oversight

Rural Water Infrastructure: Additional Coordination Can Help Avoid Potentially Duplicative Application Requirements

Published by the Government Accountability Office on 2012-10-16.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

               United States Government Accountability Office

GAO            Report to Congressional Addressees




October 2012
               RURAL WATER
               INFRASTRUCTURE
               Additional
               Coordination Can
               Help Avoid Potentially
               Duplicative
               Application
               Requirements




GAO-13-111
                                             October 2012

                                             RURAL WATER INFRASTRUCTURE
                                             Additional Coordination Can Help Avoid Potentially
                                             Duplicative Application Requirements
Highlights of GAO-13-111, a report to
congressional addressees




Why GAO Did This Study                       What GAO Found
Many rural communities with                  Funding for rural water and wastewater infrastructure is fragmented across the
populations of 10,000 or less face           three federal programs GAO reviewed, leading to program overlap and possible
challenges in financing the costs of         duplication of effort when communities apply for funding from these programs.
replacing or upgrading aging and             The three federal water and wastewater infrastructure programs—the
obsolete drinking water and                  Environmental Protection Agency’s (EPA) Drinking Water and Clean Water State
wastewater infrastructure. EPA and           Revolving Fund (SRF) programs and the U.S. Department of Agriculture’s
USDA oversee the three largest               (USDA) Rural Utilities Service (RUS) Water and Waste Disposal program—have,
federally funded drinking water and          in part, an overlapping purpose to fund projects in rural communities with
wastewater funding programs for these
                                             populations of 10,000 or less. For the 54 projects GAO reviewed in the five states
communities. In response to Pub. L.
                                             it visited, this overlap did not result in duplicate funding, that is funding for the
No. 111-139, which directs GAO to
identify and report on duplicative goals
                                             same activities on the same projects. However, GAO identified the potential for
or activities in the federal government,     communities to complete duplicate funding applications and related documents
this report examines the (1) potential       when applying for funding from both agencies. In particular, some communities
for fragmentation, overlap, and              have to prepare preliminary engineering reports and environmental analyses for
duplication between EPA and USDA             each program. GAO’s analysis showed—and community officials and their
drinking water and wastewater                consulting engineers confirmed—that these reports usually contain similar
infrastructure programs and (2) extent       information but have different formats and levels of detail. Completing separate
to which these agencies coordinate at        engineering reports and environmental analyses is duplicative and can result in
the federal and state level to fund          delays and increased costs to communities applying to both programs.
community water infrastructure
projects. GAO analyzed relevant laws         EPA and USDA have taken some actions to coordinate their programs and
and regulations and program data and         funding at the federal and state levels to help meet the water infrastructure needs
documents. GAO also visited five             of rural communities, but GAO’s review in five states showed that their efforts
states based on high rural funding           have not facilitated better coordination at the state level in more specific ways.
needs and geographic location                EPA and USDA signed a joint memorandum in 1997 encouraging state-level
(Colorado, Montana, North Carolina,          programs and communities to coordinate in four key areas: program planning;
Pennsylvania, and South Dakota) to           policy and regulatory barriers; project funding; and environmental analyses and
meet with federal, state, and                other common federal requirements. As of July 2012, EPA and USDA had taken
community officials and visit projects.      action at the federal level to help the states coordinate better and make programs
                                             more efficient for communities applying for funding. For example, EPA and
What GAO Recommends                          USDA had formed a working group to draft uniform guidelines for preliminary
GAO recommends that EPA and                  engineering report requirements, but this effort is not yet complete. However, the
USDA complete guidelines to help             agencies have not taken action to help states develop uniform environmental
states develop uniform preliminary           analysis requirements, as called for in the 1997 memorandum. Without uniform
engineering reports, develop                 requirements, communities face a continuing burden and cost of applying for
guidelines to help states develop            federal and state funds to improve rural water and wastewater infrastructure.
uniform environmental analyses, and          Coordination in the four key areas varied across the five states GAO visited. For
reemphasize the importance of state-         example, state and federal officials in Montana created a drinking water and
level coordination. EPA neither agreed       wastewater working group to coordinate project funding and to resolve regulatory
nor disagreed with GAO’s first two           barriers such as different funding cycles between the programs. In addition, state
recommendations and concurred with           and federal officials in Pennsylvania coordinated to develop uniform
the third. USDA neither agreed nor           environmental analysis requirements. However, in North Carolina and Colorado,
disagreed with the recommendations.          state-level programs did not coordinate well initially about project funding, which
                                             resulted in the state-level programs planning to pay for the same projects. The
                                             programs were able to avoid paying for the same projects, but state-level RUS
View GAO-13-111. For more information,       programs have or expect to deobligate almost $20 million committed to these
contact David Trimble at (202) 512-3841 or   projects and return the funding to USDA. Further delays in coordinating programs
trimbled@gao.gov.
                                             could prevent funds from reaching needy communities.
                                                                                      United States Government Accountability Office
Contents


Letter                                                                                      1
               Background                                                                   6
               Fragmentation and Overlap in EPA and USDA Programs Can
                 Result in Potential Duplication of Community Efforts to Apply
                 for Funding                                                              15
               Federal and State Actions Have Not Fully Facilitated Coordination
                 for Funding Communities’ Projects                                        28
               Conclusions                                                                35
               Recommendations for Executive Action                                       36
               Agency Comments and Our Evaluation                                         37

Appendix I     Objectives, Scope, and Methodology                                         42



Appendix II    Drinking Water and Clean Water State Revolving Fund Program Funds
               Provided to Communities with Populations of 10,000 or Less        47



Appendix III   Comments from the Environmental Protection Agency                          49



Appendix IV    Comments from the U.S. Department of Agriculture’s Office of Rural
               Development                                                                53



Appendix V     GAO Contact and Staff Acknowledgments                                      57



Tables
               Table 1: Funding Awards for 42 Drinking Water and Wastewater
                        Projects Selected for Review                                      17
               Table 2: Funding Awards for 12 Drinking Water and Wastewater
                        Projects Selected for Review That Received Funding from
                        an SRF Program and the RUS Program                                21
               Table 3: Similarities in Components of Preliminary Engineering
                        Reports Prepared for the SRF and RUS Programs for Four
                        Selected Projects                                                 23



               Page i                                    GAO-13-111 Rural Water Infrastructure
          Table 4: Similarities in Components of Environmental Analyses
                   Submitted to the SRF and RUS Programs for Four Selected
                   Projects                                                                         26
          Table 5: State SRF and RUS Program Activities to Implement 1997
                   Joint Memorandum on Drinking Water and Wastewater
                   Activities                                                                       32
          Table 6: Drinking Water and Clean Water SRF Program Funds
                   Provided to Communities with Populations of 10,000 or
                   Less                                                                             47


Figures
          Figure 1: State Drinking Water and Clean Water SRF Program
                   Funding Sources                                                                   8
          Figure 2: Application Process and Timeline Generally Followed for
                   EPA’s SRF and USDA’s RUS Programs                                                11




          Abbreviations

          EPA               Environmental Protection Agency
          HUD               Department of Housing and Urban Development
          NEPA              National Environmental Policy Act
          NIMS              National Information Management System
          RUS               Rural Utilities Service
          SRF               State Revolving Fund
          USDA              U.S. Department of Agriculture




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          Page ii                                              GAO-13-111 Rural Water Infrastructure
United States Government Accountability Office
Washington, DC 20548




                                   October 16, 2012

                                   Congressional Addressees

                                   Many communities with populations of 10,000 or less face significant
                                   challenges in financing the costs of replacing or upgrading aging and
                                   obsolete drinking water and wastewater infrastructure. The demand for
                                   such drinking water and wastewater infrastructure projects in these
                                   communities, many of which are considered rural, is estimated by federal
                                   agencies to be more than $100 billion in the coming decades. For
                                   example, communities may need to upgrade basic wastewater systems,
                                   which treat wastes by allowing them to settle out in ponds or lagoons,
                                   with more sophisticated equipment that mechanically and biologically
                                   removes solids and contaminants. Or, communities may need to upgrade
                                   to more expensive filtration equipment to remove contaminants, such as
                                   arsenic or excess nutrients, as regulations become more stringent for
                                   drinking water quality and wastewater. Communities typically pay for
                                   drinking water and wastewater infrastructure through the rates charged to
                                   users of the drinking water and wastewater systems. In some cases,
                                   however, these communities do not have the number of users needed to
                                   spread the cost of major infrastructure projects and still maintain
                                   affordable user rates. In addition, unlike larger, urban communities that
                                   can issue their own public bonds to pay for major water and wastewater
                                   infrastructure improvements, it can be difficult for rural communities to
                                   independently finance such major improvements. In many cases, rural
                                   communities have limited access to financial markets, restricting their
                                   ability to issue bonds to raise capital. As a result, these communities
                                   depend heavily on federal and state grants and subsidized loan programs
                                   to finance their water and wastewater infrastructure projects.

                                   The Environmental Protection Agency (EPA) and the U.S. Department of
                                   Agriculture (USDA) oversee the three largest federally funded drinking
                                   water and wastewater infrastructure assistance programs. EPA
                                   administers the Drinking Water State Revolving Fund (SRF) program,
                                   which provides annual funding to states to finance projects for publicly
                                   and privately owned drinking water treatment plants, and the Clean Water
                                   SRF program, which provides funding to states to finance projects for
                                   constructing, replacing, or upgrading publicly owned municipal
                                   wastewater treatment plants. EPA allocates its funding in the form of
                                   capitalization grants to revolving fund programs administered by each
                                   state, and state officials in turn distribute loan funding for qualified
                                   drinking water and wastewater infrastructure projects in local


                                   Page 1                                    GAO-13-111 Rural Water Infrastructure
communities. Communities of any size can apply for assistance. When
allocating funds to community projects, state officials consider
environmental factors, such as the projects’ impact on the communities’
compliance with federal and state regulations for drinking water and clean
water. Over the long term, the state SRF programs are intended to be
sustained through communities’ repayment of loans, creating a continuing
source of assistance for priority drinking water and wastewater
infrastructure projects. In fiscal year 2011, the Drinking Water and Clean
Water SRF programs received $963 million and $1.5 billion in federal
appropriations, respectively.

