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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
Protecting America's Waters
EPA Needs to Demonstrate
Public Health Benefits of
Drinking Water State
Revolving Fund Projects
Report No. 15-P-0032
December 5, 2014

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Report Contributors:
Dan Engelberg
Khadija Walker
Charles Brunton
Tiffine Johnson-Davis
Gerry Snyder
Abbreviations
DWSRF	Drinking Water State Revolving Fund
EPA	U.S. Environmental Protection Agency
GPRA	Government Performance and Results Act of 1993
OIG	Office of Inspector General
PBR	Project and Benefits Reporting
PWSS	Public Water System Supervision
SDWA	Safe Drinking Water Act
SDWIS	Safe Drinking Water Information System
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More information at www.epa.gov/oiq/hotline.html.
EPA Office of Inspector General
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Washington, DC 20460
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U.S. Environmental Protection Agency	15-P-0032
December 5, 2014
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At a Glance
Why We Did This Review
We conducted this review to
determine how the U.S.
Environmental Protection
Agency (EPA) and states
demonstrate that completed
Drinking Water State Revolving
Fund (DWSRF) projects met
project and program goals and
contributed to improved
drinking water quality and
public health.
The 1996 Safe Drinking Water
Act Amendments, in part,
authorize the EPA to provide
funding for capitalization grants
to states to further public health
objectives and promote efficient
use of funds. The states use
these funds to support low
interest loans and other types
of assistance to public water
systems. The EPA conducts
annual reviews encompassing
certain aspects of the states'
programs.
This report addresses the
following EPA goals or
cross-agency strategies:
•	Protecting America's
waters.
•	Protecting human health
and the environment by
enforcing laws and
assuring compliance.
Send all inquiries to our public
affairs office at (202) 566-2391
or visit www.epa.gov/oiq.
The full report is at:
www.epa.qov/oiq/reports/2014/
20141205-15-P-0032.pdf
EPA Needs to Demonstrate Public Health Benefits
of Drinking Water State Revolving Fund Projects
The EPA needs to enforce
grant requirements for
collecting DWSRF project
information to demonstrate
the public health results of the
$11.37 billion it has invested
in drinking water
infrastructure since 2009.
What We Found
The EPA does not obtain all required DWSRF
project data from states, despite capitalization
grants that require states to input key project
information into EPA databases. The EPA
also does not always use annual reviews of
state DWSRF programs to assess project
outcomes. Without this information the EPA
cannot determine whether completed DWSRF
projects contributed to improved drinking
water quality and public health. In addition, the GPRA Modernization Act of 2010
(GPRA refers to the Government Performance and Results Act of 1993) requires
all federal agencies to have long-term goals that are supported by interim
performance indicators. The EPA requires states to systematically provide
information that can be used to assess project results. However, not all states
report complete, required information in every instance. Our analysis shows that
systems that received DWSRF funding regain compliance, indicating public
health improvements. However, incomplete reporting affects the overall value of
our analysis of the DWSRF program. These incomplete data hamper the EPA's
ability to evaluate program effectiveness and public health outcomes.
As a result, the EPA is unable to demonstrate the public health results of its large
DWSRF agency expenditure, which represents about 10 percent of the agency's
annual budget. Further, the EPA cannot demonstrate the overall success of
DWSRF projects. The EPA is also missing an opportunity to capture potential
best practices of state programs and projects.
Recommendations and Agency Corrective Actions
We recommend that the Assistant Administrator for Water enforce grant
requirements that states input all necessary data in the project-level tracking
database and review data completeness as part of the EPA's annual review of
state performance. We also recommend that the EPA enhance coordination
between DWSRF and Public Water System Supervision programs and
periodically evaluate program results.
The agency agreed with our recommendations and provided corrective actions
with milestone dates. The recommendations are resolved with corrective actions
pending.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
December 5, 2014
MEMORANDUM
SUBJECT: EPA Needs to Demonstrate Public Health Benefits of
Drinking Water State Revolving Fund Projects
Report No. 15-P-0032

FROM: Arthur A. Elkins Jr.
