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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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) Evaluation Report - March 2011 Appendix B - Page 6 ------- 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 ------- 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 ------- 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 ------- 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 Evaluation Report - March 2011 Appendix B - Page 10 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 Appendix E - Page 21 ------- 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 Appendix E - Page 22 ------- 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 ------- 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 ------- 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 Appendix E - Page 25 ------- 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 Appendix E - Page 26 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 Appendix E - Page 31 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- |