USDA’s Rural Utilities Service (RUS) administers the Water and Waste
Disposal program, which provides funding for both drinking water and
wastewater projects in low-income rural communities of 10,000 or less.1
In fiscal year 2011, the program received $516 million in appropriations,
which was then allocated to USDA offices located in each state, using a
formula based on the state’s rural population, number of households in
poverty, and rate of unemployment. Each USDA state office reviews
project applications and approves funding for communities. If the USDA
funds allocated to each state office are not fully obligated, they are pooled
by USDA headquarters and redistributed to states that have projects
ready to fund.

We have previously reported that fragmentation and overlap among
government programs can lead to duplicative program requirements.2
Fragmentation occurs when more than one federal agency, or more than
one organization within an agency, is involved in the same broad area of
national need. Overlap occurs when multiple agencies and programs
have similar goals, engage in similar activities or strategies to achieve
them, or target similar beneficiaries or recipients. Fragmentation can lead
to overlapping programs and can create the potential for inefficiencies



1
 In this report, we refer to the RUS’ Water and Waste Disposal program as the RUS
program.
2
 GAO, Managing for Results: Using the Results Act to Address Mission Fragmentation
and Program Overlap, GAO/AIMD-97-146 (Washington, D.C.: Aug. 29, 1997). For more
information on fragmentation, overlap, and duplication in federal programs see GAO,
Opportunities to Reduce Potential Duplication in Government Programs, Save Tax
Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1, 2011) and
GAO, Opportunities to Reduce Duplication, Overlap and Fragmentation, Achieve Savings,
and Enhance Revenue, GAO-12-342SP (Washington, D.C.: Feb. 28, 2012).




Page 2                                             GAO-13-111 Rural Water Infrastructure
such as duplication. Duplication occurs when two or more agencies or
programs are engaged in the same activities to provide the same services
to the same recipients; however, in some instances, duplication may be
warranted because of the magnitude or nature of the federal effort. We
have also reported that federal programs contributing to the same or
similar outcomes should coordinate or collaborate on their efforts. For
example, in August 1997, we reported that federal programs contributing
to the same or similar outcomes should be closely coordinated,
consolidated, or streamlined, as appropriate, to ensure that goals are
consistent and that program efforts are mutually reinforcing.3
Furthermore, we have identified practices that can help enhance and
sustain collaboration among federal agencies. In this report, we do not
distinguish between the two terms coordination and collaboration.4

EPA and USDA have long recognized the potential for fragmentation,
overlap, and duplication in their drinking water and wastewater
infrastructure programs and the need for coordination to avoid these
outcomes. Together with the Department of Housing and Urban
Development (HUD),5 EPA and USDA issued a joint memorandum in
1997 that emphasized cooperation and coordination on jointly financed
drinking water and wastewater infrastructure projects to, among other
things, foster cooperation among the organizations that administer these
programs and minimize duplication of planning efforts.6 However, in
December 2009, we reported that EPA, USDA, and other agencies that
fund drinking water and wastewater infrastructure for rural communities
along the U.S.-Mexico border lacked coordinated policies and processes




3
GAO/AIMD-97-146.
4
 GAO, Results-Oriented Government: Practices That Can Help Enhance and Sustain
Collaboration among Federal Agencies, GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
These practices include identifying common outcomes, developing joint strategies,
leveraging resources, and establishing compatible policies and procedures across agency
boundaries.
5
 HUD disburses grants to states and local governments through the Community
Development Block Grant Program to fund housing, infrastructure, and other community
development activities, including drinking water and wastewater projects.
6
 Joint Memorandum between USDA, EPA and HUD. Cooperation and Coordination on
Jointly Financed Water and Wastewater Activities. (Washington, D.C.: April 3, 1997).




Page 3                                             GAO-13-111 Rural Water Infrastructure
and did not efficiently coordinate their programs, priorities, or funding.7 To
better address the needs of the region, we suggested Congress consider
establishing an interagency mechanism to coordinate programs and
funding, such as a task force on water and wastewater infrastructure or
other mechanism, in the border region.

In 2010, Pub. L. No. 111-139 directed that GAO identify and report on
federal programs, agencies, offices, and initiatives—either within
departments or governmentwide—that have duplicative goals or
activities.8 Accordingly, the objectives of this report examine (1) the
potential for fragmentation, overlap, and duplication among programs
administered by EPA and USDA to address drinking water and
wastewater infrastructure needs in rural communities and (2) the extent to
which these agencies coordinate at the federal and state level to help
meet the water infrastructure needs of rural communities.

To address both objectives, we reviewed relevant statutes, regulations,
guidance, budgets, and other documents; interviewed officials from EPA
and USDA and representatives from engineering firms, local
communities, and relevant nonprofit organizations; and obtained financial
and other information about projects funded by at least one of the three
programs from fiscal year 2007 through fiscal year 2011. To assess the
extent of overlap between the programs, we compared annual funding
data from EPA and USDA. We assessed the reliability of these data by
interviewing EPA and USDA officials about the quality of the data and
determined it to be reliable for our purposes. We visited a
nongeneralizable sample of five selected states—Colorado, Montana,
North Carolina, Pennsylvania, and South Dakota—to observe federally
funded projects and discuss with state and local officials their experiences
in disbursing and applying for funding from the EPA and USDA




7
 GAO, Rural Water Infrastructure: Improved Coordination and Funding Processes Could
Enhance Federal Efforts to Meet Needs in the U.S.-Mexico Border Region, GAO-10-126
(Washington, D.C.: Dec. 18, 2009).
8
Pub. L. No. 111-139, § 21, 124 Stat. 29 (2010), 31 U.S.C. § 712 note.




Page 4                                             GAO-13-111 Rural Water Infrastructure
programs.9 From our analysis of EPA and USDA project needs data
compiled by state each year, the five states we visited have high levels of
drinking water and wastewater infrastructure needs for communities with
populations of less than 10,000, in comparison with other states. We
assessed the reliability of EPA’s data by reviewing its quality control
reports. We assessed the reliability of USDA’s data by interviewing RUS
officials on the quality control steps used in gathering the data. We
determined the data were reliable for our purposes of selecting states. In
addition, to determine the extent to which agencies coordinate at the
federal and state level to help meet the water infrastructure needs of rural
communities, we met with federal and state officials and considered
EPA’s and USDA’s efforts to promote the guidance established in the
1997 joint memorandum. Furthermore, we discussed the levels of
coordination among federal and state agencies with local community
officials who applied for and received funding from one or the other of the
programs. To identify leading practices for coordination, we reviewed our
prior work on practices that can help enhance and sustain collaboration
among federal agencies.10 A more detailed description of our objectives,
scope, and methodology is presented in appendix I.

We conducted this performance audit from September 2011 to
September 2012 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.




9
  We selected these five states on the basis of rural funding needs as identified by EPA
and USDA, geographic location, and information provided by federal and state officials on
the level of coordination occurring among water infrastructure programs. We selected 31
communities and 54 projects using funding lists provided by state and federal officials to
identify projects in communities that had applied for or received funding from the state
SRF and RUS programs, or both, as well as recommendations from state and federal
officials. Because these are nongeneralizable samples, the information obtained from
these visits cannot be generalized to all states, communities, or projects but provides
illustrative examples of their experiences in disbursing and applying for funding from the
EPA and USDA programs.
10
    GAO-06-15.




Page 5                                               GAO-13-111 Rural Water Infrastructure
                            Rural communities often have small or aging drinking water and
Background                  wastewater systems. The need for a water project can arise for multiple
                            reasons, including replacing or upgrading outdated or aging equipment
                            that does not treat water to meet water quality standards and systems
                            that do not produce water to meet new treatment standards. For example,
                            arsenic is often present naturally in groundwater, and to meet new federal
                            arsenic standards for drinking water, many rural communities using
                            groundwater as a drinking water source will have to improve their drinking
                            water systems to remove arsenic. EPA estimates that drinking water and
                            wastewater infrastructure for small communities over the next several
                            decades could cost more than $100 billion.

                            This section describes (1) federal funding for drinking water and
                            wastewater infrastructure projects in rural communities; (2) the process
                            for applying for these federal funds, including the requirements state and
                            federal agencies must ensure rural communities meet under the National
                            Environmental Policy Act; and (3) our prior work on coordination among
                            federal agencies and rural water infrastructure programs.


Federal Funding for Rural   The federal government administers a number of programs that assist
Water Infrastructure        rural communities in developing water and wastewater systems and
Projects                    complying with federal regulations, with EPA’s drinking water and clean
                            water SRF programs and USDA’s RUS program providing the most
                            funding. Communities typically pay for drinking water and wastewater
                            infrastructure through the rates charged to users of the drinking water and
                            wastewater systems. Large communities serve many people and can
                            spread the cost of infrastructure projects over these numerous users,
                            which makes projects more affordable. Small or rural communities have
                            fewer users across which to spread rate increases, making infrastructure
                            projects less affordable and these communities more reliant on federal
                            funding to help lower the cost of projects through lower interest rates or
                            grants that do not need to be repaid.

                            The Safe Drinking Water Act and the Clean Water Act authorize the
                            Drinking Water SRF and Clean Water SRF programs, respectively, as
                            well as EPA’s authority to regulate the quality of drinking water provided
                            by community water supply systems and the discharge of pollutants into
                            the nation’s waters. Under the Safe Drinking Water Act, EPA sets
                            standards to protect the nation’s drinking water from contaminants, such
                            as lead and arsenic. In 1996, amendments to the act established the
                            drinking water SRF program to provide assistance for publicly and
                            privately owned drinking water systems. Under the Drinking Water SRF


                            Page 6                                      GAO-13-111 Rural Water Infrastructure
program, states make loans and are required to provide a certain
percentage of funding in loan assistance to communities of less than
10,000.11 The Clean Water Act is intended to maintain and restore the
physical, chemical, and biological integrity of our surface waters, such as
rivers, lakes, and coastal waters. In 1987, amendments to the Clean
Water Act established the Clean Water SRF program to provide
assistance to publicly owned wastewater treatment facilities. Using the
federal funds EPA provides to capitalize the state SRF programs, states
provide loans to communities for drinking water and wastewater treatment
projects. In order to qualify, states must contribute an amount equal to 20
percent of the federal capitalization grant. States that qualify for funding
are responsible for administering their individual SRF programs, and
communities of any size can apply for assistance. Loans are generally
provided at below-market interest rates, saving communities money on
interest over the long term. As communities repay the loans, the states’
funds are replenished, enabling them to make loans to other eligible
drinking water and wastewater projects, and creating a continuing source
of assistance for communities. See figure 1 for a description of the state
Drinking Water and Clean Water SRF program funding sources.
Nationwide, there are almost 52,000 publicly and privately owned drinking
water systems and 16,000 publicly owned wastewater treatment facilities.