TO:
Ken Kopocis, Deputy Assistant Administrator
Office of Water
This is our report on the subject evaluation conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the problems
the OIG has identified and corrective actions the OIG recommends. This report represents the opinion of
the OIG and does not necessarily represent the final EPA position. Final determinations on matters in
this report will be made by EPA managers in accordance with established audit resolution procedures.
The office responsible for implementing the recommendations included in this report is the Office of
Water's Office of Ground Water and Drinking Water, Drinking Water Protection Division.
Action Required
The report recommendations are resolved with corrective actions pending. Therefore, the agency is not
required to provide a final response to this report. However, if you choose to provide a final response,
we will post your response on the OIG's public website, along with our memorandum commenting on
your response. You should provide your response as an Adobe PDF file that complies with the
accessibility requirements of Section 508 of the Rehabilitation Act of 1973, as amended.
We will post this report to our website at http://www.epa.gov/oig.

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EPA Needs to Demonstrate Public Health Benefits
of Drinking Water State Revolving Fund Projects
15-P-0032
Table of C
Purpose		1
Background		1
Responsible Office		3
Scope and Methodology		3
Results of Review		4
EPA Oversight of States Does Not Include Reviews
of Long-Term Public Health Outcomes
and Interim Indicators for DWSRF Projects		4
EPA and States Identified Ways to
Demonstrate Public Health Benefits		5
Analysis Shows Systems Regained Compliance
Which Indicates Public Health Improvements,
But EPA Needs to Enhance Data Quality, Collection and Integration		6
Conclusion		8
Recommendations		8
Agency Comments and OIG Evaluation		9
Status of Recommendations and Potential Monetary Benefits		10
Appendices
A Agency Response	 11
B Distribution	 14

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Purpose
We conducted this review to determine how the U.S. Environmental Protection
Agency (EPA) and states demonstrate that completed Drinking Water State
Revolving Fund (DWSRF) projects met project and program goals and
contributed to improved drinking water and public health.
Background
The 1996 Safe Drinking Water Act (SDWA) Amendments, in part, authorize the
EPA to provide funding for capitalization grants to states. SDWA subsection 1452
(b)(3)(A)(i-iii) establishes priorities for the use of funds. The states use these
funds to support low interest loans and other types of assistance to public water
systems (e.g., construction of new or improvements to existing water treatment
plants and other infrastructure). The SDWA requires the states, to the extent
practicable, to prioritize their projects that: (1) address the most serious risk to
human health, (2) are necessary to ensure compliance with the requirements of the
SDWA, and (3) assist systems most in need according to state affordability
criteria. The EPA conducts annual reviews encompassing certain aspects of the
states' programs. According to the DWSRF Operations Manual, regions annually
review and approve state Intended Use Plans/Project Priority Lists and evaluate
state DWSRF program activity over the previous year. Specifically, the regions
are required to evaluate the DWSRF programs' finances and operations, and
check their compliance with relevant statutes, regulations and grant conditions.
The regions also assess the states' progress and performance in achieving the
goals and objectives identified in the states' Intended Use Plans and reported
through the state's annual reports.
The EPA DWSRF capitalization grant agreements direct states to inform the EPA
about project-level data on a quarterly basis. The EPA grant conditions require
that each state DWSRF program provide public health protection results and
progress in achieving program outputs and outcomes. Further, the GPRA
Modernization Act of 2010 (GPRA refers to the 1993 Government Performance
and Results Act) requires all federal agencies to have long-term goals that are
supported by interim performance indicators. The EPA assesses drinking water
quality through two national measures: (1) percent of the population served by
community water systems that receive drinking water that meets all applicable
health-based drinking water standards through approaches including effective
treatment and source water protection, and, (2) percent of community water
systems that meet all applicable health-based standards through approaches that
include effective treatment and source water protection. According to the Office
of Water, the EPA DWSRF program supports these national goals by
demonstrating through Public Water System Supervision (PWSS) compliance
monitoring that these systems are achieving drinking water standards captured by
the EPA's Safe Drinking Water Information System (SDWIS).
