS Headquarters
6.   Tribes
7.   Other (e.g.,  other agencies)
8.   Are there ways in which you think communication and coordination could improve with the  parties listed
    above?
9.   Has the ARRA program implementation differed in  ways that you think enhances or inhibits project/program
    performance? Are there insights or lessons from the ARRA process that can inform, or set an example for, the
    more routine annual program implementation?

Program Achievements and Performance Measurement
10.  For the questions below, please refer to Attachment I, which lists EPA's historic  and current program strategic
    goals and measures.
11.  Given your  knowledge of project tracking through the IHS STARS database, are the  STARS data sufficiently
    suited for gauging EPA program performance with the current/proposed "access" measures?
Evaluation Report -  March 2011                                                               Appendix B - Page 8

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    EVALUATION OF THE DRINKING        AND             INFRASTRUCTURE TRIBAL SET-ASIDE
12.  Please describe any ideas or plans, even if conceptual  and/or far off in the future, for  modifying the STARS
    system and/or the underlying data that could enable EPA or any other federal agency to gauge program
    performance differently in the future.
is.  How do you define drinking water infrastructure need for tribal homes?
14.  How do you define wastewater/sanitation infrastructure need for tribal homes?
is.  Which if any of the following factors do  you think could  be influencing EPA's ability to  help meet the water
    infrastructure needs in Indian Country:
        EPA mandate, scope, and regulatory authority (e.g., relative to IHS's)
        Funding levels (e.g., overall project funding, funding provided by EPA, funding provided by community
        itself)
        Project duration
        Accuracy, completeness, and currency of information  on infrastructure needs in Indian Country
        Accuracy, completeness, and currency of information in the IHS STARS system (e.g., deficiency levels, SDS
        ranking)
        Tribal capacity
        Operation and maintenance costs associated with infrastructure projects
        Grant type (interagency agreement or direct grant)
        Population density (people per square mile)
        Landscape / ecosystem factors
        Implementation of new rules
        Type of infrastructure project; i.e.,  new/replacement and centralized/decentralized
        Age of existing infrastructure
        Role of existing guidelines (e.g., helping or hindering progress)
        Available tools for assessing technical, managerial, and financial capacity of water systems
        Other factors
16.  Do you have any suggestions for supporting tribal community compliance with the Safe Drinking Water Act
    given both the different roles and responsibilities of EPA and IHS and the way that drinking water projects are
    chosen and implemented?
Program Improvements
17.  Please share your thoughts on changes (if not already covered) that EPA (or EPA together with IHS or another
    party) could make to improve water infrastructure grant program effectiveness.  Feel free to reflect on the
    following topics or others that are not on this list:
        Program mission and goals
        Program implementation
        Determining tribal needs
        Allocating resources
        Selecting projects
        Implementing projects

Evaluation Report - March 2011                                                                 Appendix B - Page 9

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    EVALUATION OF Til	IE                AND CLEAN       INFRASTRUCTURE TRIBAL SET-ASIDE
        Coordination and communication
        Performance measures
        Tracking and reporting
is.  Is there anything else that you would like to share with us today?
19.  Would you like to share any feedback for us about the evaluation?

Tribal  Government Staff
Program Implementation
i.   Please describe your involvement with EPA's tribal water infrastructure grant programs.
2.   Please describe your overall impression of these programs including how well they are helping to meet the
    water infrastructure needs in Indian Country.
3.   If your tribal community (or a community within the tribal organization you work with) received funds through
    the  DWIG-TSA or CWISA grant programs, was it a direct grant from EPA, was the funding routed through IMS,
    or both of these?
4.   Are  there advantages and disadvantages to having projects funded through direct grants with EPA or grants
    through IMS?
5.   Please briefly describe any communication that you or your tribal organization has with the following parties
    around these water infrastructure grant programs.
6.   EPA Headquarters
7.   EPA Regions
8.   IMS  Headquarters
9.   IMS  Area Offices
10.  Other (e.g.,  other agencies)
11.  Are  there ways  in which you think  communication and coordination could improve with the parties listed
    above?
12.  Do  you  know  about the  different  implementation  of the  grant  programs  under ARRA?   Has  this
    implementation had any impact on your tribal organization?

Program Achievements and Performance Measurement
is.  Please share your thoughts on what achievements the tribal water infrastructure grant programas have been
    able to achieve? Have they really made a difference?  Why or why not?
14.  Which, if any, of the following factors do you think could be influencing EPA's ability to help meet the water
    infrastructure needs in Indian Country:
        EPA mandate, scope, and regulatory authority (e.g.,  relative to IHS's)
        Funding levels  (e.g., overall project funding, funding provided by  EPA, funding  provided by community
        itself)
        Project duration
        Accuracy, completeness, and currency of information on infrastructure needs in Indian Country
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    EVALUATION OF THE DRINKING        AND             INFRASTRUCTURE TRIBAL SET-ASIDE
        Accuracy, completeness, and currency of information in the IMS STARS system (e.g., deficiency levels, SDS
        ranking)
        Tribal capacity
        Operation and maintenance costs associated with infrastructure projects
        Grant type (interagency agreement or direct grant)
        Population density (people per square mile)
        Landscape / ecosystem factors
        Implementation of new rules
        Type of infrastructure project; i.e., new/replacement and centralized/decentralized
        Age of existing infrastructure
        Role of existing guidelines (e.g., helping or hindering progress)
        Available tools for assessing technical, managerial, and financial capacity of water systems
        Other factors
is.  Do you have any comments on the EPA's grant program performance goals and indicators? (See Attachment I
    for a list of historic and current goals and indicators.)
16.  Do you have any suggestions for how EPA could better  support tribal community regulatory compliance with
    the federal Safe Drinking Water Act?
17.  Do you have any suggestions for how EPA, working with other federal partners, could better support access to
    safe drinking water and sanitation infrastructure for tribal homes?

Other Program Improvements
is.  Please share your thoughts on changes (if not already covered) that EPA (or EPA together with IMS or another
    party) could make to improve water infrastructure grant program effectiveness.  Feel free to reflect on the
    following topics or others that are not on this list:
        Program mission and goals
        Program implementation
        Determining tribal needs
        Allocating resources
        Selecting projects
        Implementing projects
        Coordination  and communication
        Performance measures
        Tracking and reporting
19.  Is there anything else that you would like to share with us today?
20.  Would you like to  share any feedback for us about  the evaluation?
Evaluation Report - March 2011                                                                Appendix B - Page 11

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                        EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS

APPENDIX C.  DWIG-TSA REGIONAL  IMPLEMENTATION  PROCESSES
            Project Solicitation
       Biennial solicitation to tribes
       for projects
       Coordinator works directly
       with tribes to identify projects
          Selection Factors
The priority ranking system is based
loosely on IMS SDS ranking guidelines.
Includes health impact, infrastructure
needs, existing deficiency level,
readiness to proceed, tribal affordability,
O&M capability, and tribal compliance.
Selection is based on knowledge of tribal
needs
      Use of SDS List
Used SDS ranking system to
help develop Regional
ranking system. SDS list
does not include all projects
that Region 1 funds
SDS list is one information
source
     Consideration of
 Compliance/Public Health
         Impacts
Ranking includes health
impact (30/148) and if the
project will address tribal
compliance issues (15/148
+ 5 bonus)
Based on Regional
knowledge, including
compliance information
(not quantified)	
    Regional Guidances
Region 1 Priority Ranking
System (2008)
No written guidance
provided
       Funding is allocated on a
       rotational basis between the
       six tribes. One grant is given
       each year to one tribe, and
       the recipient rotates on a
       yearly basis, and alternates
       between the smaller and
       bigger tribes.	
During the calendar year prior to its
scheduling funding year, a tribe submits
a 5- year plan with proposed projects.
EPA works with tribe to refine project
list, as necessary.
Refers to SDS list as one
information source.
No explicit weighting in
written guidance; once
projects are solicited from
the tribe, Region 4 works
with the tribe to identify
the projects with the
highest public health
impact (not quantified)
Draft Guidance and
Prioritization Procedures
(September 2001)
       Region picks projects off the
       IMS SDS list, unless the Region
       knows of extenuating
       circumstances (e.g., project is
       not ready to implement) or
       there are projects that the
       Regions wants to fund that
       are not on the IMS SDS list
       (e.g., due to IMS eligibility)
Selection based on IMS SDS Ranking
Uses SDS list for selecting
projects, unless the Region
knows of other information
SDS list uses Health Impact
as a weighting factor in
ranking (30/108)
Region 5 Guidelines for the
Allocation of Drinking
Water Set-Aside Funds to
Tribes
       Biennial solicitation to tribes
       for projects
Projects are ranked based on weighting
factors including compliance issues,
disinfection needs, and capacity at the
system.
Does not use SDS list.
Region coordinates with IMS
SDS list to ensure projects
are not double-funded.
SDWA Compliance is high
weighting factor in project
ranking; different
compliance issues are
ranked differently (e.g.,
bacteria MCL issues = 10
points X the number of
months in violation)
Biennial Intended Use Plans
for Region 6 DWIG-TSA
(2008)
Evaluation Report-March 2011
                                                                                                 Appendix C - Page 12