11
  Under the Safe Drinking Water Act, 15 percent of the amount credited to any state
revolving loan fund in any fiscal year is to be available solely for providing loan assistance
to public water systems that regularly serve fewer than 10,000 persons.




Page 7                                                 GAO-13-111 Rural Water Infrastructure
Figure 1: State Drinking Water and Clean Water SRF Program Funding Sources




Note: Some states also use the funds provided by EPA to support bond issuances that they then use
to fund projects.


USDA’s RUS administers a water and wastewater loan and grant
program for rural communities with populations of 10,000 or less. The
program is designed to address public health concerns in the nation’s
rural areas by providing funding for new and improved drinking water and
wastewater infrastructure. RUS provides a mix of loan and grant funding
to communities that have been denied credit through normal commercial
channels. Like the SRF programs, the RUS program makes loans at
below-market rates to save communities interest over time but, unlike the
SRF programs, the RUS program can make loans for up to 40 years,
which helps lower communities’ annual repayment costs. In addition,
communities do not need to repay funds received as grants, further
helping to reduce the overall financial burden they incur upon a water
project’s completion. To determine the amount of loans and grants a



Page 8                                                   GAO-13-111 Rural Water Infrastructure
                          community receives, RUS assesses the potential increase in the water or
                          sewer user rate needed to repay the loan. RUS provides grants to
                          communities when necessary to reduce user rates to a level that the
                          agency determines to be reasonable.

                          Other federal agencies have programs that provide funds for drinking
                          water and wastewater infrastructure, including HUD’s Community
                          Development Block Grant program and the Department of Commerce’s
                          Economic Development Administration’s Public Works and Economic
                          Development Program. Under HUD’s program, communities use block
                          grants for a broad range of activities to provide suitable housing in a safe
                          living environment, including water and wastewater infrastructure. Thirty
                          percent of block grant funds are allocated by formula to states for
                          distribution to communities of 50,000 or less. Drinking water and
                          wastewater needs compete with other public activities for funding and,
                          according to HUD officials, account for about 10 percent of all block grant
                          funds nationally. Economic Development Administration’s Public Works
                          and Economic Development Program provides grants to small and
                          disadvantaged communities to construct public facilities, including
                          drinking water and wastewater infrastructure, to alleviate unemployment
                          and underemployment in economically distressed areas. In addition, the
                          U.S. Army Corp of Engineers and the Department of the Interior’s Bureau
                          of Reclamation provide financial assistance for some large drinking water
                          and wastewater projects, but these projects must be authorized by
                          Congress prior to construction.

                          In addition to these federal programs, some states have created their own
                          programs to provide assistance for drinking water and wastewater
                          infrastructure. For example, the North Carolina Rural Economic
                          Development Center provides infrastructure loans for communities in the
                          state’s rural counties. In Montana, the Treasure State Endowment
                          Program provides grants to make drinking water and wastewater projects
                          more affordable for the state’s communities.


Application Process and   The state SRF programs and the RUS program each have their own
National Environmental    application process through which communities can apply for funding,
Policy Act Requirements   although the application processes generally include similar steps: (1)
                          completing an application that asks for, among other things, basic
                          demographic, legal, and financial information associated with the project;
                          (2) developing a preliminary engineering report that provides basic design
                          specifications and other technical information for the project; and (3)
                          conducting an environmental analysis that considers the environmental


                          Page 9                                      GAO-13-111 Rural Water Infrastructure
effects of the proposed project and alternatives. The state agencies
responsible for EPA’s SRF programs and USDA state offices review
these documents, prioritize the projects based on agency-determined
criteria, provide comments to communities on how their applications can
be improved, and ultimately approve or reject the request for funding.
Communities can choose to apply for funding to different federal and
state programs at any stage during the process. In some cases, the SRF
and RUS programs will work together to jointly fund the same project if
the project is too large for one agency to fund, or if it will make the project
more affordable for the community. If their requests are approved,
communities design the projects, obtain construction bids, contract to
build the projects, and are reimbursed by the funding agency.
Communities usually hire a consulting engineer to develop the preliminary
engineering reports and conduct the environmental analyses for a project.
In addition, EPA and USDA pay for technical service providers that
communities can use to help them understand and apply for their
programs. Communities can also get assistance from local planning
districts, which are voluntary associations of county and municipal
governments that provide development assistance to their membership.

A preliminary engineering report describes the proposed project, including
its purpose, features of the proposed location, condition of any existing
facilities, alternative approaches considered, design features, and costs.
Figure 2 shows the application process and timeline that is generally
followed for both EPA and RUS programs.




Page 10                                       GAO-13-111 Rural Water Infrastructure
Figure 2: Application Process and Timeline Generally Followed for EPA’s SRF and
USDA’s RUS Programs




Note: These steps are a general representation of the funding application and approval process. The
exact order and timing of the steps may vary by state or program.


The state SRF and RUS state-level programs review the likely
environmental effects of projects they are considering funding using
different levels of environmental analysis. These reviews occur either
under the National Environmental Policy Act of 1969 (NEPA) for the RUS




Page 11                                                   GAO-13-111 Rural Water Infrastructure
                         program,12 or for the SRF programs, under a state environmental review
                         process similar to NEPA. EPA regulations define the necessary elements
                         of these state “NEPA-like” reviews.13 Typically, a proposed water or
                         wastewater project is subject to an environmental assessment or, in the
                         rare case that the project is likely to significantly affect the environment, a
                         more detailed environmental impact statement. If, however, the agency
                         determines that activities of a proposed project fall within a category of
                         activities the agency has determined has no significant environmental
                         impact—a determination called a categorical exclusion—then the project
                         applicant or the agency, as appropriate, generally does not have to
                         prepare an environmental assessment or environmental impact
                         statement.14 Because many community water and wastewater
                         infrastructure projects either upgrade or replace existing infrastructure,
                         projects rarely result in significant environmental impacts, and NEPA
                         requirements can be satisfied through an environmental assessment or a
                         categorical exclusion. In addition, in some cases, the funding agency may
                         help complete the environmental analysis documents for a planned
                         project.


Federal Agencies’        Our previous work has raised questions regarding sufficient coordination
Coordination for Rural   between drinking water and wastewater infrastructure funding programs,
Water Infrastructure     despite federal efforts to improve coordination at the state and local level.
                         In December 2009, we reported that EPA, USDA, and other agencies that
                         fund drinking water and wastewater infrastructure for rural communities
                         along the U.S.-Mexico border, lacked coordinated policies and processes
                         and did not efficiently coordinate their programs, priorities, or funding.15
                         Specifically, without efficient coordination, applicants faced significant
                         administrative burdens that, in some cases, resulted in project delays



                         12
                           Pub. L. No. 91-190, 83 Stat. 852 (1970), codified as amended at 42 U.S.C. §§ 4321-
                         4347 (2011). Under NEPA, federal agencies must assess the effects of major federal
                         actions—those they propose to fund, carry out, or to permit—that significantly affect the
                         environment. NEPA has two principal purposes: (1) to ensure that an agency carefully
                         considers detailed information concerning significant environmental impacts and (2) to
                         ensure that this information will be made available to the public.
                         13
                          See 40 C.F.R. 35.3140(b) (CWA); 40 C.F.R. § 35.3580(c) (SDWA).
                         14
                           According to USDA, under RUS regulations, non-administrative categorical exclusions
                         require additional supporting documentation.
                         15
                          GAO-10-126.




                         Page 12                                              GAO-13-111 Rural Water Infrastructure
because the programs required separate documentation to meet the
same requirements and did not consistently coordinate in selecting
projects. For example, an engineer in Texas told us that one community
applying for funding had to pay $30,000 more in fees because the
engineer had to complete two separate sets of engineering
documentation for EPA and USDA. As we stated in our December 2009
report, the applicant could have saved these funds had EPA and USDA
established uniform engineering requirements. To resolve such
inefficiencies, we suggested Congress consider establishing an
interagency mechanism, such as a task force, of federal agencies
working in the border region. One of the responsibilities of this task force
would be to work with state and local officials to develop standardized
applications and environmental review and engineering documents, to the
extent possible, for the federal and state agencies working in the border
region.

Similarly, our October 2005 report discusses collaboration and practices
that federal and state agencies can engage in to enhance and sustain
interagency collaboration.16 In the report, we define collaboration as any
joint activity that is intended to produce more public value than could be
produced when organizations act alone. According to the report, agencies
can enhance and sustain interagency collaboration by engaging in one or
more of the following practices:

     define and articulate a common outcome;

     establish mutually reinforcing or joint strategies;

     identify and address needs by leveraging resources;

     agree on roles and responsibilities;

     establish compatible policies, procedures, and other means to operate
      across agency boundaries;

     develop mechanisms to monitor, evaluate, and report on results;

     reinforce agency accountability through agency plans and reporting;
      and


16
    GAO-06-15.




Page 13                                         GAO-13-111 Rural Water Infrastructure
    reinforce individual accountability for collaborative efforts through
     performance management systems.

For a number of these practices, the report states that nonfederal
partners, key clients, and stakeholders need to be involved in decision
making. Additionally, a number of important factors, such as leadership,
trust, and organizational culture, are necessary elements for a
collaborative relationship.