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The DWSRF program has comprised roughly 10 percent of the EPA's overall
budget appropriation in recent years. According to the agency, the EPA started
requiring states to report project-level information into a Project and Benefits
Reporting (PBR) system in 2009. The EPA aggregates this information into the
National Information Management System for reporting purposes. According to
the DWSRF Operations Manual, state DWSRF programs must conduct final
inspections to ensure that funded projects were used for eligible purposes and
completed in accordance with original plan specifications. These programs
manage project-level information through the PBR based on EPA grant reporting
requirements.
The PBR and National Information Management System databases identify four
types of projects:
•	Compliant systems receiving funds to maintain compliance.
•	Noncompliant systems receiving funds to return to compliance.
•	Compliant systems receiving funds for issues unrelated to compliance.
•	Compliant systems receiving funds to meet future requirements.
From 2009 through 2013, 4,706 systems received $11.37 billion in funding from
state revolving funds. Using the EPA's four-part categorization scheme, this
encompassed:
•	2,544 compliant systems receiving $5.76 billion (51 percent of the total)
to maintain compliance.
•	1,173 noncompliant systems receiving $3.88 billion (34 percent of the
total) to achieve compliance (higher risk).
•	856 compliant systems receiving $1.26 billion (11 percent of the total)
for issues unrelated to noncompliance.
•	133 compliant systems receiving $468 million (4 percent of the total) to
assist in obtaining future compliance.
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Chart 1: $11.37 billion spent on DWSRF projects 1
$1.26 B (11%) $468 M (4%)
$3.88 B (34%)
$5.76 B (51%)
H Maintain compliance H Achieve compliance
U Unrelated to compliance H Future compliance
Source: The EPA's PBR System.
Responsible Office
The EPA's Office of Groundwater and Drinking Water (OGWDW) is responsible
for implementing the SDWA. This office's Drinking Water Protection Division
oversees the implementation of the act by developing and helping implement
national drinking water standards, overseeing and assisting funding of state
drinking water programs and source water protection programs, helping small
drinking water systems, protecting underground sources of drinking water, and
providing information about drinking water quality to the public. The effort to
improve public health protection for persons served by small drinking water
systems (which account for more than 97 percent of public water systems in the
United States) by strengthening the technical, managerial and financial capacity
of those systems is an Agency Priority Goal for OGWDW.
We conducted this performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a reasonable basis
for our findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives. We conducted our audit from
November 2013 through August 2014.
To answer our objective, we identified relevant laws and guidance used by the
DWSRF program. We interviewed and surveyed EPA headquarters and regional
staff, and analyzed national data on DWSRF projects and compliance. We also
selected a sample of DWSRF projects to assess compliance data after the projects
were completed and interviewed selected state DWSRF staff in Region 3
1 The portion of projects selected for our sample came from water systems that received 'Assistance to Achieve
Compliance.' This portion is in red in the chart.
Scope and Methodology
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(Pennsylvania), Region 5 (Illinois) and Region 8 (Colorado and Wyoming) about
specific projects in our sample.
Results of Review
The EPA does not obtain all required DWSRF project data from states. The EPA
also does not always use annual reviews of state DWSRF programs to assess
project outcomes. Without this information the EPA cannot determine whether
completed DWSRF projects contributed to improved drinking water quality and
public health.
The SDWA gives the EPA the authority to make capitalization grants to state
programs to further public health objectives and promote efficient use of funds.
To support these objectives, the EPA capitalization grants require states to input
key project information into the PBR and the National Information Management
System databases. In addition, the GPRA Modernization Act of 2010 requires all
federal agencies to have long-term goals that are supported by interim
performance indicators. The EPA requires states to systematically provide
information that can be used to assess project results. However, not all states
report complete, required information in every instance. Our analysis shows that
after systems received DWSRF funding, they regained compliance which
indicates public health improvements, however, incomplete reporting affects
value of the analysis for the DWSRF program. These incomplete data hamper the
EPA's ability to evaluate program effectiveness and public health outcomes.
As a result, the EPA is unable to demonstrate the public health results of this large
agency expenditure. Further, the EPA cannot, in some cases, illustrate the overall
success or challenges of specific DWSRF projects. The EPA is also missing an
opportunity to capture and disseminate potential best practices of state programs
and projects.
