United States Office of Policy March 2011
Environmental (1807T) EPA-100-F-11-020
Protection Agency
Evaluation of the Drinking Water
and Clean Water Infrastructure
Tribal Set-Aside Grant Programs
Fact Sheet
http://www.epa.gov/evaluate
For more information on
completed evaluations at EPA
or the Evaluation Support
Division, visit the above link.
Introduction
The EPA Clean Water Indian Set-Aside (CWISA) Grant Program and the Drinking Water
Infrastructure Grant Tribal Set-Aside (DWIG-TSA) Program provide funding for wastewater
infrastructure and drinking water infrastructure to American Indian tribes and Alaska Native
Villages. EPA coordinates with Indian Health Service (IMS) on these programs, a division
within the U.S. Department of Health and Human Services.
Through this program evaluation, EPA sought to determine the extent to which the
combined efforts of the EPA DWIG-TSA program and the EPA CWISA program have resulted
in increased access to safe drinking water and sanitation facilities and in increased
compliance with the Safe Drinking Water Act (SDWA) in Indian country. EPA also sought to
better understand and explain how these programs are implemented and the factors
influencing program performance. In addition, because IHS often oversees and directly
implements the infrastructure projects, EPA hoped to gain a deeper understanding of its own
scope of influence and if and how EPA could better demonstrate program results.
The following information describes the questions that structured the evaluation, the overall
evaluation approach, and the evaluation's key findings and recommendations.
Overarching Evaluation Questions
The following questions formed the structure of the evaluation:
1. How does EPA implement the DWIG-TSA and CWISA programs at headquarters and
in the regions?
2. To what extent are the DWIG-TSA and CWISA programs achieving their stated
goals?
3. What factors influence whether the programs achieve their stated goals?
4. Are the current DWIG-TSA and CWISA program performance measures accurate
indicators of EPA's progress?
5. What implementation improvements or innovations could be made by EPA to make
the DWIG-TSA and CWISA programs more effective in meeting the water and
wastewater infrastructure needs of tribes?
Evaluation Approach
To answer these overarching evaluation questions, evaluators collected and reviewed
documents related to the programs; conducted interviews with 39 individuals, including EPA
headquarters staff, EPA regional staff, IHS staff, and tribal government staff; and analyzed
data on over 650 DWIG-TSA and CWISA projects that EPA contributed funding to between
calendar years 2003 and 2009.
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EPA tracks progress made by the DWIG-TSA and CWISA programs toward the EPA Strategic Plan Goal
2—Protecting America's waters—according to performance on three Strategic Plan measures.
• Compliance Strategic Measure: By 2015, 88 percent of the population in Indian country served
by community water systems will receive drinking water that meets all applicable health-based
drinking water standards.
• Drinking Water Access Strategic Measure: By 2015, in coordination with other federal agencies,
provide access to safe drinking water for 136,100 American Indian and Alaska Native homes.
• Sanitation Access Strategic Measure: By 2015, in coordination with other federal agencies,
provide access to basic sanitation for 67,900 American Indian and Alaska Native homes.
Conclusions
• Program Goals and Priorities: The specific program goals and priorities for these programs could
be clearer and more focused. EPA has the opportunity to more clearly articulate and focus the goals
of both programs, and then to focus program design and implementation accordingly in a set of
"cascading" decisions and actions that would follow clearer goals and priorities.
• Funding Allocation: The method used to allocate funds for each program has an understandable
basis and history; however, neither allocation process is an ideal match for the current program
priorities and strategic measures.
• Project Selection: For both programs, project selection could be more clearly and consistently tied
to EPA's priorities, while still maintaining regional discretion and flexibility.
• Communication: Despite improvement in recent years, communication within EPA and between
EPA and IMS is inconsistent and not optimal for strategic program management or learning and
improvement. There are also opportunities for improved communication with tribes about these
programs.
• Access Strategic Measures: EPA has limited ability to make progress on the current strategic
measures focused on providing access to drinking water and clean water to tribal homes due to a
number of factors, such as reliance on other federal agencies and lower than needed funding levels.
• Compliance Strategic Measure: EPA appears to be quite limited in its ability to make to make
progress toward the current compliance strategic measure, though the extent of the limitations is not
clear due to a lack of measurable data. The drivers of some compliance problems may be related to
operations and maintenance (O&M) at tribal systems or the introduction of new drinking water rules,
rather than to infrastructure problems that the DWIG-TSA program can address.
• Program Results: EPA's meaningful contributions to meeting tribal infrastructure needs are not well
reflected by the reported program performance. Despite the identified challenges surrounding
making progress toward the current strategic measures, both programs have made significant
contributions over the years to Indian country through these programs by providing funding for vital
water infrastructure needs.
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Recommendations
Based on the above findings, the evaluators recommended the following to the EPA headquarters staff
with oversight responsibility for these infrastructure grant programs.
1. Clarify the goals and priorities of both infrastructure grant programs.
2. Consider changing the access strategic measures to ones that more directly reflect EPA's
mandate, authority, and scope of influence, considering available data and any changes to the
programmatic goals.
3. Consider changing the compliance strategic measure to one that more directly reflects the drivers
of compliance problems and EPA's scope of influence over these problems.
4. Reassess the national annual budget allocation for both programs to be more clearly tied to EPA's
goals and priorities.
5. For both programs, update and clarify expectations for project selection to be more clearly in line
with the program priorities; allow for regional flexibility and discretion; and promote increased
consistency and transparency.
6. For both programs, routinely collect and analyze data to enhance transparency and strategic
coordination and improve EPA's ability to report on, advocate, and improve both programs.
7. Update the national guidelines for both programs to reflect any changes made as a result of the
above recommendations and to reflect implementation changes since the inception of the
programs.
8. Continue to enhance and improve communication within EPA, between EPA and IMS, and
between EPA and the tribes.
The evaluators also offered three additional considerations which reflect support for previous work and
efforts underway related to some of the same issues the evaluation covered.
1. Continue to focus on the critical issues surrounding infrastructure sustainability, including tribal
O&M capacity issues;
2. Continue to communicate about interagency agreement requirements, expectations, and inter-
agency roles between EPA and IMS; and
3. Reflect on other reports and recommendations that pertain to these programs prepared by other
workgroups.
• Kyle Carey, Office of Water, Office of Ground Water and Drinking Water carey.kyle@epa.gov
• Matthew Richardson, Office of Water, Office of Wastewater Management,
richardson.matthew@epa.QOv
• Michelle Mandolia, Office of Policy, Evaluation Support Division, mandolia.michelle@epa.gov
" "•;••"" http://www.epa.QOv/evaluate/reports
:' ,, March 2011
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