Consistent with the findings of our October 2005 report, the 1997 joint
memorandum signed by EPA, USDA, and HUD encourages cooperation
in developing strategic plans for each agency’s program and encourages
cooperation among program managers at the state level to remove as
many barriers as possible in program regulations or policy. In addition,
the memorandum encourages the development of common practices
across agencies, including regularly communicating and leveraging funds
to make the most efficient use of available resources. Moreover, the
memorandum encourages the signing agencies to prepare common
documents, including one environmental analysis per project, that meet
all the federal and state agencies’ requirements. This memorandum is
similar to governmentwide NEPA regulations and various guidance
issued by the Council on Environmental Quality, which emphasize the
need for coordination among federal and state agencies on environmental
and other requirements.17 Most recently, the council issued a March 2012
guidance that encourages federal agencies to cooperate with state, tribal,
and local governments so that one document satisfies as many applicable
environmental requirements as practicable. In addition, the guidance
encourages federal agencies to enhance coordination under NEPA by
designating a lead agency responsible for conducting an environmental
analysis.18 Furthermore, according to the guidance, a federal agency
preparing an environmental analysis should consider adopting another
federal agency’s environmental analysis if it addresses the proposed




17
  The Council on Environmental Quality, which is part of the Executive Office of the
President, coordinates federal environmental efforts in the development of environmental
policies and initiatives.
18
  A lead agency must supervise the preparation of an environmental analysis if more than
one federal agency either (1) proposes or is involved in the same action or (2) is involved
in a group of actions directly related to each other because of their functional
interdependence or geographical proximity. 40 C.F.R. § 1501.5(a).




Page 14                                              GAO-13-111 Rural Water Infrastructure
                           action and meets the standards for an adequate analysis under NEPA
                           and the adopting agency’s NEPA guidance.


                           Drinking water and wastewater infrastructure funding is fragmented
Fragmentation and          among the three programs we reviewed—EPA’s Drinking Water and
Overlap in EPA and         Clean Water SRF programs and USDA’s RUS program. As a result,
                           overlap can occur when communities with populations of 10,000 or less
USDA Programs Can          apply to one of the SRF programs and the RUS program. For the 54
Result in Potential        projects we reviewed in the five states we visited, this overlap did not
Duplication of             result in duplicate funding or funding for the same activities on the same
                           project. Specifically, for 42 projects that we reviewed, the state SRF
Community Efforts to       programs or the RUS program funded the projects individually, and for
Apply for Funding          the remaining 12 projects that we reviewed, the state SRF and RUS
                           programs each contributed a portion of the overall project cost because
                           none of the programs could cover the full cost individually, according to
                           community officials. However, we identified potentially duplicative efforts
                           by communities to complete funding applications and related documents
                           for both agencies.


The SRF and RUS            Overlap can occur among the state SRF and RUS programs because
Programs Provide           they can each direct funding to communities with populations of 10,000 or
Overlapping, but Not       less. As a result, these communities are eligible to apply for funding from
                           more than one of these programs. For example, communities of 10,000 or
Duplicative, Funding to    less can apply to the state Clean Water SRF and RUS programs for funds
Communities with           to install or upgrade wastewater treatment plants and sewer lines. In
Populations of 10,000 or   addition, communities of 10,000 or less can apply to the state Drinking
Less                       Water SRF and RUS programs for funds to install, repair, improve, or
                           expand treatment facilities, storage facilities, and pipelines to distribute
                           drinking water.

                           The state SRF and RUS programs have funded projects in communities
                           with populations of less than 10,000 in recent years, according to our
                           analysis of SRF and RUS data from July 1, 2007, through June 30, 2011.
                           Specifically, over this time frame, communities with populations of 10,000
                           or less received $3.2 billion, or 36 percent of total Drinking Water SRF
                           funding. Similarly, such communities received $6.3 billion, or 24 percent




                           Page 15                                     GAO-13-111 Rural Water Infrastructure
of total Clean Water SRF funding.19 In accordance with its mission, the
RUS program has directed all of its funding for drinking water and
wastewater infrastructure projects to such communities, for a total of $11
billion from October 1, 2006, through September 30, 2011. The amount of
program funding overlap between the state SRF and RUS programs
varies among the states, with some states showing greater overlap than
others. State Drinking Water SRF program funding overlap with the RUS
program ranged from 7 percent in Rhode Island to 93 percent in Virginia,
and state Clean Water SRF program funding overlap with the RUS
program ranged from 8 percent in California to 74 percent in
Pennsylvania. Additional information about variations in program funding
overlap is provided in appendix II.

Overlap in program funding could lead agencies to fund the same project,
resulting in the potential for duplication. However, for the state SRF and
RUS programs, the majority of projects we reviewed in the five states
were funded by either one of the SRF programs or the RUS program, in
conjunction with other federal or state program funds, such as HUD’s
Community Development Block Grant program, Montana’s Treasure
State Endowment Program, and programs from the North Carolina Rural
Economic Development Center.20 Table 1 shows the funding awards for
community projects in states we visited. In the five states we visited—
Colorado, Montana, North Carolina, Pennsylvania, and South Dakota—42
of the 54 projects we reviewed received funding from the SRF or RUS
programs, in addition to other sources.




19
  EPA’s state-level data are provided as a total amount starting from when EPA began
providing SRF funds to the states. According to EPA documents, EPA began to provide
Drinking Water SRF program funds in federal fiscal year 1997, or starting October 1,
1996, and states reported these data from their corresponding fiscal year—starting on July
1, 1996. Similarly, EPA began to provide Clean Water SRF program funds in federal fiscal
year 1988, or starting October 1, 1987; states reported on the funds received beginning in
their corresponding fiscal year—starting on July 1, 1987.
20
  The Community Development Block Grant program primarily focuses existing or
proposed drinking water and wastewater transmission lines. Because of this specific focus
of the program, we determined the possibility for duplication with the EPA and USDA
programs was slight. In addition, the five states we reviewed have additional sources of
funding for water and wastewater infrastructure. For the projects we reviewed in these
states, we did not identify duplicate funding from these sources of funds.




Page 16                                             GAO-13-111 Rural Water Infrastructure
Table 1: Funding Awards for 42 Drinking Water and Wastewater Projects Selected for Review

All amounts in dollars
State/community/project           Clean Water SRF      Drinking Water SRF           RUS            Other             Total
Colorado
Eckley (DW)                                                      $100,000                                        $100,000
Grover (DW)                                                       518,000                                        518,0000
Grover (WW)                                                                    1,019,000          17,500         1,036,500
Mack (WW)a                                                                                                                0
                                                                                        a
Nunn (DW)                                                       2,424,000              0          10,000         2,434,000
Pagosa Springs (WW)                               0b                   0b                      1,250,000         1,250,000
Paonia (DW)                                                       824,780                        500,000         1,324,780
Salida (WW)                                                                   14,719,000       2,918,000        17,637,000
Salida (DW)                                                       545,000                                          545,000
Montana
East Helena (WW)                           324,350                                               303,239           627,589
East Helena (WW)                           356,215                                                32,408           388,623
East Helena (WW)                                                               5,677,000         850,000         6,527,000
Gallatin Gateway County Water                                                  3,465,000         850,000         4,315,000
and Sewer District (WW)
Valier (DW)                                                                    1,977,500         792,200         2,769,700
Valier (WW)                                600,000                                               600,000         1,200,000
North Carolina
Clinton (WW)                               594,020                                                                 594,020
Clinton (DW)                                                      285,699                                          285,699
Columbia (DW)                                                     491,401                        500,000           991,401
Hertford (WW)                              854,187                                                                 854,187
Southeastern Wayne Sanitary
District (DW)                                                     515,000                        364,850           879,850
Southeastern Wayne Sanitary
District (DW)                                                          0a      6,500,000          38,000         6,538,000
Trinity (Phase 1) (WW)                   3,000,000                                                               3,000,000
Trinity (Phase 2) (WW)                                                         3,377,900         692,100         4,070,000
Trinity (Phase 3) (WW)                                                         5,000,000       2,500,000         7,500,000
Trinity (Phase 4) (WW)                   2,100,000                                                               2,100,000
Trinity (Phase 4A) (WW)                                                        4,845,000       1,205,000         6,050,000
Tuckaseigee Water and Sewer
Authority (WW)                                                                   300,000         500,000           800,000
Wilkesboro (Combination)                                                         300,000         572,150           872,150




                                        Page 17                                        GAO-13-111 Rural Water Infrastructure
All amounts in dollars
State/community/project            Clean Water SRF            Drinking Water SRF                            RUS            Other             Total
Wilkesboro (WW)                             7,363,544                                                                  1,000,000         8,363,544
Pennsylvania
Gratz (DW)                                                                                               396,000         310,000           706,000
Millerstown Municipal Authority
(WW)                                        1,807,500                                                                  3,615,000         5,422,500
Muddy Run Regional Sewer
Authority (WW)                                                                                         20,144,000                       20,144,000
Muddy Run Regional Sewer
Authority (WW)                               571,435                                                                                       571,435
Royalton (WW)                                                                                           1,140,000                        1,140,000
South Dakota
Clay Rural Water System (DW)                                                     844,968                                                   844,968
Clay Rural Water System (DW)                                                   2,208,000                                                 2,208,000
Clay Rural Water System (DW)                                                   1,369,758                                 100,000         1,469,758
Fall River Water Users System
(North Well) (DW)                                                                                       1,178,500        460,000         1,638,500
Faulkton (DW)                                                                    511,725                                                   511,725
Mobridge (DW)                                                                    213,500                                  25,000           238,500
Mobridge (DW)                                                                      62,442                                                   62,442
Southern Black Hills Rural Water
System (DW)                                                                                             4,517,000        767,098         5,284,098

                                        Legend: DW = drinking water project; WW = wastewater project

                                        Source: GAO analysis of federal, state, and local documents.


                                        Notes: “Combination” indicates projects that had both a drinking water and wastewater component.
                                        “Other” indicates federal, state, and local funding sources not listed in this table. A blank cell indicates
                                        funding was not requested from the specific source. Other sources of funding include HUD’s
                                        Community Development Block Grant; state sources such as Montana’s Treasure State Endowment
                                        Fund and and programs from the North Carolina Rural Economic Development Center; and the
                                        community’s own reserve funds.