EPA Oversight of States Does Not Include Reviews of Long-Term
Public Health Outcomes and Interim Indicators for DWSRF Projects
The EPA does not measure the results obtained from the projects funded by the
DWSRF. The EPA does not use interim indicators, such as successful project
completion nor long term outcome measures such as compliance information
tracked in SDWIS. As a result, the DWSRF program is unable to demonstrate the
public health results of these projects and in some cases, illustrate the overall
success of the DWSRF program.
There is an opportunity to discuss and capture project outcomes during annual
state/regional DWSRF program reviews and also at project completion. However,
the EPA does not always take advantage of these opportunities. The DWSRF
Program Operations Manual requires that each state DWSRF program submit an
annual report to its EPA regional office detailing the state's performance and its
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compliance with DWSRF regulations including capitalization grant requirements.
The EPA grant conditions require that each state DWSRF program demonstrate
progress in achieving outputs and outcomes. However, we found that EPA
DWSRF regional staff do not always focus on project outcomes during annual
reviews. Staff from one of the EPA regions shared that, during the annual review,
there is limited consideration of public health benefits. These EPA regional staff
explained that this may be due to the fact that health benefits are strongly
considered up front. The EPA's annual review checklist directs regional staff to
focus on grant and programmatic compliance issues along with financial and
managerial compliance. According to headquarters staff, project outcomes may be
discussed during the annual review, if appropriate. However this is not routine.
The EPA and states holding discussions about the public health benefits of
projects during the annual review would be an important first step in measuring
long term outcomes for the program. These discussions would enhance the EPA
regions and states' ability to meet the requirements contained in the Operations
Manual and grant conditions.
In addition to annual reviews, the EPA requires that state DWSRF programs
conduct final inspections at project completion to determine whether funded
projects were used for eligible purposes and completed in accordance with
original plan specifications. However, the EPA does not have a corresponding
requirement that the states enter the results of these inspections (or similar project
completion information) into the PBR. This is a missed opportunity to capture
individual project results for future analysis and program improvement. This
information source could serve as a positive interim indicator for overall program
success.
Further, according to the Office of Water, descriptions of DWSRF-financed
projects could be more specific to include the compliance objective(s) to be
addressed by the funding. This improvement in reporting would establish a clear
connection between the funds and the public health outcomes that could be tested
by examining the compliance monitoring results after the completion of the
project's construction.
EPA and States Identified Ways to Demonstrate Public Health
Benefits
We asked EPA headquarters and regional DWSRF staff to identify ways in which
information might be collected to track whether projects contributed to improved
drinking water quality and public health. Headquarters DWSRF staff suggested
that we compare project level information in the PBR to compliance data in the
Safe Drinking Water Information System (SDWIS). Nine of the 10 regions we
surveyed suggested ways that data could be analyzed to track whether projects
contributed to improved public health and water quality using data already
available in the SDWIS and the PBR. Specifically,
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•	Four regions proposed combining information from the SDWIS and the
PBR.
•	Three regions proposed using the SDWIS database.
o Two of these regions proposed assessing whether there are changes
in water system compliance status,
o One region proposed having the ability to generate summaries of
DWSRF funding by water system.
•	One region proposed that the PBR could be more user-friendly allowing
for more data querying and reporting.
•	One region proposed that tracking public health benefits of DWSRF
projects should be discussed with key representatives who would be
potentially impacted.
Staff from one state supported the idea of having a way to collect the
environmental benefits of DWSRF projects. They further commented that
involvement from their public water system departments would also be necessary,
as those departments have more information.
Analysis Shows Systems Regained Compliance Which Indicates
Public Health Improvements, But EPA Needs to Enhance Data
Quality, Collection and Integration
We sampled the EPA data and public drinking water system information for the
"Assist Non-Compliant Systems to Achieve Compliance" category for before and
after project completion from 2009 through 2013. We chose this category because
we expected that there would be a noticeable difference in system compliance
before and after the DWSRF projects ended. Our results indicated that a large
majority of projects and overall expenditures appear to have achieved positive
results as measured by returning to compliance. However, these are not concrete
conclusions because missing data in our sample, such as compliance period begin
and end dates, may affect actual results. Given the limitations, we found:
•	347 of 370 systems (93.8 percent) had no reported violations after the
project completion.