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                          EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
            Project Solicitation
       Annual solicitation to tribes
       for projects
                                        Selection Factors
                              Projects selected based on information
                              from solicitation, sanitary survey, site
                              visits, knowledge of tribes, evaluation of
                              the tribes' needs, and SDS list to identify
                              projects. There are no formal weighting
                              criteria. If there are more projects to be
                              funded than funds available, the region
                              will look to maximize use of funds.
                                              Use of SDS List
                                       The SDS list is one
                                       component of project
                                       selection.
                                 Consideration of
                             Compliance/Public Health
                                     Impacts
                            Based on Regional
                            knowledge, including
                            compliance information,
                            and SDS list, which includes
                            Health Impact as a
                            weighting factor in ranking
                            (30/108)
                                Regional Guidance^
                            Region 7 Standing
                            Operating Procedures for
                            Direct Implementation
                            (2010)
       Annual solicitation to tribes
       for projects
                              Projects are ranked based on many
                              factors, including: public health
                              improvements, addressing a lack of safe
                              water supply, improvements in public
                              safety, improvements in ability to
                              comply with regulations, and
                              improvements in environment.
                                        Does not use SDS list
                            "Improvements in Public
                            Health" is highest weighting
                            factor (70/300);
                            "Improvements in ability to
                            comply" provides the
                            second highest point total
                            (50/300)
                            Region 8 DWIG-TSA
                            Program Guidelines
                            (January 2010)
                                                                                                        Region first prioritizes
                                                                                                        projects based on health
                                                                                                        improvement (e.g., First
                                                                                                        funded projects: those that
                                                                                                        have demonstrated illness
                                                                                                        attributable to the water
                                                                                                        system)
Annual solicitation to tribes
for projects
Projects are first ranked on the level of
health improvement they would address.
If funding cannot be provided for all
eligible projects within the same health
category, further criteria for ranking
include: consolidation of water systems,
addressing secondary standards, level of
population served and tribal population
served, whether the system is tribally
owned, and total grant amount.	
Does not use SDS list
                            Region 9 DWIG-TSA
                            Guidance and Procedures
                            for Applying for Assistance
                            (2010)
  10
Regional allocation is divided
between Alaska and  PNW
subregions, proportional to
community water system
needs, as reflected in IHS SDS
list. Tribes do not need to
submit project proposals.
Selection based on IHS SDS Ranking. The
IHS Alaska Area SDS ranking criteria
includes compliance concerns. The
Portland Area SDS ranking criteria does
not include compliance concerns, so
Region 10 includes a compliance factor
to add onto SDS scores when
determining the final project list for the
subregion.
Uses SDS list for selecting
projects, but adds in
compliance information for
final projects. Region
reserves right to skip over
SDS projects that are not
ready to proceed or the
correct type of funding is
not available to address the
deficiency identified in the
SDS project.
SDS list in Alaska Area
explicitly includes
compliance concerns as
part of weighting and
ranking of projects.
In Portland Area, a
compliance factor is added
to SDS scores when
determining project
rankings (12 points, on top
of 108 points in SDS). This
compliance factor is based
on MCLs and length of
exposure to MCLs.	
Final Guidelines: DWIG-TSA
Program Region 10 (August
1999)
Evaluation Report-March 2011
                                                                                                                                     Appendix C - Page 13

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                      EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
APPENDIX  D.  RESULTS OF  CORRELATION  ANALYSES
Wote: Correlations looked at CWISA and DWIG-TSA projects together, except where noted. These correlations included both infrastructure grant projects in
analyses for project duration because the evaluation determined that average project duration between the two programs was not different enough to warrant
separate analyses.

i.   Correlation between IMS area and project duration? Summary response: No.
General Descriptive Statistics:
    >   Number  of Projects = 402, these projects contain data needed to define duration (MOA_signed_date and construction_complete_date). Ongoing
       projects do not have a construction complete date.
    >   Average Project Duration = 1227 days
    >   Areas that are positively correlated with project duration:  Aberdeen, Albuquerque, Bemidji, Phoenix, Portland, and Tucson
    >   Areas that are negatively correlated with project duration: Alaska, Billings, California, Nashville, Navajo, and Oklahoma
    >   Of the 12 areas, the only statistically significant correlations are for Nashville and  Portland, but the  correlation coefficients are low and thus the
       correlation  is not strong.3
           Projects located in Nashville are associated with shorter duration
           Projects located in Portland are associated with longer duration
Projects in Percent of Completed Projects with Percent of Average Project Correlation
Area1 Total Duration Data2 Total Duration (days)3 Coefficient
Aberdeen
Alaska
Albuquerque
Bemidji
Billings
California
Nashville
Navajo
Oklahoma
57
198
53
60
25
56
83
239
35
6%
20%
5%
6%
3%
6%
8%
24%
4%
34
78
26
27
3
10
44
87
7
8%
19%
6%
7%
1%
2%
11%
22%
2%
1323
1209
1492
1327
972
966
773
1148
1059
0.04
-0.012
0.096
0.037
-0.03
-0.057
-0.219
-0.057
-0.031



t-stat t-crit Significant?
0.807
-0.242
1.928
0.746
-0.607
-1.147
-4.489
-1.136
-0.615
1.96
1.96
1.96
1.96
1.96
1.96
1.96
1.96
1.96
No
No
No
No
No
No
Yes
No
No
 In general, a correlation coefficient with an absolute value greater than 0.8 is considered strong, while that with an absolute value less than 0.5 is considered weak.
Evaluation Report- March 2011
Appendix D - Page 14

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                         EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
Projects in Percent of Completed Projects with Percent of Average Project Correlation . _. ... ,
Area ' i . "" . ' 2 , . , . ,3 „ „. . t-stat t-crit Significant?
Area Total Duration Data Total Duration (days) Coefficient
Phoenix
Portland
Tucson
TOTAL
91
55
44
996
9%
6%
4%

33
36
17
402
8%
9%
4%

1386
1603
1287

0.065
0.163
0.017

1.312
3.298
0.349

1.96
1.96
1.96

No
Yes
No

Notes:
(1) We are missing area designation for approximately 100 projects. This would not affect results of the correlation.
(2) We compared the percent of the total number of projects within an area to the percent of completed projects with duration data and the percents are approximately equal. Thus, we have no
reason to believe that one or more areas are disproportionately affected by missing/incomplete data.
(3) Project duration defined as the difference between MOA_signed_date and Construction_complete_date data found in STARS.

2.   Correlation between EPA Region and project duration? Summary response:  No.

General Descriptive Statistics:

    >    Number of Projects = 402, these projects contain  data needed  to define duration  (MOA_signed_date and construction_complete_date).  Ongoing
         projects do not have a construction complete date.
    >    Average Project Duration = 1227 days
    >    Regions that are positively correlated with project duration: Region 5, Region 6, Region 7, Region 8, and Region 10
    >    Regions that are negatively correlated with project duration:  Region 1, Region 2, Region 4, and Region 9
    >    Of the 9 regions, the only statistically significant correlations are for Region 1, Region 4, and Region 7, but the correlation coefficients are low and thus
         the correlation is not strong.
    >    Projects located in Region 1 and Region 4are associated with shorter duration
    >    Projects located in Region 7 are associated with longer duration
Region
Region 1
Region 2
Region 4
Region 5
Region 6
Region 7
Region 8
Projects in
Region
33
14
40
66
79
39
117
Percent of
Total
3%
1%
4%
6%
7%
4%
11%
Completed Projects with
Duration Data1
18
2
20
27
34
17
26
Percent of
Total
4%
0%
5%
7%
8%
4%
6%
Average Project
Duration (days)
769
799
757
1327
1347
1573
1270
Correlation
Coefficient
-0.136
-0.042
-0.148
0.037
0.05
0.1
0.016
t-stat
-2.754
-0.834
-2.993
0.746
1.007
2.013
0.317
t-crit
1.96
1.96
1.96
1.96
1.96
1.96
1.96
Significant?
Yes
No
Yes
No
No
Yes
No
Evaluation Report-March 2011
Appendix D - Page 15

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                          EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
Projects in Percent of Completed Projects with Percent of Average Project Correlation
Region Total Duration Data1 Total Duration (days) Coefficient
Region 9
Region 10
TOTAL
449
255
1092
41%
23%

144
114
402
36%
28%

1174
1333

-0.054
0.092

-1.074
1.857

t-crit
1.96
1.96

Significant?
No
No

Notes:


(1) We compared the percent of the total number of projects within a region to the percent of completed projects with duration data and the percents are similar or equal. Thus, we have no reason

to believe that one or more areas are disproportionately affected by missing/incomplete data.
3.   Correlation between project funding levels and project duration? Summary response: Yes, but weakly.
                             Scatter plot - Total Funded and Duration
             4500
        n
       •a
        c
        O
                                             STARS Total Funded
               Correlation Coefficient
                      0.147
                                                  2.970         1.96
Significant?
                                                                               Yes
Evaluation Report-March 2011
                                                              Appendix D - Page 16

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                        EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
        General Descriptive Statistics:
            Number of Projects = 402 (with duration data), 400 with needed funding data
            Average Duration = 1229 days; Average Funding = $509,360
        Project duration is positively correlated with funding amount - projects with more funding are associated with longer duration.
        This relationship is statistically significant, but the correlation coefficient is low and thus the correlation is not strong.
        Funding information can be found in two places within STARS:  Fund_Advice_Snapshot and Project_Costs_Snapshot. Both are from PDS, and both can
        be used to produce per-project cost estimates by aggregating cost data for each project.  For the most part, the sources produce similar project costs.
        However, for a minority of projects, sources have missing data or conflicting data. Thus, for projects that are missing cost data from one source, we
        used the other source. For projects where cost data conflict, we used to the higher cost figure.
4.   Correlation between project funding from a community and project duration? Summary response: No.
      Projects with Tribal Funding  Average Duration for a project with Tribal Funding (days) Correlation Coefficient    t-stat    t-crit   Significant?
                 28
                                                     1,095
                                                                                       -0.050
                                                                                                       -0.995
                                                                                                                1.96
                                                                                                                           No
    >   General Descriptive Statistics:
            Number of Projects = 402 (with duration data), 28 with Tribal funding
            Average Duration = 1229 days average across 402 projects; 1095 days for 28 projects with tribal funding.
    >   Thus, project duration is negatively correlated with project having received tribal funding.
    >   This relationship is not statistically significant.

s.   Correlation between whether a project is a direct grant and project duration? Response: Cannot analyze because only 2 of the 402 projects in the
    universe with complete project duration data were direct grants.