                                        We selected communities and projects on the basis of funding data and recommendations provided
                                        by state officials. Because these are nongeneralizable samples, the information obtained cannot be
                                        generalized to all communities or projects but provides illustrative examples of community
                                        experiences in applying for funding from the EPA and USDA programs. See appendix I for additional
                                        details.
                                        a
                                         Community asked for, but did not receive, funding.

                                        b
                                         Community received funds from SRF and RUS programs, but returned them.




                                        Page 18                                                                GAO-13-111 Rural Water Infrastructure
In addition to the 42 projects that were separately funded by the state
SRF or RUS programs, 12 projects we reviewed received funding from
both the SRF and RUS programs (see table 2 for funding details). Our
analysis of these projects showed the programs did not pay for the same
activities with their funding, and according to state and community
officials, the joint funding for a community’s project was beneficial and
warranted. Specifically, according to federal, state, and community
officials we interviewed, jointly funded projects tended to be relatively
expensive projects that exceeded one or the other agency’s ability to fund
independently or that needed additional funding to make the project
affordable for community residents. Following are examples:

   Washington, Pennsylvania, population approximately 3,500, sought
    funding from both the Clean Water SRF and RUS programs, and
    other programs, for its nearly $21 million sewer project to install over
    200,000 feet of sewer lines. The community initially sought funding
    from the Clean Water SRF program, but then decided to seek
    additional funding from the RUS program after realizing the project
    exceeded available funding from the SRF program, according to the
    consulting engineer the community used. The Clean Water SRF
    program provided $10.3 million, and the RUS program provided $5.5
    million.

   Hertford, North Carolina, population approximately 2,200 sought
    funding from the Drinking Water SRF and RUS programs for its
    project to expand drinking water capacity by drilling wells, installing
    water supply lines, expanding the water treatment plant, and
    constructing an elevated storage tank. Similar to the Washington,
    Pennsylvania, project, community officials said that the Hertford
    project was too expensive for a single agency to fund. The Drinking
    Water SRF program provided $2.6 million toward the project, and the
    RUS program provided $772,000.

   Faulkton, South Dakota, population approximately 800, sought
    funding from the Drinking Water SRF, the RUS program, and the
    Community Development Block Grant program to replace water
    pipelines and install a water tower. The town applied to multiple
    programs to receive grants to help ensure that the project would be
    affordable to its residents. The Drinking Water SRF program provided
    a loan in the amount of $500,000 and immediately forgave the




Page 19                                      GAO-13-111 Rural Water Infrastructure
    balance of the loan, effectively providing these funds at no cost to the
    community.21 The RUS program provided $2.1 million in funds to this
    project, including grant funds, which helped keep the project
    affordable. The Community Development Block Grant program
    provided approximately $519,000 in additional funds, and the
    community put forth $149,000.




21
  This is called “principal forgiveness,” which means that the state SRF program forgave
all or a portion of the remaining loan balance for a community’s water or wastewater
infrastructure project. Under the American Reinvestment and Recovery Act of 2009 and
subsequent appropriations, states were required to use a portion of their capitalization
grants, under their state SRF programs, to provide additional subsidization to eligible
recipients in the form of forgiveness of principal, negative interest loans, or grants, or any
combination of the three.




Page 20                                                GAO-13-111 Rural Water Infrastructure
Table 2: Funding Awards for 12 Drinking Water and Wastewater Projects Selected for Review That Received Funding from an
SRF Program and the RUS Program

All amounts in dollars
State/community/project                Clean Water SRF            Drinking Water SRF                         RUS          Other          Total
Montana
Conrad (WW)                                   $1,335,000                                                $2,942,400   $1,255,527    $5,532,927
North Carolina
Burgaw (WW)                                     3,000,000                                                5,000,000    3,500,000    11,500,000
Hertford (DW)                                                                      2,569,647              772,000       610,222     3,951,869
Tuckaseigee Water and Sewer                     3,000,000                                               10,250,000      800,000    14,050,000
Authority (WW)
Pennsylvania
Shamokin Coal Township Joint                  20,000,000                                                17,640,000    2,610,000    40,250,000
Sewer Authority (WW)
Washington Township (WW)                      10,288,000                                                 5,466,300    5,150,000    20,904,300
South Dakota
Fall River Water Users System (North                                                 612,000             1,128,000      633,000     2,373,000
Expansion Project) (DW)
Fall River Water Users System                                                        750,000              958,000         6,391     1,714,391
(System Improvements Project) (DW)
Faulkton (DW)                                                                        500,000             2,124,000      668,175     3,292,175
Mobridge (DW)                                                                        500,000              931,000       407,000     1,838,000
Selby (DW)                                                                           100,000              514,000       310,900       924,900
Selby (WW)                                       $700,000                                               $1,815,000     $774,000    $3,289,000

                                         Legend: DW = drinking water project; WW = wastewater project

                                         Source: GAO analysis of federal, state, and local documents.


                                         Notes: Other indicates federal, state, and local funding sources not listed in this table. A blank cell
                                         indicates funding was not requested from the specific source. Other sources of funding include HUD’s
                                         Community Development Block Grant; state sources such as Montana’s Treasure State Endowment
                                         Fund; programs from the North Carolina Rural Economic Development Center; and the community’s
                                         own reserve funds.

                                         We selected communities and projects on the basis of funding data and recommendations provided
                                         by state officials. Because these are nongeneralizable samples, the information obtained cannot be
                                         generalized to all communities or projects but provides illustrative examples of community
                                         experiences in applying for funding from the EPA and USDA programs. See appendix I for additional
                                         details.




                                         Page 21                                                               GAO-13-111 Rural Water Infrastructure
Fragmentation and                Program overlap among the state SRF and RUS programs can result in
Overlap in State SRF and         potential duplication of communities’ efforts to prepare funding
RUS Programs Can Result          applications and related documents, including preliminary engineering
                                 reports and environmental analyses, according to our analysis of project
in Potentially Duplicative       documents and interviews with engineers and community officials in the
Application Efforts by           five states we visited. In these states, as with others, the state SRF and
Communities                      RUS programs require the communities to submit a preliminary
                                 engineering report and an environmental analysis as part of their loan
                                 applications.

Preliminary Engineering Report   Preliminary engineering reports submitted by communities to the SRF
                                 and RUS programs contained many of the same components, but the
                                 format and the level of detail required varied. Table 3 shows the similar or
                                 common components included in these preliminary engineering reports of
                                 four projects we reviewed. We judgmentally selected an example from
                                 one community in each state that had at least one jointly funded project or
                                 that had applied to both programs for funding, and that prepared
                                 preliminary engineering reports.22




                                 22
                                   In Pennsylvania, agencies prepare technical documents, called Act 537 Plans, for
                                 wastewater infrastructure projects. These documents are required by Pennsylvania state
                                 law and include similar information to preliminary engineering reports. According to
                                 Pennsylvania officials, communities applying for funds for drinking water infrastructure
                                 projects are required to submit a typical preliminary engineering report, but they told us
                                 they have not jointly funded a drinking water project for several years.




                                 Page 22                                              GAO-13-111 Rural Water Infrastructure
Table 3: Similarities in Components of Preliminary Engineering Reports Prepared for the SRF and RUS Programs for Four
Selected Projects

                                   Pagosa Springs, CO      Tuckaseigee Authority,     Faulkton, SDa        Conrad, MTa
                                      Wastewater              NC Wastewater           Drinking Water       Wastewater
Report component                     SRF            RUS        SRF          RUS          SRF/RUS             SRF/RUS
Project planning area /
summary
Location                              X              X                       X              X                    X
Environmental resources               X              X                       X              X                    X
present
     Wetlands                         X              X                                                           X
     100-year floodplain              X              X                                                           X
     analysis
     500-year floodplain                             X
     analysis
Growth areas and population           X              X          X            X              X                    X
trends
Existing facilities
Location                              X              X                       X              X                    X
History                               X              X          X            X              X                    X
Condition of facilities               X              X          X            X              X                    X
Financial status of any existing      X              X                       X                                   X
facilities
Need for or purpose of
project
Health, safety, and                   X              X                       X              X                    X
security/compliance
System operation and                  X              X                       X              X                    X
maintenance
Growth                                X              X          X            X              X
Alternative approaches
Description of alternatives           X              X          X            X              X                    X
Design criteria                       X              X                       X                                   X
Environmental impacts                 X              X          X            X                                   X
Land requirements/site                X              X                       X                                   X
selection
Construction problems                 X              X                       X                                   X
Cost estimates                        X              X          X            X              X                    X
Advantages and disadvantages          X              X          X            X                                   X
of alternatives




                                          Page 23                                      GAO-13-111 Rural Water Infrastructure
                              Pagosa Springs, CO                    Tuckaseigee Authority,               Faulkton, SDa        Conrad, MTa
                                 Wastewater                            NC Wastewater                     Drinking Water       Wastewater
Report component                SRF                RUS                     SRF                 RUS         SRF/RUS              SRF/RUS
Proposed project
Project design                   X                   X                                               X         X                    X
Project cost estimates           X                   X                       X                       X         X                    X
Annual operating budget                              X                       X                       X         X                    X
    Income                                           X                       X                       X         X                    X
    Operations and               X                   X                       X                       X         X                    X
    maintenance costs
    Debt repayments/service                          X                       X                       X         X                    X
Reserves                                             X                                                         X
Short-lived assetsb                                  X                                               X         X
Conclusions and                  X                   X                                               X         X                    X
recommendations
Preliminary implementation       X                   X                                                         X                    X
schedule
                                     Sources: GAO analysis of federal, state, and local documents.

                                     a
                                      This community produced one preliminary engineering report and submitted it to both programs.
                                     b
                                      Short-lived assets, for the purpose of these preliminary engineering reports, include equipment that
                                     have a planned life less than the repayment period of the loan.

                                     As table 3 shows, the preliminary engineering reports for both programs
                                     asked for similar information such as project location, community growth
                                     and population, existing facilities, alternative approaches to the project,
                                     and environmental and technical details of the project. The preliminary
                                     engineering reports prepared for the RUS program also included
                                     information on debt service and short-lived assets—those assets that
                                     have a planned life less than the repayment period of the loan—while the
                                     SRF engineering reports did not include such information.