•	23 of 370 systems (6.2 percent) had reported violations after project
completion.
o 18 of those 23 systems had only reporting or monitoring violations
where the system failed to file a monitoring report for a regulated
contaminant (4.9 percent),
o Five of those 23 systems had contaminant-related violations after
project completion (1.4 percent).
These results show positive indications that the DWSRF project investments are
beneficial, as the majority are achieving and maintaining compliance. Despite
these positive indications, the EPA's incomplete data hampers tracking of public
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health outcomes. The following analysis showed several limitations that prevent a
full evaluation of results, including:
•	Required data fields in the PBR were incomplete. For example, out of our
sample of 370 projects in the category of 'assisting non-compliant systems
to achieve compliance', 172 (46 percent) were missing one or more data
elements. Specifically, 29 projects did not have project start dates listed,
and 36 projects were missing or did not have complete Public Water
System identification numbers (unique identification numbers used for all
public water systems).
•	Compliance dates were missing in the SDWIS database. Records for
77 projects indicated noncompliance without a beginning date, and
169 projects indicated noncompliance, but did not have a date for
returning to compliance. Of the 23 projects that had violations
post-DWSRF funding, 14 had violations with no indication that they had
returned to compliance (some violations may be ongoing and not yet
reported).2
These data quality limitations show that states are not always compliant with EPA
grant requirements. The EPA requires, per the capitalization grant agreements,
that states enter project level data about proposed public health benefits, project
begin and end dates, and system identification into the PBR. Our data review
shows that states are not inputting all of this information. These data limitations
prevented us from comprehensively evaluating DWSRF projects and hamper the
EPA's ability to evaluate overall DWSRF program effectiveness. As a result, the
EPA is impeded in its ability to determine the extent to which expected results are
achieved.
Additionally, we found that the EPA PWSS and DWSRF programs have not
coordinated their respective databases to link compliance monitoring data to
DWSRF project investment data. The EPA DWSRF headquarters program staff
expressed that they would like to retrospectively review DWSRF projects, but due
to oversight and management responsibilities, have not been able to do so. An
Office of Water official stated that their office has compared DWSRF and PWSS
data on a case-specific basis in the past, but could do this routinely if DWSRF and
PWSS program datasets were linked.
By linking information in these systems, the agency then could assess compliance
monitoring results after the completion of the project's construction. Drawing the
link between specific DWSRF investments in public water systems and their
impact on particular communities is needed. The public needs to know how this
large agency investment benefited the drinking water supply.
2 The systems with missing data are counted in more than one missing value category.
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According to Office of Water staff, the EPA is currently planning to consolidate
DWSRF tracking systems to allow project level data to be aggregated to provide
state and national financial reports. The EPA, while consolidating data systems,
could use this as an opportunity to improve data collection and require certain
data fields to incorporate tracking project public health results. The EPA would be
able to determine the completed DWSRF projects that could potentially
demonstrate public health outcomes.
Conclusion
After DWSRF projects are completed, nearly all water systems appear to be in
compliance with health-based drinking water standards. While this is
encouraging, currently the agency is unable to determine that completed DWSRF
projects contribute to improved public health because of incomplete data and lack
of data integration in the PBR and SDWIS databases.
The complexities of drinking water infrastructure improvements make it difficult
for the EPA to confidently attribute completed DWSRF projects to improvement
in public health. However, the EPA could track interim indicators, long-term
public health impacts, and improve data quality, collection and integration for
selected types of DWSRF-funded projects. The public needs to be informed of the
extent to which this large agency investment benefits the drinking water supply.
The fact that the EPA is currently upgrading the SDWIS database and proposing
to consolidate DWSRF tracking systems provides the agency a cost-effective
opportunity to modify data systems to allow it to assess the feasibility of tracking
project results. The EPA should take advantage of this opportunity to provide
further assurance that state programs are meeting SDWA requirements. By doing
so, the EPA could support states in identifying how DWSRF investments
contributed to improved public health.