6.   Correlation between project level DLs and community DLs? Summary response: No.
. . . Number of Communities with
CW/Sewer DL
DW/Water DL
347
354
Number of Projects in these
696
556
Correlation ...
• „. . t-stat t-crit Significant?
Coefficient
0.047
-0.058
0.882
-1.086
1.96
1.96
No
No
Evaluation Report-March 2011
Appendix D - Page 17

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                       EVALUATION OF THE                AND            INFRASTRUCTURE TRIBAL SET-ASIDE

        The analysis finds no statistically significant relationship between changes in CW project DLs and changes in the community sewer DL.
        The analysis finds no statistically significant relationship between changes in DW project DLs and changes in the community water DL

    Methodology: To explore the correlation  between project DLs and community DLs, we used the following method:
    1.   Community data: Community DLs are reported by home type in STARS, not by the community as a whole.  Thus, for each community served by one or
        more EPA projects, we calculated:
           a.  The weighted-average (by homes served) of the water DLs in both 2004 and DL in 2009
           b.  The weighted-average (by homes served) of the sewer DLs in both 2004 and DL in 2009.
           c.  We then calculated the change in the water and sewer DLs for each community between 2004 and 2009.
    2.   Project data: We took the most recent data reported  on the IDL and FDL for each EPA project, and calculated a weighted average IDL and FDL (by
        homes served) for projects in each  community served by an EPA project. We then calculated the change from the IDL to the FDL for each project.
    3.   We then ran two separate correlations :
           a.  The change in community-level sewer DL over the timeframe of this analysis and the change in clean water (CW) project DLs.
           b.  The change in community-level water DL over the timeframe of this analysis and the change in drinking water (DW) project DLs.

    Notes:
    1.   We used all projects in this correlation, not just completed projects, because community DLs factor in the predicated results of ongoing projects. IMS
        enters a new (prospective) community DL when they enter a new project into PDS. It is not clear if IMS revises the DL once the project is complete.
    2.   Summing the number of projects in the table above gives a number greater than the EPA project universe considered for this analysis.  The sum is
        greater because some projects are  associated with more than one community and thus may impact more than one community DL.
    3.   This analysis looks only at EPA-funded projects, and  relationship of EPA-funded projects to community DLs. Although it is not central to the evaluation
        of  EPA's programs, it should  be noted  that it is possible that results of this correlation  analysis would differ if we looked  at all projects in the
        community, not just ones funded by EPA.  However, we do not see how we could  look at the relationship between all projects in a community and
        community DLs because STARS does not indicate (in any of the numeric  fields at least) if a project is a drinking water or clean water/sewer project,
        despite the fact that they record separate community-level DLs for water and sewer.
Evaluation Report - March 2011                                                                                                      Appendix D - Page 18

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
APPENDIX  E.  DETAILED  DATA TABLES
Data Notes: Most information, except where noted, is organized by "funding year" - the year in which funds were
awarded to a project. Funding year is equivalent to calendar year, rather than federal fiscal year. In addition,
except where noted, data tables are for EPA-funded projects that are funded between 2003 and 2009, excluding
ARRA projects. ARRA projects are discussed separately.

DWIG-TSA Implementation

                  Table 1. Number of DWIG-TSA Projects, by EPA Region and Funding Year
Region 2003 2004 2005 2006 2007 2008 2009 Total
1
2
4
5
6
7
8
9
10
Total
0
0
1
4
2
2
2
19
16
46
0
1
1
2
3
4
4
16
14
45
4
1
1
4
2
1
6
11
10
40
0
0
1
8
2
3
4
13
7
38
4
2
1
4
3
3
8
6
8
39
3
0
1
3
0
3
7
7
4
28
0
1
1
4
2
2
4
9
8
31
11
5
7
29
14
18
35
81
67
267
Note: This table includes all projects funded by EPA between 2003-2009, excluding ARRA projects, but including direct grants and lAs with IMS.
Projects that a re funded multiple times over multiple years under the same PDS number are considered separate projects for this count. There
are 257 unique projects within this timeframe.

                       Table 2. EPA Funding of DWIG-TSA projects, by EPA Region
Region Average Median Minimum Maximum
1
2
4
5
6
7
8
9
10
All
$148,273
$435,820
$433,314
$229,360
$251,639
$113,853
$255,850
$426,793
$480,261
$354,942
$113,000
$300,000
$456,000
$161850
$258,120
$104080
$189,119
$236,000
$340,000
$230,000
$14,000
$198,400
$150,000
$12,700
$50,000
$14,152
$2,100
$10,000
$50,915
$2,100
$358,000
$928,852
$603,900
$590,696
$619,000
$300,800
$711,401
$2,603,000
$2,382,300
$2,603,000
Evaluation Report-March 2011
Appendix E - Page 19

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS

                        Table 3. Total Funding to DWIG-TSA projects, by EPA Region
Region 2003 2004 2005 2006
1
2
4
5
6
7
8
9
10
Total
$0
$0
$423,000
$584,595
$669,000
$248,400
$569,150
$4,767,946
$5,203,837
$12,465,928
$0
$928,852
$150,000
$361,000
$613,741
$312,050
$743,962
$7,021,574
$4,715,182
$14,846,361
$351,000
$198,400
$603,900
$1,138,550
$110,000
$300,800
$1,442,760
$7,368,442
$4,896,673
$16,410,525
$0
$0
$431,300
$982,050
$662,000
$365,000
$1,285,259
$3,120,457
$5,237,410
$12,083,476
2007 2008 2009 Total
$765,000
$778,348
$489,000
$1,219,500
$1,068,200
$251,100
$1,781,075
$3,766,209
$3,256,372
$13,374,804
$515,000
$0
$480,000
$724,600
$0
$304,740
$1,709,430
$2,940,790
$4,467,000
$11,141,560
$0
$273,500
$456,000
$1,641,136
$400,000
$267,260
$1,423,100
$5,584,776
$4,401,000
$14,446,772
$1,631,000
$2,179,100
$3,033,200
$6,651,431
$3,522,941
$2,049,350
$8,954,736
$34,570,194
$32,177,474
$94,769,426
            Table 4. Total Number and Funding of DWIG-TSA lAs and Direct Grants, by EPA Region
Region Direct Grants Direct Grant $
1
2
4
5
6
7
8
9
10
All
0
1
3
0
1
0
21
10
0
36 (13.5%)
$0
$928,852
$1,524,200
$0
$208,741
$0
$4,725,011
$5,612,701
$0
$12,999,505 (13.7%)

11
4
4
29
13
18
14
71
67
231 (86.5%)
1 |
$1,631,000
$1,250,248
$1,509,000
$6,651,431
$3,314,200
$2,049,350
$4,229,725
$28,957,493
$32,177,474
$81,769,921 (86.3%)
11
5
7
29
14
18
35
81
67
267
$1,631,000
$2,179,100
$3,033,200
$6,651,431
$3,522,941
$2,049,350
$8,954,736
$34,570,194
$32,177,474
$94,769,426
    Table 5. Number of Homes Served by DWIG-TSA Projects, by EPA Region and by Funding Year (from PDS)
Region 2003 2004 2005 2006 2007 2008 2009 Total
1
2
4
5
6
7
8
9
10
Total
0
0
75
118
448
267
0
11,500
1373
13,781
0
225
200
350
826
790
0
2,530
641
5,562
61
97
224
794
284
175
856
2,622
1,415
6,528
0
0
0
1,230
767
844
983
6,628
1,660
12,112
586
543
195
0
100
274
582
1,285
615
4,180
270
0
177
56
0
637
955
590
774
3,459
0
0
351
111
631
0
1,531
313
971
4,524
917
865
1,222
3,275
3,056
2,987
4,907
25,468
7,449
50,146
Note that there are homes served multiple times in this count. "Served" indicates a home benefited from or was impacted by an EPA project,
versus "provided access". This table does not include direct grant projects or projects that could not otherwise be connected to IMS STARS PDS.
The above table accounts for approximately 79% of unique DWIG-TSA projects (204 out of 257).

DWIG-TSA Project Selection

DWIG-TSA SDS Information

The below tables present information available from SDS for EPA DWIG-TSA projects funded between 2004 and
2009, excluding ARRA  projects.  As there is only data from 2004-2009 from IMS STARS for this evaluation, projects
funded by EPA in 2003 do not have SDS information for this evaluation. These tables include approximately 34% of
the EPA, non-ARRA, projects funded between 2004 and 2009 (72 out of 214). Some funded projects are associated
Evaluation Report-March 2011
Appendix E - Page 20

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS

with multiple SDS projects.  For DWIG-TSA, regions  are not required to choose projects from the SDS list, which
could explain at least part of the reason behind the low percentage of projects with SDS information.