                                     Engineers and community officials we interviewed in some states told us
                                     that they prepare separate preliminary engineering reports for each
                                     agency when a community applies for funding from both agencies, which
                                     can increase costs to the communities. Specifically, officials and
                                     engineers in some states told us the requirements for USDA’s RUS
                                     preliminary engineering report are generally more rigorous. They stated
                                     that these reports contain similar information but with different formats
                                     and levels of detail. Examples are as follows:

                                          In North Carolina, engineers and a technical service provider we
                                           interviewed told us that the state SRF and RUS formats for the



                                     Page 24                                                              GAO-13-111 Rural Water Infrastructure
                             preliminary engineering reports differed significantly in format but
                             contained much of the same information. State officials told us the
                             state SRF programs do not typically accept preliminary engineering
                             reports completed for the state-level RUS program because they try to
                             maintain a common format to enable efficient review. Similarly, the
                             state-level RUS program officials said that they do not accept reports
                             completed for the state SRF programs.

                            In Colorado, an engineer for several projects we reviewed told us that
                             the engineering firm had to complete preliminary engineering reports
                             for both the state SRF programs and the RUS program even though
                             the reports had similar formats and information.

                            In South Dakota, engineers told us that to minimize effort, time, and
                             cost to the community, they prepare preliminary engineering reports to
                             meet state SRF, RUS, and other program requirements even if the
                             community does not initially seek funds from all of these programs.
                             These engineers said doing so helps minimize the additional effort it
                             would take to revise the report at a later time if the community decided
                             to seek additional funds. According to another engineer, if the
                             preliminary engineering report is completed to meet just the SRF
                             programs’ requirements, the firm will require additional time and
                             money to meet the additional preliminary engineering report
                             requirements necessary to apply for funding through the RUS
                             program.

                         Montana and Pennsylvania take a different approach than the other three
                         states we visited as follows:

                            Montana has a uniform preliminary engineering report accepted by
                             most federal and state agencies. Engineers said that the agencies ask
                             for some different information, which they gather in amendments to
                             the report instead of having communities submit similar information
                             multiple times.

                            In Pennsylvania, officials from state SRF and state-level RUS
                             programs said they encourage communities to apply to either the SRF
                             or RUS programs and do not often jointly fund projects. Officials from
                             both programs told us that when they do fund projects jointly, they try
                             to accept one another’s documents to avoid duplicating them.

Environmental Analysis   We also found similarities in the environmental analyses submitted by
                         communities to the SRF and RUS programs for four of the projects in the
                         states we visited. According to our review of environmental analyses


                         Page 25                                     GAO-13-111 Rural Water Infrastructure
                                          submitted to the state SRF and RUS programs—we judgmentally
                                          selected one in each of four communities and states that had jointly
                                          funded projects or applied to both programs for funding—each
                                          environmental analysis followed a similar overall format and contained
                                          many of the same components, but the level of analysis and the level of
                                          detail needed to satisfy federal and state requirements varied. Table 4
                                          shows the overall format and similar components for these environmental
                                          analyses. The agencies ask for information on many of the same
                                          components, including purpose and need, alternatives analysis, and
                                          environmental consequences.

Table 4: Similarities in Components of Environmental Analyses Submitted to the SRF and RUS Programs for Four Selected
Projects

                                                 Conrad, MT                    Selby, SDa         Mack, CO             Hertford, NC
                                                                                                                                    a

                                                 Wastewater                  Drinking Water      Wastewater            Drinking Water
Component                                       SRF          RUS                 SRF/RUS        SRF        RUS             SRF/RUS
Purpose and need                                  X            X                                  X          X                 X
Alternatives analysis                             X            X                       X          X          X                 X
Environmental consequences
    Land use /geology                             X            X                       X          X          X                 X
    Floodplains                                   X            X                       X          X          X                 X
    Wetlands                                      X            X                       X          X          X                 X
    Cultural resources and historic               X            X                       X          X          X                 X
    properties
    Biological resources                          X            X                       X          X          X                 X
    Water quality/quantity                        X            X                       X          X          X                 X
    Coastal resources                                                                                        X                 X
    Air quality                                   X            X                       X          X          X                 X
    Transportation                                                                     X                     X                 X
    Noise                                         X            X                       X          X          X                 X
    Socioeconomic/environmental justice                                                X          X          X                 X
Mitigation strategy                               X            X                       X          X          X                 X
                                          Sources: GAO analysis of state SRF and RUS data.

                                          a
                                          Other agencies accepted the SRF environmental analysis for this project.


                                          The extent to which communities duplicate their environmental analyses
                                          for each program varies by state, depending on the extent to which water
                                          and wastewater infrastructure programs in the state accept each other’s
                                          work or use each other’s documents. In Colorado, North Carolina, and
                                          South Dakota, the communities can submit the final approved



                                          Page 26                                                     GAO-13-111 Rural Water Infrastructure
environmental analyses prepared for the RUS program to the SRF
programs, which eliminates one of the documents they have to prepare.
However, in these states, the state-level RUS program will not typically
accept the analysis prepared for the SRF program because the state
analyses are less rigorous, according to RUS officials. In Pennsylvania,
the state programs have agreed to uniform environmental requirements,
and the communities therefore submit the same document to both
programs. Communities may be required to submit additional information,
as needed, to meet requirements specific to each program. In Montana,
the state SRF programs prepare an environmental analysis for the
community that is primarily based on information that the community
submits in the preliminary engineering report, but the community prepares
the environmental analysis that it submits to the state RUS program.

Furthermore, in some cases, the state programs may require the same
type of environmental analysis for a project but, in other cases, the state
programs may require different levels of environmental analysis—such as
a categorical exclusion. For example, for a single wastewater project, the
town of Conrad, Montana, completed an environmental analysis for the
state-level RUS program, while the state SRF program completed the
environmental analysis for the town. In contrast, Pagosa Springs,
Colorado, submitted an environmental checklist to the state SRF program
for its wastewater project and received a categorical exclusion but had to
submit an environmental analysis for the application it submitted to the
state-level RUS program for the same project. Variation exists across
states despite NEPA regulations stating that federal agencies should
eliminate duplication with state and local procedures by providing for joint
preparation of environmental analyses or by adopting appropriate
environmental analyses. According to state SRF officials, state-level RUS
officials do not always accept state analyses because NEPA regulations
under the RUS program are rigid and because some state RUS officials
are not flexible in their interpretation of the requirements for
environmental analyses. State RUS officials, however, told us that
environmental analyses by some state environmental programs are not
sufficient to meet federal NEPA standards, making it difficult for them to
accept these environmental analyses.

Potentially duplicative application requirements, including preliminary
engineering reports and environmental analyses, may make it more costly
and time-consuming for communities to complete the application process.
For example, if consulting engineers have to provide similar, or even the
same, information, in two different engineering reports or environmental
analyses, their fees to the community may be higher. Engineers we


Page 27                                     GAO-13-111 Rural Water Infrastructure
                            interviewed estimated that preparing additional preliminary engineering
                            work could cost anywhere from $5,000 to $50,000 and that the cost of an
                            environmental analysis could add as little as $500 to a community’s costs
                            or as much as $15,000. Moreover, having to complete separate
                            preliminary engineering reports or environmental analyses may delay a
                            project because of the additional time required to complete and submit
                            these documents. State officials in Montana told us that coordination
                            between federal and state programs and the implementation of uniform
                            application requirements could reduce the time it takes an applicant to
                            complete a rural water infrastructure project by up to half.


                            Our review of five states and local communities in those states showed
Federal and State           that EPA and USDA have taken some actions to coordinate their
Actions Have Not            programs and funding at the federal and state level to help meet the
                            water infrastructure needs of rural communities, but not others specified
Fully Facilitated           in the 1997 memorandum. Because these federal programs are
Coordination for            implemented at the state level, efforts to coordinate between the agencies
Funding                     primarily occur among state officials managing the SRF and other water
                            infrastructure programs, the RUS state-level offices, and the communities
Communities’                whose projects they fund. In some cases, inconsistent coordination at the
Projects                    state level has led to potential duplication for communities applying for
                            funding and inefficiencies in program funding. EPA and USDA, at the
                            federal level, and the state SRF and RUS state-level offices, have taken
                            some actions to coordinate but have not taken others that could help
                            avoid duplication of effort by communities applying for project funding.


Agencies Have Taken         Recognizing the importance of coordinating the SRF and RUS programs
Some Actions to             at the state level, EPA and USDA agencies have taken some actions at
Encourage Coordination at   the federal level to encourage coordination between the state-level
                            programs and communities but not other actions specified in the 1997
the State and Community     memorandum. The 1997 joint memorandum signed by EPA and the
Level but Not Others        USDA sought to improve coordination among federal and state agencies
                            as they help fund community projects. It identified four major actions that
                            state and state-level federal offices can take to improve coordination and
                            reduce inefficiencies and potential duplication of effort. These actions are
                            consistent with several of the leading practices we identified in our




                            Page 28                                      GAO-13-111 Rural Water Infrastructure
October 2005 report on interagency collaboration.23 These actions are as
follows:

Cooperate in preparing planning documents. The memorandum
encourages state SRF and RUS programs to cooperate in preparing
planning documents, including operating, intended use, and strategic
plans that are required under each agency’s programs. The
memorandum says that the federal and state programs should endeavor
to incorporate portions of each agency’s planning documents to minimize
duplication of planning efforts. This action is consistent with two leading
practices for interagency collaboration identified in our previous work—
defining and articulating common outcomes and developing joint
strategies—through which partner agencies can overcome significant
differences in agency missions and cultures, and align their activities and
resources to accomplish common goals.

Cooperate to remove policy and regulatory barriers. The memorandum
states that agencies should cooperate in removing as many barriers to
coordination as possible in program regulations or policy by, for example,
coordinating project selection systems and funding cycles. This action is
consistent with a leading practice for interagency collaboration identified
in our previous work—promoting compatible policies and procedures.