Recommendations
We recommend that the Assistant Administrator for Water:
1.	Enforce the grant requirement for states to input all necessary data in the
PBR database (e.g., project completion, project results, project start/end
dates, compliance period begin/end dates, and public water system
identification numbers).
2.	Review state-level data entry to ensure data completeness in the PBR
database as part of the EPA's annual review of state performance.
3.	Implement the most cost-effective method to capture public health
benefits by using information gathered in state annual reviews and
enhancing coordination with compliance monitoring programs at the
federal and state levels.
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4. Periodically evaluate program results to ensure that program goals are
being achieved at water systems receiving DWSRF financial assistance,
and record successes, best practices and challenges to be shared among
EPA regions and the states to focus and enhance program performance.
Agency Comments and OIG Evaluation
The Office of Water agreed with all recommendations and provided projected
completion dates. Therefore, the recommendations are resolved with
corrective actions pending. We also received technical comments from the
Office of Water, which are incorporated into the report as appropriate. In its
response, the Office of Water said that the data we reviewed for this report
revealed a high indication of public health protection from DWSRF funds.
While the results of our sample show positive indications, the EPA's
incomplete data hampers tracking of public health outcomes. In addition, the
EPA needs to systematically demonstrate how project results contribute to
public health.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
No.
Subject
Status1
Planned
Completion
Action Official	Date
Claimed
Amount
Ag reed-To
Amount
Enforce the grant requirement for states to input all
necessary data in the PBR database (e.g., project
completion, project results, project start/end dates,
compliance period begin/end dates, and public
water system identification numbers).
Review state-level data entry to ensure data
completeness in the PBR database as part of the
EPA's annual review of state performance.
Implement the most cost-effective method to
capture public health benefits information by using
information gathered in state annual reviews and
enhancing coordination with compliance monitoring
programs at the federal and state levels.
Periodically evaluate program results to ensure that
program goals are being achieved at water
systems receiving DWSRF financial assistance and
record successes, best practices and challenges to
be shared among EPA regions and the states to
focus and enhance program performance.
Assistant Administrator
for Water
4/30/15
Assistant Administrator 12/31/142
for Water
Assistant Administrator 3/31/15
for Water
Assistant Administrator 12/31/14
for Water
1	0 = Recommendation is open with agreed-to corrective actions pending.
C = Recommendation is closed with all agreed-to actions completed.
U = Recommendation is unresolved with resolution efforts in program.
2	While the Office of Water cited an earlier date in its response to the draft report, the Office of Water subsequently indicated it will not complete the
action until December 31, 2014.
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Appendix A
Agency Response
MEMORANDUM
SUBJECT: Response to Office of Inspector General Draft Report No. OPE-FY-0009, "EPA
Needs to Demonstrate Public Health Benefits of Drinking Water State Revolving Fund
Projects," dated August 1, 2014
FROM: Kenneth J. Kopocis
Deputy Assistant Administrator
TO:	Arthur A. Elkins, Jr.
Inspector General
Thank you for the opportunity to respond to the issues and recommendations in the subject audit
report. Following is a summary of the U.S. Environmental Protection Agency's overall position,
along with its position on each of the report recommendations. For the report recommendations,
with which the EPA agrees, we have provided high-level intended corrective actions and
estimated completion dates. We have also attached technical comments on the report for your
consideration.
AGENCY'S OVERALL POSITION
The EPA's Office of Water/Office of Ground Water and Drinking Water has worked to ensure
public health benefits of the Drinking Water State Revolving Fund through integration with the
Public Water System Supervision program. Both programs are driven to maximize the same
internal measures established for the National Water Program in 1997:
(1)	The percent of the population served by community water systems that receive
drinking water that meets all applicable health-based drinking water standards
through approaches including effective treatment and source water protection.
(2)	The percent of community water systems that meet all applicable health-based
standards through approaches that include effective treatment and source water
protection.