        Table 6. Area Priority Ranking Information of DWIG-TSA Projects Selected by EPA by IMS Area and
                                            EPA Region (from SDS)
IMS Area
Aberdeen
Region 7
Region 8
Alaska (RIO)
Albuquerque
Region 6
Region 8
Bemidji (R5)
Billings (R8)
California (R9)
Nashville
Region 1
Region 2
Region 4
Region 6
Navajo (R9)
Oklahoma
Region 6
Region 7
Phoenix
Region 8
Region 9
Portland (RIO)
Tucson (R9)
Overall
ft of Projects Minimum Maximum Average
4
1
3
26
1
1
0
11
0
10
8
1
3
4
0
1
2
1
1
6
1
5
9
1
79
1 (0.5%)
65 (26.0%)
1 (0.5%)
1 (0.2%)
73 (34.0%)
73 (34.0%)
n/a
2 (0.9%)
n/a
3 (2.0%)
1 (0.6%)
64 (32.3%)
1 (0.6%)
2 (1.1%)
n/a
307 (43.7%)
6 (1.9%)
142 (42.8%)
6 (1.9%)
5 (2.0%)
16 (6.4%)
5 (2.0%)
1 (0.5%)
9 (5.8%)
1
65 (26.0%)
65 (26.0%)
31 (11.4%)
163 (32.6%)
73 (34.0%)
73 (34.0%)
n/a
51 (29.0%)
n/a
218 (93.2%)
75 (36.9%)
64 (32.3%)
6 (3.0%)
75 (36.9%)
n/a
307 (43.7%)
142 (42.8%)
142 (42.8%)
6 (1.9%)
114 (44.7%)
16 (6.4%)
114 (44.7%)
80 (40.4%)
9 (5.8%)
307
27.00
65.00
14.33
30.00
73.00
73.00
n/a
22.36
n/a
53.60
23.38
64.00
4.00
27.75
n/a
307.00
74.00
142.00
6.00
49.33
16.00
56.00
15.11
9.00
35.77
Median
22
65
11
17
73
73
n/a
14
n/a
9
5.5
64
5
17
n/a
307
74
142
6
27
16
36
4
9
14
Note: The above is the minimum, maximum, average, and median priority rankings, by area, for all EPA projects funded between 2004 and
2009. For the minimum and maximum, the percentile ranks within that year's area SDS list is in parentheses. This information is presented by
area, as SDS lists are by IMS areas, rather than in EPA regions.  Where multiple EPA regions work with  an IMS area, the region's specific
information is presented.

Below, the table  presents the average deficiency level score of all EPA-funded projects in a particular EPA region.
The deficiency level score is a 0 to 18 score that is a component of computing the priority ranking for SDS:

    >   DL-4or5:18 points

    >   DL-3: 12 points

    >   DL-2: 6 points

    >   DL-1: 0 points
Evaluation Report-March 2011
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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS

  Table 7. Average of Deficiency Level Scores of DWIG-TSA projects, by EPA Region, excluding ARRA (from SDS)
EPA Region Deficiency Level Score Average # of SDS projects
1
2
4
5
6
7
8
9
10
All
6.00 (DL-2)
14.00 (DL-3 to DL-4/5)
12.00 (DL-3)
12.55 (DL-3 to DL-4/5)
15.00 (DL-3 to DL-4/5)
12.00 (DL-3)
12.00 (DL-3)
15.88 (DL-3 to DL-4/5)
15.43 (DL-3 to DL-4/5)
14.51 (DL-3 to DL-4/5)
1
3
4
11
2
2
4
17
35
79
  Table 8. Deficiencies Funded from SDS list for DWIG-TSA projects, by EPA Region, excluding ARRA (from SDS)
EPA Region
1
2
4
5
6
7
8
9
10
Total
Deficiency Level Score
6 (DL-2) 12 (DL-3) 18 (DL-4/5)
1
0
2
3
0
1
0
1
1
9 (11.4%)
0
2
0
4
1
0
4
4
13
28 (35.4%)
0
1
2
4
1
1
0
12
21
42 (53.2%)
# of SDS projects
1
3
4
11
2
2
4
17
35
79
As the deficiency level is just one of eight criteria for determining the priority ranking of a project (18 possible
points out of 108), projects with lower deficiency levels can be in the top rankings of areas.  In the latest year of
SDS data available for this evaluation (2009), the top 10 SDS needs (including solid waste,  water, and  sewer
projects) in all of the 12 IMS areas accounted for:
    >    72 DL-4 or DL-5 home needs (60%)
    >    33 DL-3 home needs (27.5%)
    >    15 DL-2 home needs (12.5%)

DWIG-TSA PDS Information

The below tables present information available from SDS for EPA DWIG-TSA projects funded between  2003 and
2009, excluding ARRA. These tables include information for approximately 79% of all DWIG-TSA projects funded
between 2003  and 2009, excluding ARRA (204 out of 257); these tables exclude PDSs that were  funded multiple
times by EPA to eliminate some duplication in project and home counting.
Evaluation Report-March 2011
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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS

              Table 9. Project-level IDL and FDLs of DWIG-TSA projects, excluding ARRA (from PDS)
                 Total
                            33
                                    38
                                    55
                                    42
                                   141
                                                   10
                                                           15
                                                           15
                                                                                   Without DL-0
                                                                    28 (13.7%)
                                                                     3 (1.5%)
44 (21.6%)
66 (32.4%)
60 (29.4%)
                                                                     3 (1.5%)
                                                                       204
                   n/a
                 3 (1.7%)
44 (25.0%)
66 (37.5%)
60 (34.1%)
                 3 (1.7%)
                                                                                       176
Note: DL-0 needs appear to be situations where the IDL and FDL have not been entered for the project in STARS PDS or deficiencies were
determined not to exist.  Percentages are provided including and excluding the DL-0 designations to account for any data gaps.


    Table 10. Home IDL and FDLs of DWIG-TSA projects, funding years 2003-2009, excluding ARRA (from PDS)

IDL Total
0 1234 Without DL-0
0
1
2
3
4
5
Total
11,304
0
118
459
0
0
11,881
0
199
13,267
9,261
5,024
163
27,914
0
0
2,024
0
0
0
2,024
0
0
0
3,315
1,388
0
4,703
0
0
0
0
3,624
0
3,624
11,304 (22.5%)
199 (0.4%)
15,409 (30.7%)
13,035 (26.0%)
10,036 (20.0%)
163 (0.3%)
50,146
n/a
199 (0.5%)
15,409 (39.7%)
13,035 (33.6%)
10,036 (25.8%)
163 (0.4%)
38,842
Note: DL-0 needs appear to be situations where the IDL and FDL have not been entered for the project in STARS PDS or deficiencies were
determined not to exist.  Percentages are provided including and excluding the DL-0 designations to account for any data gaps.

Compliance Information

                 Table 11. Compliance Information for Evaluation Universe (SDWIS: 2004-2008)
Universe # of systems/projects # with at least 1 HB violation # with repeat HB violations
All EPA Tribal Systems (CWSs)
EPA-funded Systems
Non-Grantee Systems
733
249
496
314 (42.9%)
116 (46.6%)
198 (39.9%)
195 (26.6%)
83 (33.3%)
112 (22.6%)
Note: Does not include 51 projects with no PWSs or PWSs that could not be linked to SDWIS data pull.
Evaluation Report-March 2011
                          Appendix E - Page 23

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS





                   Table 12. Number of Violations at EPA-funded PWSs(SDWIS: 2004-2008)
HB/MR Vcode Violation Name
HB
MR
1
2
21
22
37
41
42
43
44
46
57
58
65
3
4
6
23
24
25
26
27
29
31
36
38
51
52
53
71
72
75
MCL, Single Sample
MCL, Average
MCL, Acute (TCR)
MCL, Monthly (TCR)
Treatment Technique State Prior Approval
Treatment Technique (SWTR and GWR - failure to maintain adequate
treatment; LT2 -failure to provide the level of treatment appropriate for
bin classification)
Failure to Filter (SWTR)
Treatment Technique Exceeds Turb 1 NTU
Treatment Technique Exceeds Turb 0.3 NTU
Treatment Technique Precursor Removal
OCCT Study Recommendation
OCCT Installation/Demonstration
Public Education
Monitoring, Regular
Monitoring, Check/Repeat/Confirmation
Notification, Public
Monitoring, Routine Major (TCR)
Monitoring, Routine Minor (TCR)
Monitoring, Repeat Major (TCR)
Monitoring, Repeat Minor (TCR)
Monitoring and Reporting Stage 1
M&R Filter Profile/CPE Failure
Monitoring (UNFILTERED), Routine/Repeat (SWTR-Unfilt and GWR-
Unfiltered) - Major & Minor
Monitoring, Routine/Repeat (SWTR-Filter and GWR-Unfiltered)) - Major
& Minor
M&R Filter Turbidity Reporting
Initial Tap Sampling for Pb and Cu
Follow-up and Routine Tap Sampling
Initial Water Quality Parameter WQP M&R
CCR Complete Failure to Report
CCR INADEQUATE REPORTING
PN Violation for NPDWR Violation
Number of Violations
27
461
12
173
40
260
6
29
68
56
2
3
4
4592
8
8
760
386
68
84
1157
20
4
769
220
4
74
2
322
26
1
Note: HB = Health-based violation, MR = Monitoring and Reporting Violation
Evaluation Report-March 2011
Appendix E - Page 24

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
                                 Table 13. SP-3 Calculations for Funded Projects
EPA Funded PWSs # of Projects
All Systems
All Systems, excluding
Alaska
Systems with Completed
Projects4
Systems with Completed
Projects excluding Alaska
279
219
75
65
Total
Population in
Population Compliance
214,686
196,899
44,566
40,002
164,093
152,297
34,701
30,683
SP-3 Results for
SP-3 Result all Tribal CWSs
^^^^^^^|| (2009)
76.4%
77.3%
77.9%
76.7%
81.2%
The nationally reported results for SP-3 for 2009 are calculated on four quarters of data, spanning July 2008 to June 2009. To more accurately
compare to this information with available detailed SDWIS data, this evaluation looked at the compliance information across the four quarters
of calendar year 2008 compared against the nationally reported results of federal fiscal year 2009. This information does not included the 51
projects that had PWSIDs that could not be linked to provided SDWIS information.