Cooperate on project funding. The joint memorandum encourages state
SRF and state-level RUS officials to meet on a regular basis to cooperate
in determining what projects will receive funding and which program
should fund which project, and to discuss the possibility of jointly funding
projects when necessary. This action is consistent with two of the leading
practices for interagency collaboration identified in our previous work—
agreeing upon roles and responsibilities and leveraging resources.
Through such actions, federal and state agencies funding water and
wastewater infrastructure can clarify which agencies will be responsible
for taking various steps and for organizing joint and individual agency
efforts and thereby obtain benefits that they would not have realized by
working individually.

Cooperate in preparing environmental analyses and meeting other
common federal requirements. The joint memorandum states that,



23
 GAO-06-15.




Page 29                                     GAO-13-111 Rural Water Infrastructure
whenever possible, agencies should cooperate on federal requirements
that are common across agencies—environmental analyses and other
common documents, such as preliminary engineering reports—in order to
create one comprehensive application package per project. This action is
consistent with our leading practice for interagency collaboration of
establishing compatible policies and procedures for operating across
agency boundaries. Through such an action, federal and state agencies
would seek to make policies and procedures more compatible.

In February 2012, EPA, USDA, and several other federal and state
agencies created a working group to examine the feasibility of developing
uniform guidelines for preliminary engineering report requirements. The
group plans to develop a draft outline for uniform preliminary engineering
report guidelines by September 2012 and has received numerous
examples and comments from participating states. According to RUS
officials, however, once the draft outline is developed it must be reviewed
by participating state and federal agencies before it is considered final,
and the final outline could be delayed if agency review and response
times are slow. In addition, EPA and USDA have taken action at the
federal level to help the states coordinate better and make programs
more efficient for communities applying for funding. Specifically, EPA and
USDA coordinate at the federal level to encourage states to emphasize
coordination between their SRF programs and RUS, as well as with local
communities. According to EPA and USDA officials, to inform state
officials and communities about the programs and funding opportunities
available in their respective states, the federal agencies participate in
conferences and workshops, conduct Webinars, and sponsor training.
The federal agencies also issue guidance to their programs. For example,
EPA issued a report in 2003 providing case studies and innovative
approaches on how state SRF programs could better coordinate with
other programs with similar purposes. In addition, in June 2011, EPA and
USDA signed a Memorandum of Agreement to work together to help
communities implement innovative strategies and tools to achieve short-
and long-term water and wastewater infrastructure sustainability. Among
other things, the memorandum encourages the agencies to share and
distribute resources and tools to communities that promote long-term
sustainability and to provide training and information that encourages the
adoption and adaptation of effective water infrastructure management
strategies.

The actions that EPA and USDA have taken to date, such as providing
guidance in the 1997 memorandum, have helped states and state-level
federal agencies to coordinate generally but have not facilitated better


Page 30                                     GAO-13-111 Rural Water Infrastructure
                            coordination at the state level in more specific ways. In particular, the
                            federal agencies have not taken actions, highlighted in the 1997
                            memorandum, to develop common documents for communities to apply
                            to different funding programs. For example, EPA and USDA have not
                            created a working group or taken similar action to work with other federal
                            and state officials to develop a uniform environmental analysis. Making
                            environmental analyses more compatible would be consistent with the
                            March 2012 Council on Environmental Quality guidance on eliminating
                            duplication in federal NEPA efforts. Similar to the 1997 joint
                            memorandum, Council of Environmental Quality NEPA regulations and
                            guidance encourage coordination between state and federal agencies in
                            preparing environmental documents to reduce the time and cost required
                            to make federal permitting and review decisions while improving
                            outcomes for communities and the environment. According to agency
                            officials, the agencies have not taken such action because they believe
                            they have coordinated sufficiently. According to EPA officials, the states
                            conduct NEPA-like analyses but are not required to meet the same NEPA
                            requirements as federal agencies, and EPA cannot therefore dictate what
                            documents the states use. In addition, USDA officials said that the RUS
                            program’s NEPA guidance documents already encourage state-level
                            RUS offices to coordinate with the state SRF programs to accept RUS’s
                            environmental analyses, as appropriate and consistent with guidance
                            from the Council on Environmental Quality. Without agreement to use
                            common environmental analyses, however, rural communities could
                            continue to spend more effort and resources to meet application
                            requirements for improving their water and wastewater infrastructure.


State-Level Programs Took   In the five states we visited, the state-level programs varied in the actions
Varied Actions to           they took to coordinate their water and wastewater infrastructure
Coordinate in Five States   programs consistent with the 1997 joint memorandum. In some states,
                            the state SRF and RUS programs have developed innovative ways to
We Visited                  coordinate and remove barriers to coordination consistent with the 1997
                            memorandum but, in other states, the state SRF and RUS programs have
                            been less successful, leading to potential duplication for communities
                            applying for funding and inefficiencies in program funding. Table 5 shows
                            the extent of actions to coordinate taken by the state SRF programs and
                            state-level RUS programs in the five states we visited. Some community
                            officials we met with suggested that, for the drinking water and
                            wastewater infrastructure programs, good coordination among state
                            officials would involve meeting on a regular basis to cooperate in
                            determining what projects would receive funding, thereby leveraging
                            agency funds that are increasingly limited.


                            Page 31                                      GAO-13-111 Rural Water Infrastructure
Table 5: State SRF and RUS Program Activities to Implement 1997 Joint Memorandum on Drinking Water and Wastewater
Activities

                                                        Activities to Implement 1997 Joint Memorandum
                                                                                          Cooperate on preparation
                                                                                          of environmental
                            Cooperate in       Cooperate to remove                        analysis documents and
                            preparing planning regulatory and policy Cooperate on project other common federal
States                      documents          barriers              funding              requirements
Colorado                    No                        No                                  Partial          No
Montana                     No                        Yes                                 Yes              Partial
North Carolina              No                        No                                  Partial          No
Pennsylvania                No                        Yes                                 Partial          Partial
South Dakota                No                        Yes                                 Yes              No
                                       Sources: GAO analysis of state documents and interviews.


                                       In the five states we visited, the state SRF and state-level RUS programs
                                       varied in the number and types of action they had taken to coordinate, as
                                       described in the memorandum. However, the state-level programs did not
                                       take actions to cooperate in preparing planning documents. The extent of
                                       actions taken by the five states consistent with the memorandum are as
                                       follows:

                                       Cooperate in preparing planning documents. In the states we visited,
                                       state SRF and RUS programs do not regularly coordinate when
                                       developing agency-specific planning documents. State SRF officials
                                       identify the projects that apply to their program in planning documents
                                       called intended use plans. In these plans, the states rank projects using
                                       state-determined criteria following EPA guidance, such as environmental
                                       and health concerns. Similarly, state-level RUS officials develop funding
                                       plans in which they separately rank projects applying to their program
                                       using national criteria that focus primarily on economic development, as
                                       well as environmental and health concerns.

                                       Cooperate to remove policy and regulatory barriers. The state SRF and
                                       RUS programs in three of the states we visited had cooperated to remove
                                       policy barriers to coordination, such as differences in funding cycles.
                                       Specifically, in those states, federal and state officials meet regularly to
                                       ensure funding cycles are aligned to avoid unnecessary project delays.
                                       For example, in South Dakota, the state’s SRF and other state water and
                                       wastewater infrastructure funding programs have the same funding cycles
                                       and application timelines, which are administered by one agency. State
                                       and local officials told us that having the state funding programs aligned



                                       Page 32                                                      GAO-13-111 Rural Water Infrastructure
made it easier to navigate differences in funding cycles with RUS and
other federal funding programs operating in the state. In addition,
Montana officials created a working group to share information across
state water and wastewater infrastructure programs and coordinate
funding cycles. State and local officials in Montana said that regular
coordination between federal and state officials on individual projects
helped manage programmatic differences, such as differing funding
cycles, to avoid lengthy delays in funding projects. Officials and engineers
in both states said that the benefits of these joint efforts included
reductions in community costs and administrative burdens for submitting
applications and related documents, as well as reductions in the federal
and state agencies’ time in reviewing the documents. Other states have
not worked to remove policy and regulatory barriers to coordination. For
example, state and local officials in North Carolina told us that differences
in application processes and funding cycles for the federal and state
programs, including state SRF programs and the RUS program,
increased the complexity and cost of applying for funding. Multiple
agencies in the state that fund drinking water and wastewater
infrastructure projects, including the SRF programs, have different
funding cycles, so that communities have to apply separately to each
program and at different times to make the project affordable. State and
local officials in Colorado told us that they faced similar barriers.

Cooperate on project funding. Officials in all the states we visited meet at
various times during the year, although some meet more frequently and
discuss project funding in greater detail. Officials in Montana and South
Dakota told us that they meet regularly to discuss upcoming projects,
project applications, and coordination of funding, when possible. For
example, officials from federal and state drinking water and wastewater
funding programs in the Montana working group share information and
discuss current projects and communities applying for funding.
Community representatives said that state SRF program officials hold
monthly meetings between the applicant and other state and federal
funders to ensure that adequate funding is available to keep the project
moving forward and to resolve any differences between the community
and the federal and state programs providing funding. Similarly, in South
Dakota, officials for the state SRF and RUS programs told us that they
discuss project applications routinely and work closely with officials from
local planning districts who, in turn, use their expertise working with
federal and state programs to help communities apply for funding. In
Pennsylvania, the state SRF and state-level RUS programs coordinate
early in the application process by (1) conducting joint outreach sessions
with communities interested in applying for drinking water and wastewater


Page 33                                      GAO-13-111 Rural Water Infrastructure
project funding and (2) directing communities to the program that better
fits their needs, according to state officials we spoke with. State-level
officials and engineers we spoke with identified improvements in the
efficiency and effectiveness of the programs because the officials direct
communities to the program that best fits their needs or provides the best
opportunity for a successful application.