In 2006 the Director of the OW/OGWDW wrote a memorandum to Regional Water Division
Directors indicating that coordination of the DWSRF and PWSS programs is essential to SDWA
implementation and underscoring the importance of integrating these mutually-reinforcing
programs. Available data examined for the subject draft report support that intended public
health benefits are being achieved for consumers of water systems receiving DWSRF financial
assistance. The Inspector General's comparison of results of the DWSRF Project and Benefits
Reporting System (PBR) and the Safe Drinking Water Information System (SDWIS) shows that
93.8 percent of water systems (347 of 370 systems) had no reported violations after DWSRF-
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funded project completion. Additionally, of the 6.2 percent of systems with reported violations,
only five systems (1.4 percent of the total) had violations due to the presence of contaminants.
Notwithstanding this high indication of public health protection, the EPA agrees that more can
be done to integrate the results of the two information systems. We are currently working on a
pilot effort using FY 2013 data to complete a comparison of violations in SDWIS with project
completion status in PBR (through electronic spreadsheet analysis) to integrate results without
the expense of database modification.
AGENCY'S RESPONSE TO REPORT RECOMMENDATIONS
Agreements
No.
Recommendation
High-Level Intended Corrective
Action(s)
Estimated Completion by FY
1
Enforce the grant
requirement for states to
input all necessary data
in PBR (e.g., project
completion, project
results, project start/end
dates, compliance
period begin/end dates,
and public water system
identification numbers).
The OW/OGWDW agrees with
the intent of this recommendation
as a path to mutual data quality
objectives, which we share with
the IG. We take lack of reporting
seriously and will work with
Regions and states to ensure
receipt in PBR of complete data
for projects receiving DWSRF
financial assistance as provided for
in grant terms and conditions. To
support complete data reporting,
we will also be doing further
analysis of data completeness in
PBR.
The OW/OGWDW will
provide Regions a report of
completeness of required
DWSRF project data
beginning in April 2015 and
quarterly thereafter. The
Regions will be able to
identify with states the
actions needed for states to
provide complete data for
projects receiving DWSRF
financial assistance and to
oversee steps to accomplish
complete reporting of
required data. Where
incomplete reporting of
required data continues to be
a problem, the
OW/OGWDW will consult
with the Region on taking
appropriate corrective action.
2
Review state-level data entry
to ensure data completeness in
PBR as part of the EPA's
annual review of state
performance.
The OW/OGWDW agrees with
this recommendation and will
provide guidance for the annual
review process and checklist that
includes checking on completeness
of the states' data reported in PBR
for reviews in FY 2015.
September 2014.
3
Implement the most cost-
effective method to capture
public health benefit
The OW/OGWDW agrees with
this recommendation and has
initiated data integration of the
March 2015.
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information by using
information required in state
annual/biennial reports and
enhancing coordination with
compliance monitoring
programs at the federal and
state levels.
PBR and SDWIS data sets to
identify completed projects
receiving DWSRF financial
assistance which were in violation
after project completion. The
OW/OGWDW will develop a
regular report for use by Regions
and states to document the public
health results of the DW SRF
financial assistance.

4
Periodically evaluate program
results to ensure that program
goals are being achieved at
water systems receiving
DWSRF financial assistance
and record successes, best
practices and challenges to be
shared among the EPA
regions and the states to focus
and enhance program
performance.
The OW/OGWDW agrees with
this recommendation. The
OGWDW conducts an annual
review of the program through the
Regional offices' focused reviews
of state program outputs for the
prior year. OW/OGWDW will
continue to evaluate program
results and achievement of
program goals as well as
determine what actions are
necessary to achieve results where
needed. The reviews will also
record successes, best practices
and challenges to share among
Regions and states.
December 2014 and annually
thereafter.
CONTACT INFORMATION
If you have any questions regarding this response, please contact Charles Job, Chief of the
Infrastructure Branch in the OW/OGWDW, at (202) 564-3941 orjob.charles@epa.gov.
cc: Dan Engelberg
Carolyn Cooper
Marilyn Ramos
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Distribution
Office of the Administrator
Deputy Assistant Administrator for Water
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Principal Deputy Assistant Administrator for Water
Audit Follow-Up Coordinator, Office of Water
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