CWISA Implementation

                    Table 14. Number of CWISA Projects, by EPA Region and by Funding Year
Region 2003 2004 2005 2006 2007 2008 2009 Total
1
2
4
5
6
7
8
9
10
Total
2
0
9
1
5
2
7
54
17
95
2
1
3
5
3
1
7
23
12
57
1
1
0
7
3
0
6
34
9
61
0
1
4
2
3
1
4
20
10
45
1
1
1
1
5
1
4
42
9
65
0
0
1
3
2
1
3
26
11
47
1
1
3
5
3
0
6
35
5
59
7
5
14
24
24
4
36
224
65
429
Note: This table includes all projects funded by EPA between 2003-2009, excluding ARRA projects, but including direct grants and lAs with IMS.
Projects that a re funded multiple times over multiple years under the same PDS number are considered separate projects for this count. There
are 402 unique  projects in this timeframe.
                             Table 15. EPA Funding of CWISA projects, by EPA Region
Region Average
1
2
4
5
6
7
8
9
10
All
$312,171
$165,000
$101,950
$82,332
$271,268
$179,051
$252,072
$202,284
$534,807
$258,530
^1X^1 ^I^Tffi ^I^^H
$264,200
$102,000
$83,057
$50,000
$221,905
$175,000
$191,668
$122,500
$421,000
$1506,000
$200,000
$55,000
$10,000
$9,600
$12,000
$74,000
$12,100
$6,108
$60,600
$6,108
$618,000
$376,000
$446,200
$388,420
$975,600
$289,000
$740,000
$1,889,000
$2,225,639
$2,225,639
 Completed as of the end of 2008

Evaluation Report- March 2011
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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
                Table 16. Total Funding of all CWISA projects, by EPA Region and Funding Year
Region 2003 2004 2005 2006 2007
1
2
4
5
6
7
8
9
10
Total
$504,200
$0
$477,500
$178,200
$1,035,000
$224,000
$1,628,300
$7,663,600
$8,193,300
$19,904,100
$510,000
$100,000
$631,200
$474,400
$1,521,100
$150,000
$1,519,800
$8,692,100
$6,531,900
$20,130,500
$618,000
$376,000
$0
$299,500
$362,000
$0
$2,114,000
$7,493,000
$5,073,000
$16,335,500
$0
$192,000
$381,500
$235,580
$590,600
$289,000
$1,112,100
$5,731,800
$4,858,200
$13,390,780
$353,000
$102,000
$278,000
$388,420
$1,000,000
$200,000
$1,238,000
$6,338,600
$6,443,000
$16,341,020

$0
$0
$44,183
$125,790
$1,081,886
$211,305
$788,821
$3,908,320
$4,174,624
$10,334,929
^^^^^1
$200,000
$55,000
$328,557
$274,077
$919,854
$0
$925,652
$3,865,939
$3,766,921
$10,336,000
$2,185,200
$824,965
$1,830,440
$1,975,967
$6,510,440
$850,305
$9,248,573
$43,046,177
$37,194,306
$103,666,373
             Table 17. Total Number and Funding of CWISA lAs and Direct Grants, by EPA Region
Region Direct Grants Direct Grant $ lAs
1
2
4
5
6
7
8
9
10
All
0
0
11
0
0
0
8
2
0
21 (4.9%)
$0
$0
$679,000
$0
$0
$0
$1,432,317
$1,050,000
$0
$3,161,317 (3.0%)
7
5
10
24
22
6
29
230
73
406 (95.1%)

$2,185,200
$824,965
$1,461,940
$1,975,967
$5,964,940
$1,074,305
$7,894,356
$42,643,359
$39,040,945
$103,066,012 (97.0%)

7
5
21
24
22
6
37
232
73
427
•^^^^Kz^H
$2,185,200
$824,965
$2,140,940
$1,975,967
$5,964,940
$1,074,305
$9,326,673
$43,693,359
$39,040,945
$106,227,329
Note: Two Region 6 projects were listed as being both direct grants and lAs-they are not included here.
           Table 18. Number of Homes Served by CWISA Projects, by EPA Region and Funding Year
Region 2003 2004 2005 2006 2007 2008 2009 Total
1
2
4
5
6
7
8
9
10
Total
473
0
49
41
639
0
1,470
3,305
1,362
7,339
0
40
511
1,584
749
18
1,284
6,567
999
11,752
229
81
0
98
211
0
2,261
4,549
514
7,943
0
0
1,431
222
548
24
1,656
7,872
581
12,334
118
60
65
0
1,332
23
1,167
6,525
1,003
10,293
0
0
1,045
127
454
125
128
1,373
914
4,166
63
0
200
0
962
0
168
776
823
2,992
883
181
3,301
2,072
4,895
190
8,134
30,967
6,196
56,819
Evaluation Report-March 2011
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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS

             Table 19. Number of Homes Served by CWISA Projects, by IMS Area and Funding Year
IMS Area 2003 2004 2005 2006 2007 2008 2009 Total
Aberdeen
Albuquerque
Anchorage
Bemidji
Billings
California
Navajo
Nashville
Oklahoma
Phoenix
Portland
Tucson
Total
1,265
111
1,040
41
47
225
2,116
943
104
919
322
45
7,339
775
600
692
1,584
527
82
1,642
551
149
3,905
307
938
11,752
926
135
453
98
1,200
199
1,833
310
211
1,101
61
1,416
7,943
988
548
581
222
668
216
5,957
1,431
24
1,667
0
32
12,334
972
1,184
614
0
195
245
5,455
111
137
742
389
83
10,293
0
382
650
127
128
389
564
1,117
125
393
264
27
4,166
133
4
163
0
35
294
144
263
958
323
660
15
2,992
5,059
3,125
4,193
2,072
2,800
1,650
1,7711
4,892
1,708
9,050
2,003
2,556
56,819
Note that there are homes served multiple times in these above counts. "Served" indicates a home benefited from or was impacted by an EPA
project, versus necessarily "provided access". This table does not include projects that could not be connected to IMS STARS PDS. The above
accounts for approximately 85% of unique CWISA projects funded between 2003 and 2009 (343 out of 402).

Project Selection

CWISA SDS Information

The below tables present information available from SDS for EPA CWISA projects funded between 2004 and 2009,
excluding ARRA projects.  As there is only data from 2004-2009 from IMS STARS for this evaluation, projects funded
by EPA in 2003 do not have SDS information for this evaluation. These tables  include approximately 82% of the
EPA, non-ARRA,  projects funded between 2004 and 2009 (255  out of 310). Some funded projects  are associated
with multiple SDS projects.
Evaluation Report-March 2011
Appendix E - Page 27

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS

  Table 20. Area Priority Ranking Information of CWISA Projects Selected by EPA for Funding Years 2004-2009,
                             excluding ARRA projects, by IMS Area and EPA Region
IMS Area/ EPA Region # of Projects Minimum Maximum Average
Aberdeen
Region 7
Region 8
Alaska (RIO)
Albuquerque
Region 6
Region 8
Bemidji (R5)
Billings (R8)
California (R9)
Nashville
Region 1
Region 2
Region 4
Region 6
Navajo (R9)
Oklahoma
Region 6
Region 7
Phoenix
Region 8
Region 9
Portland (RIO)
Tucson (R9)
Overall
9
0
9
37
8
7
1
19
12
28
18
3
4
9
2
107
9
6
3
14
0
14
6
10
277
2 (1.0%)
n/a
2 (1.0%)
1 (0.2%)
2 (0.9%)
2 (0.9%)
8 (4.1%)
11 (6.1%)
1 (0.7%)
1 (0.4%)
1 (0.5%)
2 (1.3%)
1 (0.6%)
1 (0.5%)
1 (0.5%)
1 (0.1%)
4(1.2%)
4(1.2%)
15 (4.6%)
4(1.6%)
n/a
4(1.6%)
5 (2.5%)
1 (0.7%)
1
12 (5.7%)
n/a
12 (5.7%)
152 (27.2%)
21 (9.8%)
21 (9.8%)
8 (4.1%)
152 (66.4%)
34 (24.0%)
120 (40.4%)
13 (6.5%)
6 (3.0%)
9 (5.1%)
13 (6.5%)
9(4.6)
536 (76.4%)
36 (11.0%)
27 (8.3%)
36 (11.0%)
109 (42.7%)
n/a
109 (44.0%)
92 (46.9%)
40 (26.0%)
536
6.89
n/a
6.89
20.00
8.75
8.86
8.00
79.89
6.92
19.36
5.33
4.00
5.00
6.00
5.00
67.35
18.44
14.83
25.67
25.64
n/a
25.64
22.33
10.70
40.06
Median
7
n/a
7
15
8
8
8
79
4
11
4.5
4
6
5
5
20
16
14
26
11.5
n/a
11.5
8
2
14
Note: The above is the minimum, maximum, average, and median priority rankings, by area, for all EPA projects funded between 2004 and
2009, excluding ARRA. Forthe minimum and maximum, the percentile ranks within that year's area SDS list is in parentheses. This information
is presented by area, as SDS lists are by IMS area, rather than in EPA regions. Where multiple EPA regions work with an IMS area, the region's
specific information is presented.

               Table 21. Average Deficiency Level Scores of CWISA projects (SDS), by EPA Region
EPA Region Deficiency Level Score Average # of SDS projects
1
2
4
5
6
7
8
9
10
All
12.00 (DL-3)
15.00 (DL-3 to DL-4/5)
11.33 (DL-2 to DL-3)
7.89 (DL-2 to DL-3)
14.40 (DL-3 to DL-4/5)
18.00 (DL-4/5)
14.18 (DL-3 to DL4/5)
16.19 (DL-3 to DL-4/5)
15.07 (DL-3 to DL-4/5)
14.99 (DL-3 to DL-4/5)
3
4
9
19
15
3
22
159
43
277
As the deficiency level is just one of eight criteria for determining the priority ranking of a project (18 possible
points out of 108), projects with lower deficiency levels can be in the top rankings of areas.  In the latest year of
SDS  data available for this evaluation (2009), the  top 10 SDS needs (including solid waste, water,  and sewer
projects) in all of the 12 IMS areas accounted for:
Evaluation Report-March 2011
Appendix E - Page 28

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS

    >   72 DL-4 or DL-5 home needs (60%)
    >   33 DL-3 home needs (27.5%)
    >   15 DL-2 home needs (12.5%)
                      Table 22. Deficiency Levels of CWISA projects (SDS), by EPA Region
EPA Region
1
2
4
5
6
7
8
9
10
Total
Deficiency Level Score
6 (DL-2) 12 (DL-3) 18 (DL-4/5)
0
0
3
14
3
0
2
10
0
32 (11.6%)
3
2
4
4
3
0
10
28
21
75 (27.1%)
0
2
2
1
9
3
10
121
22
170 (61.4%)
# of SDS projects
3
4
9
19
15
3
22
159
44
277
Note: Of the 170 DL-4/5 projects, 15 of these projects would have a final deficiency level of DL-4, indicating that no access was provided.

CWISA PDS Information

The below tables present information available from SDS for EPA CWISA projects funded between 2003 and 2009,
excluding ARRA.  These tables  include information for  approximately  85% of  unique CWISA projects funded
between 2003 and 2009, excluding ARRA (343 out of 402); these tables exclude  PDSs that were funded multiple
times by EPA to eliminate some duplication in project and home counting.

                           Table 23. Project-level IDL and FDLs of CWISA projects
•55B
	 1 	 1 	 1 	 1 	
01234 Without DL-0
0
1
2
3
4
5
Total
24
0
2
7
7
2
42
0
5
36
76
72
72
261
0
0
5
5
2
0
12
0
0
0
6
7
0
13
0
0
0
0
13
2
15
24 (7.0%)
5 (1.5%)
43 (12.5%)
94 (27.4%)
101 (29.5%)
76 (21.2%)
343
n/a
5 (1.6%)
43 (13.5%)
94 (29.5%)
101 (31.7%)
76 (23.8%)
319
Note: DL-0 needs appear to be situations where the IDL and FDL have not been entered for the project in STARS PDS or deficiencies were
determined not to exist. Percentages are provided including and excluding the DL-0 designations to account for any data gaps.
Evaluation Report-March 2011
Appendix E - Page 29

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
                              Table 24. Home IDLs and FDLs of CWISA projects
             Total
                     7,178
                     367
                     3,054
                     591
                      108
                    11,298
                             1,103
                             13,705
18,920
                             3,905
                             1,795
39,428
         3,048
1,360
                                      195
                                       0
4,603
                                             380
                                             334
                                             714
                                                    743
                                                    33
                                                    776
                                7,178 (12.6%)
                                1,103 (1.9%)
                       17,120 (30.1%)
23,714 (41.7%)
                                5,768 (10.2%)
                                1,936 (3.4%)
   56,819
                                          1,103 (2.2%)
                  17,120 (34.5%)
23,714 (47.8%)
                                         5,768 (11.6%)
                                          1,936 (3.9%)
   49,641
Note: DL-0 needs appear to be situations where the IDL and FDL have not been entered for the project in STARS PDS or deficiencies were
determined not to exist.  Percentages are provided including and excluding the DL-0 designations to account for any data gaps.

Project Completion and Duration  Information

DWIG-TSA

Note: The below tables include information  on all unique EPA projects provided for this evaluation with milestone
data in, excluding ARRA projects PDS (403  of 462 projects, or 87%).  When an EPA region has funded a project
under the same  PDS number multiple times, the milestone information is only included once in the calculations.
Projects for these tables fall between EPA funding years of 1997 and 2009.

            Table 25. DWIG-TSA projects with construction completed, by IMS Area and EPA Region
Area/Region
Aberdeen
Region 7
Region 8
Alaska (RIO)
Albuquerque
Region 6
Region 8
Bemidji (R5)
Billings (R8)
California (R9)
Nashville
Region 1
Region 2
Region 4
Region 6
Navajo (R9)
Oklahoma
Region 6
Region 7
Phoenix
Region 8
Region 9
Portland (RIO)
Tucson (R9)
Total - DWIG-TSA
Construction not
Complete
13
9
4
37
8
6
2
11
9
18
18
7
4
7
0
34
11
7
4
17
2
15
8
9
193 (47.9%)
Construction Complete
20
13
7
54
19
18
1
20
0
6
27
14
2
11
0
9
4
2
2
16
2
14
26
9
210 (52.1%)
Total
33
22
11
91
27
24
3
31
9
24
45
21
6
18
0
43
15
9
6
33
4
29
34
18
403
Paperwork Complete
5
2
3
41
11
10
1
4
n/a
2
5
4
1
0
n/a
1
1
1
0
15
2
13
24
0
109 (51.9% of projects complete)
Evaluation Report-March 2011
                                                            Appendix E - Page 30

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
       Table 26. Construction Duration (MOA signed to Construction Complete) for DWIG-TSA projects,
                                   by IMS Area and EPA Region (days)
Area/Region Average Median
Aberdeen
Region 7
Region 8
Alaska (RIO)
Albuquerque
Region 6
Region 8
Bemidji (R5)
Billings (R8)
California (R9)
Nashville
Region 1
Region 2
Region 4
Region 6
Navajo (R9)
Oklahoma
Region 6
Region 7
Phoenix
Region 8
Region 9
Portland (RIO)
Tucson (R9)
All
1,289
1,516
868
1,173
1,547
1,601
580
1,480
n/a
1,114
872
849
799
914
n/a
1,475
1,288
950
1,627
1,420
2,674
1,241
1,599
901
1,282 (3.51 years)
1,074
1,155
512
1,102
1,417
1,454
580
1,437
n/a
1,158
749
710
799
797
n/a
1,310
1,081
950
1,627
1,460
2,674
1,411
1,494
839
1,202 (3.29 years)
Minimum
77
653
77
64
386
386
580
178
n/a
410
14
79
748
14
n/a
976
638
638
899
336
2,489
336
242
505
14 (0.04 years)
Maximum # of Projects
3,169
3,169
2,945
2,759
3,224
3,224
580
3,324
n/a
1,509
1,961
1,961
849
1,720
n/a
2,875
2,354
1,262
2,354
2,858
2,858
2,254
3,068
1,415
3,324 (9.11 years)
20
13
7
54
19
18
1
20
0
6
27
14
2
11
0
9
4
2
2
16
2
14
26
9
210
Evaluation Report-March 2011
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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
   Table 27. Duration Final Report (Construction Complete to Final Report Complete) for DWIG-TSA projects,
                                   by IMS Area and EPA Region (days)
Area/Region
Aberdeen
Region 7
Region 8
Alaska (RIO)
Albuquerque
Region 6
Region 8
Bemidji (R5)
Billings (R8)
California (R9)
Nashville
Region 1
Region 2
Region 4
Region 6
Navajo (R9)
Oklahoma
Region 6
Region 7
Phoenix
Region 8
Region 9
Portland (RIO)
Tucson (R9)
All

728
947
582
679
643
682
260
2,194
n/a
1,327
749
733
815
n/a
n/a
728
690
690
n/a
467
307
492
502
n/a
681 (1.69 years)
^B^^P
620
947
620
565
260
236
260
2,195
n/a
1,327
815
671
815
n/a
n/a
728
690
690
n/a
493
307
537
501
n/a
559 (1.53 years)
Minimum Maximum # of projects
241
241
334
61
43
43
260
1,370
n/a
915
159
159
815
n/a
n/a
728
690
690
n/a
18
292
18
105
n/a
18 (0.05 years)
1,653
1,653
792
2,243
2,387
2,387
260
3,015
n/a
1,738
1,429
1,429
815
n/a
n/a
728
690
690
n/a
941
322
941
932
n/a
3,015 (8.26 years)
5
2
3
41
11
10
1
4
n/a
2
5
4
1
0
n/a
1
1
1
0
15
2
13
24
0
109
Evaluation Report-March 2011
Appendix E - Page 32

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
CWISA

Wote: The below tables include information on all unique EPA projects provided for this evaluation with milestone
data in, excluding ARRA projects PDS (457 out of 554 projects, or 83%).  When an EPA region has funded a project
under the same PDS number multiple times, the milestone information is only included once in the calculations.
Projects for these tables fall between EPA funding years of 1993 and 2009.

                           Table 28. CWISA projects, by IMS Area and EPA Region
Construction not Construction
Aberdeen
Region 7
Region 8
Alaska (RIO)
Albuquerque
Region 6
Region 8
Bemidji (R5)
Billings (R8)
California (R9)
Nashville
Region 1
Region 2
Region 4
Region 6
Navajo (R9)
Oklahoma
Region 6
Region 7
Phoenix
Region 8
Region 9
Portland (RIO)
Tucson (R9)
Total -CWISA
7
0
7
47
11
9
2
16
13
22
12
1
4
6
1
89
10
7
3
25
0
25
4
13
269 (58.9%)
14
2
12
21
7
7
0
7
3
4
17
4
0
9
4
78
3
3
0
16
1
15
10
8
188 (41.1%)
21
2
19
68
18
16
2
23
16
26
29
5
4
15
5
167
13
10
3
41
1
40
14
21
457
Paperwork Complete
0
0
0
7
1
1
n/a
1
0
1
6
0
n/a
6
0
10
2
2
n/a
12
1
11
8
0
48 (25.5% of projects
complete)
Evaluation Report-March 2011
Appendix E - Page 33

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
         Table 29. Construction Duration (MOA signed to Construction Complete) for CWISA projects,
                                   by IMS Area and EPA Region (days)
Area/Region Average Median Minimum Maximum # of Projects
Aberdeen
Region 7
Region 8
Alaska (RIO)
Albuquerque
Region 6
Region 8
Bemidji (R5)
Billings (R8)
California (R9)
Nashville
Region 1
Region 2
Region 4
Region 6
Navajo (R9)
Oklahoma
Region 6
Region 7
Phoenix
Region 8
Region 9
Portland (RIO)
Tucson (R9)
All
1,371
1,890
1,285
1,326
1,341
1,341
n/a
892
972
745
615
488
n/a
564
857
1,110
753
753
n/a
1,436
2,688
1,352
1,616
1,720
1,174 (3.22 years)
1,326
1,890
1,326
1,315
1,376
1,376
n/a
853
761
393
505
372
n/a
666
791
948
940
940
n/a
1,330
2,688
1,299
1,333
1,824
1,045 (2.86 years)
449
1,141
449
127
324
324
n/a
300
492
26
5
202
n/a
5
432
149
217
217
n/a
461
2,688
461
471
1,124
5 (0.01 years)
2,638
2,638
2,047
2,768
2,392
2,392
n/a
2,086
1,664
2,168
1,415
1,007
n/a
1,213
1,415
2,683
1,101
1,101
n/a
2,774
2,688
2,774
3,990
2,414
3,990 (10.93 years)
14
2
12
21
7
7
0
7
3
4
17
4
0
9
4
78
3
3
0
16
1
15
10
8
188
Evaluation Report-March 2011
Appendix E - Page 34

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
     Table 30. Duration Final Report (Construction Complete to Final Report Complete) for CWISA projects,
                                   by IMS Area and EPA Region (days)
        Area/Region      Average
Median
Maximum      # of Projects
Aberdeen
Region 7
Region 8
Alaska (RIO)
Albuquerque
Region 6
Region 8
Bemidji (R5)
Billings (R8)
California (R9)
Nashville
Region 1
Region 2
Region 4
Region 6
Navajo (R9)
Oklahoma
Region 6
Region 7
Phoenix
Region 8
Region 9
Portland (RIO)
Tucson (R9)
All
n/a
n/a
n/a
686
412
412
n/a
2,186
n/a
984
490
n/a
n/a
490
n/a
587
483
483
n/a
807
21
878
1,214
n/a
782 (2.14 years)
n/a
n/a
n/a
602
412
412
n/a
2,186
n/a
984
337
n/a
n/a
337
n/a
467
483
483
n/a
665
21
715
711
n/a
609 (1.69 years)
n/a
n/a
n/a
293
412
412
n/a
2,186
n/a
984
121
n/a
n/a
121
n/a
105
313
313
n/a
21
21
238
292
n/a
21 (0.06 years)
n/a
n/a
n/a
1,489
412
412
n/a
2,186
n/a
984
1,368
n/a
n/a
1,368
n/a
1,261
652
652
n/a
2,310
21
2,310
3,403
n/a
3,403 (9.32 years)
0
0
0
7
1
1
n/a
1
0
1
6
0
n/a
6
0
10
2
2
n/a
12
1
11
8
0
48
Evaluation Report-March 2011
                                              Appendix E - Page 35

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
ARRA Implementation
Table 31. Number of CWISA Projects and Funding of
             ARRA projects, by Region
   Table 32. Number of DWIG-TSA Projects and
      Funding of ARRA projects, by Region*
Region Funding # of Projects
1
2
4
5
6
7
8
9
10
Total
$346,670
$1,343,330
$1,700,000
$1,590,010
$4,430,760
$7,160
$6,417,660
$22,300,460
$21,863,950
$60,000,000
1
1
3
6
8
1
7
46
23
96
Region Funding # of projects
1
2
4
5
6
7
8
9
10
Total
$668,800
$698,000
$1,100,000
$1,291,800*
$2,865,600
$765,700
$3,139,600
$8,448,500
$10,620,900
$29,598,900*
6
2
3
5*
7
5
6
13
16
63*
*Note: during the course of the evaluation, one additional DWIG-TSA project in Region 5 was allocated funding. This project was funded in the
amount of $401,100, which brought the total number of ARRA DWIG-TSA projects to 64, and total ARRA DWIG-TSA funding allocated to
$30,000,000. This project is included in the summary information in the report narrative, but was not included in analyses for this evaluation.
Table 33. Average Funding of CWISA Projects (ARRA
          versus non-ARRA (2003-2009))
 Table 34. Average Funding of DWIG-TSA Projects
      (ARRA versus non-ARRA (2003-2009))
Region Non-ARRA ARRA
1
2
4
5
6
7
8
9
10
All
$312,171
$165,000
$101,950
$82,332
$271,268
$179,051
$252,072
$202,284
$534,807
$258,530
$346,670
$1,343,330
$566,667
$265,002
$553,845
$7,160
$916,809
$484,793
$950,607
$625,000
Region Non-ARRA ARRA
1
2
4
5
6
7
8
9
10
All
$148,273
$435,820
$433,314
$229,360
$251,639
$113,853
$255,850
$426,793
$480,261
$354,942
$111,467
$349,000
$366,667
$258,360
$409,371
$153,140
$523,267
$649,885
$663,806
$469,824
  Table 35. Average IDL of CWISA Projects, ARRA
    versus non-ARRA projects, by Region (PDS)
Table 36. Average IDL of DWIG-TSA Projects, ARRA
    versus non-ARRA projects, by Region (PDS)
Region Non-ARRA ARRA Overall
1
2
4
5
6
7
8
9
10
All
2.60
3.00
2.75
1.86
2.96
4.00
3.00
3.63
3.28
3.35
3.00
3.00
3.33
4.00
3.88
2.00
3.00
3.74
3.30
3.56
2.67
3.00
2.87
2.50
3.19
3.60
3.00
3.65
3.29
3.39
Region Non-ARRA ARRA Overall
1
2
4
5
6
7
8
9
10
All
2.33
3.00
3.00
2.67
3.00
2.63
1.92
2.65
2.72
2.65
2.33
2.00
3.33
3.00
2.86
2.80
3.17
3.85
2.18
2.93
2.33
2.67
3.11
2.74
2.95
2.67
2.32
2.84
2.64
2.71
Note: For non-ARRA projects, Table 34 and Table 35 only include projects that could be linked to PDS information in STARS (85% of unique
CWISA projects funded between 2003 and 2009, or 343 out of 402 and 79% of unique DWIG-TSA projects funded between 2003 and 2009, or
204 out of 257).
Evaluation Report-March 2011
                                Appendix E - Page 36

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    EVALUATION OF THE DRINKING WATER AND CLEAN WATER INFRASTRUCTURE TRIBAL SET-ASIDE GRANT PROGRAMS
                               Table 37. Homes Served by ARRA Projects (PDS)
Region CWISA DWIG-TSA Overall
1
2
4
5
6
7
8
9
10
All
50
228
1,170
59
500
125
1,583
6,178
2,159
12,052
2,051
1,311
2,163
387
1,480
858
2,916
5,604
5,588
22,358
2,101
1,539
3,333
446
1,980
983
4,499
11,782
7,747
34,410
Note: The "homes served" value likely double counts some homes as some tribes received multiple grants from one or both programs.
Evaluation Report-March 2011
Appendix E - Page 37

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              OF THE               AND
APPENDIX F.   INFORMATION SOURCES
General information on the DWIG-TSA and CWISA Programs

    DWIG-TSA Program Overview. Available: http://water.epa.gov/grants funding/dwsrf/allotments/tribes.cfm

    CWISA Program Overview. Available: http://water.epa.gov/type/watersheds/wastewater/Clean-Water-
    Indian-Set-Aside-Grant-Program.cfm

EPA Headquarters Documents

Drinking Water

    Bergman, Ron.  Memorandum to Regional Drinking Water Branch Chiefs Regions I, II, IV-X: Drinking Water
        Infrastructure Grants-Tribal Set Aside (DWIG-TSA) Program  Guidance for projects funded using  the
        American Recovery and Reinvestment Act of 2009.

    Corr, Elizabeth. Memorandum to Regional Ground Water and Drinking Water Branch Chiefs Regions I, II and IV
        - X: Final Allotments for the FY 2004 Drinking Water Infrastructure Grants Tribal Set-Aside Program (DWIG-
        TSA). March 2004.

    Dougherty, Cynthia. Letter to Tribal Leaders on Drinking Water Infrastructure Needs Survey. September 2010.

    Fellows, Elizabeth. "Drinking Water State Revolving Fund (DWSRF) Program Policy Announcement: Eligibility of
        Using DWSRF Funds to Create  a New Public Water System." Federal Register. Volume 63, No. 212.
        November 1998.

    Heare, Steve. Memorandum to Regional Drinking Water Program Managers Regions I, II, IV-X: Availability of
        FY2007 DWSRF Tribal Program Funds.  May 2007.

    Enyeart, Ray. Memorandum to Drinking  Water  Tribal Set-Aside Program Coordinators Regions I,  II, IV-X:
        Drinking Water Infrastructure Grants Tribal Set-Aside Program — Guidelines on Using Funds to Create New
        Public Water Systems. December, 1998.

    Enyeart, Ray. Memorandum to Drinking  Water  Tribal Set-Aside Program Coordinators Regions I,  II, IV-X:
        Financial Information for the Drinking Water Infrastructure Grants Tribal Set-Aside Program - FY97 & FY98
        Carryover and FY99 NOA - DRAFT. December, 1998.

    US   EPA   Office   of   Water.   Drinking   Water   Infrastructure   Needs  Surveys.      Available:
        http://water.epa.gov/infrastructure/drinkingwater/dwns/index.cfm

    US EPA Office of Water. Drinking Water Infrastructure Grants Tribal Set-Aside Program Final Guidelines.
        October 1998. Available:
        http://www.epa.gov/ogwdw/dwsrf/allotments/tribes/pdf/guidelines  dwsrf tribal.pdf

Clean Water

    Allbee, Stephen P. Memorandum to Regional Construction Grants Program Managers Regions I-X: Notice of
        Change - Indian Set-Aside Program National Project Priority List. March 1995.
Evaluation Report - March 2011                                                           Appendix F - Page 38

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               OF THE                AND

    Frace, Sheila. Memorandum to Clean Water Indian Set-Aside Program Coordinators: Clean Water Indian Set-
        Aside (CWISA) Program Guidance for projects funding using the American Recovery and Reinvestment Act
        of 2009. March 2008.

    Frace, Sheila E. Memorandum to Regional Water Division Directors: Clean Water Indian Set-Aside (CWISA)
        Program Guidance for Projects Funded Using the American Recovery and Reinvestment Act of 2009. July
        2009.

    Frace, Sheila E. Memorandum to Water Division Directors Regions I, II, IV-X: Eligibility of Lateral Connections
        Under the Clean Water Indian Set-Aside Grant Program. September 2007.

    Hochberg, Adriana. Memorandum to Regional Clean Water Indian Set-Aside Program Coordinators: Guidance
        for Allocating FY2006 Clean Water Indian Set-Aside (CWISA) Grant Program Funding. March 2006.

    Hochberg, Adriana.  Memorandum to Clean  Water Indian Set-Aside  Program Coordinators: Guidance  for
        Allocating FY 2007 Clean Water Indian Set-Aside (CWISA) Grant Program Funding. April 2007.

    Hogye, Steve. Memorandum to Regional CW Indian Set-Aside  Program Coordinators: Guidance for Allocating
        FY2005 Clean Water Indian Set-Aside (CWISA) Grant Program Funding. January 2005.

    Marrs, Alicia. Memorandum to Clean Water Indian Set-Aside Program Coordinators Regions I, II, IV-X: Guidance
        for Allocating FY2008 Clean Water Indian Set-Aside (CWISA) Grant Program Funding. April 2008.

    Marrs, Alicia. Memorandum to Clean Water Indian Set-Aside Program Coordinators Regions I, II, IV-X: Guidance
        for Allocating FY2009 Clean Water Indian Set-Aside (CWISA) Grant Program Funding. May 2009.

    US EPA.  Clean Water Indian Set-Aside Grant Program: Answers to Frequently Asked Questions. March  2007.
        Available: http://water.epa.gov/type/watersheds/wastewater/upload/CWISA-tribal-faq-highres.pdf

    US EPA Office of Water. Guidelines and Requirements for Applying For Grants From [Clean Water] The Indian
        Set-Aside Program. April 1989. http://water.epa.gov/type/watersheds/wastewater/upload/CWISA-
        guidl989.pdf

    US EPA Office of Water. Notice of Change: [Clean Water] Indian Set-Aside Program Addendum. March 1995.
    Available: http://water.epa.gov/type/watersheds/wastewater/upload/CWISA-addl989.pdf

Other

    US EPA, Tribal Water Infrastructure Meeting via ARRA: Evaluation Response Summary. December 2010.

    US EPA Office of Inspector General.  Costs Claimed by the Alaska Native Tribal Health Consortium Under EPA
        Interagency     Agreement     DW    75-95754001.         September    2010.        Available:
        http://www.epa.gov/oig/reports/2010/20100930-10-4-0241.pdf

    US EPA Office of Water. Tribal Drinking Water and Clean Water Access Measure Modification. January 2010.

    US EPA Office of Water. National Water Program Guidance: Fiscal Year 2010. April 2009. Available:
    http://www.epa.gov/ocfo/npmguidance/2010/fylO guidance.htm

    US EPA Office of Water. National Water Program Guidance: Fiscal Year 2011. April 2010.  Available:
    http://www.epa.gov/ocfo/npmguidance/2011/fyll guidance.htm#OW
Evaluation Report - March 2011                                                               Appendix F - Page 39

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               OF THE                AND

EPA Regions Drinking Water Guidances and Documents

    US EPA Region 1. Priority Ranking System. 2008.

    US EPA Region 4. Drinking Water Infrastructure Grants Tribal Set-Aside (DWIG-TSA) Construction Program:
        Draft Guidance and Prioritization Procedures. September 2001.

    US EPA Region 5. Guidelines for the Allocation of Drinking Water Set-Aside Funds to Tribes.

    US EPA Region 6. Preapplication Conference Agenda. January 2009.

    US EPA Region 6. 2008 Intended Use Plan for Tribal Set-Aside Program Cover Letter. 2008.

    US EPA Region 6. 2008 Intended Use Plan for the EPA Region 6 Drinking Water Tribal Set-Aside Program. 2008.

    US EPA  Region  7. Oversight of Public Water Systems in Indian Country: Standing Operating Procedures for
        Direct Implementation. 2010.

    US EPA Region 7. Drinking Water Infrastructure Grants Tribal Set-Aside (DWIG-TSA) Process.

    US EPA Region 8. Project Solicitation Guidance. 2010.

    US EPA Region 8. Summary of Application and Award Process for Drinking Water Infrastructure Grants (DWIG)
        Tribal Set-Aside (TSA) Funds.

    US EPA Region 8. Drinking Water Infrastructure Grants Tribal Set-Aside Program Guidelines. January 2010.

    US EPA  Region 9. U.S. Environmental Protection Agency, Region 9 Drinking  Water Tribal Set-Aside Program
        2010 Guidance and Procedures for Applying for Assistance. 2010.

    US EPA  Region  10. Final Guidelines: Drinking Water Infrastructure Grants Tribal Set-Aside Program. August
        1999.

Indian Health  Service (IMS)

    Hawasly, Ramsey. "Indian Health Service (IMS) Office of Environmental Health and Engineering (OEH&E)
        Division of Sanitation Facilities Construction  (DSFC)." PowerPoint Presentation.

    Indian Health  Service. FY 2011 Online Performance Appendix.

    Indian Health  Service. Strategic Plan 2006-2011. Available:
        http://www.ihs.gov/planningevaluation/index.cfm?module=dsp  pe strategic planning

    Indian Health  Service Office of Environmental Health and Engineering Division of Sanitation Facilities
        Construction. Five-Year Strategic Plan (2006-2011) 2009 Performance Scorecard. January 2010.

    Indian Health  Service Sanitation Facilities Construction Program. Public Law 86-121 Annual Report for Fiscal
        Years 2002,  2003, 2004, 2005, 2006, 2007. Available:
        http://www.ihs.gov/dsfc/index.cfm?module=documents
Evaluation Report - March 2011                                                               Appendix F - Page 40

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    EVALUATION OF Til	IE                AND             INFRASTRUCTURE TRIBAL SET-ASIDE

    Indian Health Service Division of Sanitation Facilities Construction. Sanitation Deficiency System (SDS): Guide
        for Reporting Sanitation Deficiencies for Indian Homes and Communities. May 2003. Available:
        http://www.ihs.gov/dsfc/documents/SDSWorkingDraft2003.pdf

    Indian Health Service Division of Sanitation Facilities Construction. Sanitation Tracking and Report System
        (STARS) User Manual. September 2008.

Infrastructure Task Force

    Infrastructure Task  Force Access Subgroup. Meeting the Access Goal: Strategies for Increasing Access to Safe
        Drinking Water and Wastewater Treatment to American Indian and Alaska Native Homes.  March 2008.

    Infrastructure Task Force Access Subgroup. Overview of Tribal Infrastructure Funding Application Processes
        and Recommended Streamlining Opportunities. October 2010.

    Federal Infrastructure Task Force on Tribal Access to Safe Drinking Water and Basic Sanitation Tribal Technical
        Assistance Workgroup. Tribal Access  Workgroup Report: Strategies for Improving Technical Assistance
        Delivery in American Indian and Alaska Native Communities. March 2010.

    Office of Environmental Health and Engineering Division of Sanitation Facilities Construction. Criteria for the
        Sanitation Facilities Construction Program. June 1999.

Data Sources

    STARS Data exports and pivot tables.  Provided by IHS to evaluators in June 2010.

    US EPA compiled DWIG-TSA spreadsheets for EPA-funded projects in each EPA region.  Provided to evaluation
        in Spring 2010.

    US EPA compiled CWISA spreadsheet for EPA-funded projects in each EPA region. Provided to evaluation in
        Spring 2010.

    US EPA Safe Drinking Water Information System (SDWIS) data exports.  Provided to evaluation  in Spring and
        Summer 2010.

    US EPA Safe Drinking Water Information System summary information for GPRA reporting.  Provided to
        evaluation in Spring 2010
Evaluation Report - March 2011                                                               Appendix F - Page 41

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