Officials in Colorado and North Carolina also meet but do not regularly
discuss project funding or the communities that have applied for funding,
and said that they have experienced lapses in program efficiency and
effectiveness, such as loss of federal funding for the state. Officials in
both states told us coordination is complicated by communities not
disclosing that they have applied to other state or federal programs for
funding. Specifically, according to federal and state officials, in some
cases, communities and the consulting engineers representing them will
sign a funding agreement with either the state SRF or state-level RUS
program but continue to seek additional grant or subsidized loan funding
from other state and federal programs to get additional grant funding or
better loan terms. State SRF and state-level RUS program officials in
North Carolina and Colorado told us that not disclosing multiple funding
sources can lead to inefficiencies when state SRF program officials and
state-level RUS officials are unaware that a community has applied to
both programs. Specifically, state-level officials who administer the RUS
program in North Carolina and Colorado reported having to or expecting
to deobligate a total of more than $20 million that they had committed to
fully fund projects because they were unaware that the state SRF
programs had committed to fully fund the same projects. The state-level
RUS program in North Carolina expects to have to deobligate funding for
three projects totaling about $4.9 million in loan and grant funding, and
the RUS program in Colorado had to deobligate funding for seven
projects totaling $15.6 million. The two RUS state offices could not meet
internal agency deadlines to fully obligate their available funds and, as a
result, had to return these funds to the RUS headquarters pool. State
officials in North Carolina recently developed a uniform cover sheet for all
state drinking water and wastewater funding program applications that
asks communities to disclose other sources of funding. However, in our
review of the uniform cover sheet, applicants are not asked to provide
information on funding requested from RUS and other federal drinking
water and wastewater funding programs.

Cooperate in preparing environmental analyses documents and other
common federal requirements. In our visits to Montana and Pennsylvania,
we learned that federal and state programs, including the state SRF and


Page 34                                     GAO-13-111 Rural Water Infrastructure
              RUS programs, have coordinated to streamline the application process in
              their states. For example, in Montana, these programs coordinated to
              develop uniform application materials and preliminary engineering report
              requirements that are accepted by all federal and state water and
              wastewater infrastructure programs in the state. Similarly, in
              Pennsylvania, program officials agreed upon uniform environmental
              analyses that are accepted by all programs, which reduce the cost and
              time for completing applications. Other states we visited have not agreed
              on uniform application requirements. According to federal and state
              officials in Colorado, North Carolina, and South Dakota, the state SRF
              and RUS programs have not developed documents with common formats
              and requirements for drinking water and wastewater infrastructure
              projects because of difficulty in integrating multiple program requirements.
              Specifically, state and local officials said that much of the information
              required in the environmental analyses was the same, but that agencies
              could not agree on a standard format and level of detail. For example,
              state SRF and RUS program officials in Montana told us they had tried,
              but were unable, to develop a uniform format for the presentation of their
              environmental analyses even though they had done so for their
              preliminary engineering reports. Furthermore, officials in Colorado and
              North Carolina expressed concern that having uniform documents that
              incorporated both state SRF and RUS program requirements would slow
              the application processes for all three programs and make them more
              costly. Specifically, officials administering both of the state SRF programs
              were concerned that, by adopting a format compatible with RUS policies
              and procedures, they would make the state SRF application process
              more onerous.


              Rural communities rely on federal grants and loans to meet their water
Conclusions   and wastewater infrastructure needs and to keep their drinking water and
              sewer user rates affordable. It is therefore important to make the most
              efficient use of limited federal funds to help as many communities as
              possible and to eliminate potential duplication of effort by communities
              when they apply for funds. EPA and USDA recognized in a 1997
              memorandum that it is necessary to more effectively and efficiently
              coordinate the SRF and RUS programs at the state level through four
              major actions: in preparing planning documents, removing policy and
              regulatory barriers, meeting regularly to discuss project funding, and
              preparing common environmental analyses and other common federal
              requirements. In addition, EPA and USDA have taken actions to
              encourage states to improve coordination over the past 15 years.
              Specifically, recent actions by EPA and USDA, such as their efforts to


              Page 35                                     GAO-13-111 Rural Water Infrastructure
                      inform state officials and communities about the programs and funding
                      opportunities by participating in conferences and workshops, conducting
                      Webinars, and sponsoring training, as well as creating a working group to
                      examine the possibility of developing guidelines to assist states in
                      developing uniform preliminary engineering reports to meet requirements
                      for federal and state programs, are encouraging and will help
                      communities. However, the guidelines have not yet been completed, and
                      EPA and USDA have not initiated a similar effort to develop guidelines for
                      uniform environmental analyses that can be used to meet federal and
                      state requirements. Without uniform documents, rural communities face a
                      continuing burden and additional costs when applying for federal funds to
                      improve their water and wastewater infrastructure. The state-level
                      programs in the five states we reviewed varied in the number and types of
                      actions they had taken to coordinate across the four key areas in the
                      1997 memorandum. Some state-level programs have developed
                      innovative ways to coordinate and remove barriers to coordination, but in
                      other states, the programs have been less successful, warranting
                      stronger federal attention. Moreover, the state-level programs did not take
                      actions to cooperate in preparing planning documents in any of the
                      states. Until the state-level programs are regularly coordinating across the
                      four key areas in the 1997 memorandum, including when developing
                      planning documents, they will continue to risk potential program
                      inefficiencies. Additional delays in taking actions to help improve such
                      coordination could prevent EPA and USDA from more effectively and
                      efficiently providing limited resources to needy communities.


                      To improve coordination and to reduce the potential for inefficiencies and
Recommendations for   duplication of effort, we recommend that the Secretary of Agriculture and
Executive Action      the Administrator of EPA take the following three actions:

                         ensure the timely completion of the interagency effort to develop
                          guidelines to assist states in developing their own uniform preliminary
                          engineering reports to meet federal and state requirements;

                         work together and with state and community officials to develop
                          guidelines to assist states in developing uniform environmental
                          analyses that could be used, to the extent appropriate, to meet state
                          and federal requirements for water and wastewater infrastructure
                          projects; and

                         work together and with state and community officials through
                          conferences and workshops, Webinars, and sponsored training to



                      Page 36                                     GAO-13-111 Rural Water Infrastructure
                         reemphasize the importance of coordinating in all four key areas in
                         the 1997 memorandum.

                     We provided EPA and USDA with a draft of this report for their review and
Agency Comments      comment, and both agencies provided written comments. EPA neither
and Our Evaluation   agreed nor disagreed with our first two recommendations but concurred
                     with the third. USDA neither agreed nor disagreed with any of our
                     recommendations. EPA’s comments are provided in appendix III and
                     USDA’s comments are provided in appendix IV. Both agencies made
                     technical comments that we incorporated as appropriate. In addition, we
                     sent relevant portions of this report to state or federal officials responsible
                     for administering the state SRF programs and state-level RUS programs
                     for their review and technical comment.

                     In its comments on our first recommendation, that the agencies complete
                     their efforts to develop uniform requirements for preliminary engineering
                     reports, EPA stated that it supported the intent of the recommendation but
                     noted it does not have the authority to require states to adopt a required
                     format and that some states may not utilize it. EPA recommended that we
                     replace the word “requirements” with the word “format.” USDA also
                     indicated that EPA and HUD have no authority to require state
                     governments to use a particular preliminary engineering report outline
                     and requested that we therefore change the word “requirements” to the
                     word “guidelines.” We recognize and agree that states have discretion to
                     develop their own requirements for their SRF programs. In making our
                     recommendations, we did not intend to limit states’ discretion in adopting
                     their own preliminary engineering report requirements. However, we
                     continue to believe that the federal agencies could do more to help states
                     identify common requirements for their own uniform preliminary
                     engineering report documents. We changed our recommendation to
                     reflect that the states do have discretion and that the federal agencies
                     should develop guidelines to help the states develop uniform preliminary
                     engineering report requirements.

                     In its comments on our second recommendation, to develop uniform
                     requirements for environmental analysis documents, EPA stated that in
                     principle it agreed with our recommendation but said it is not realistic to
                     develop a one-size-fits-all approach. EPA said that developing the
                     “essential elements” for environmental analyses should achieve the same
                     outcome and requested that we change the word “requirements” to
                     “essential elements.” USDA stated that it did not necessarily disagree
                     with the intent of the recommendation but noted that EPA has limited



                     Page 37                                       GAO-13-111 Rural Water Infrastructure
authority to dictate specific requirements to states implementing the SRF
program. It also identified several procedural and policy hurdles including
the fact that USDA’s NEPA requirements are typically more stringent than
the reviews under the SRF programs. USDA stated that it would work
with EPA to discuss the concept of unified reviews and identify what
would be required to achieve such reviews. USDA suggested that the
Council on Environmental Quality could be called on to facilitate a
working group between federal water and wastewater infrastructure
funding programs on NEPA implementation. In making our
recommendation, we did not intend to limit states’ discretion in adopting
their own requirements for environmental analyses. We changed the
wording of our recommendation to clarify that the agencies would develop
guidelines to assist states in developing common requirements for
environmental analyses. We also note that USDA’s suggestion for the
Council on Environmental Quality to facilitate a working group seems
reasonable but did not make this part of our recommendations because
we did not review the Council on Environmental Quality as part of our
work.

EPA concurred with our third recommendation, that the agencies work
together and with state and community officials in all four key areas of the
1997 memorandum, while USDA neither agreed nor disagreed with the
recommendation. EPA said that our report showed that little overlap
existed between the programs but that state-level coordination should be
encouraged more broadly. USDA said that it had no control over
communities that choose to change funding sources to a state SRF
program after accepting funding from the state-level RUS programs. We
understand that communities have the discretion to change funding
sources if better loan and grant terms are available, but strong
coordination can help the agencies know when communities are applying
to other programs and what other communities might need funding. Such
coordination, envisioned in the 1997 memorandum, can avoid the loss of
funds from states with high needs and other inefficiencies identified in this
report. Furthermore, as EPA confirmed in its comments, state-level
coordination can be encouraged more broadly to help other state and
federal water and wastewater infrastructure funding programs better
leverage limited state and federal funds.

Finally, in its general comments on the draft report, USDA commented on
GAO’s use of a relatively small sample of states for this review and that
the RUS programs in those states were experiencing a transition in
leadership and had not had time to develop relationships and learn other
agencies’ programs. We selected states that had high rural water and


Page 38                                      GAO-13-111 Rural Water Infrastructure
wastewater infrastructure needs and a range of experience coordinating
their water and wastewater infrastructure funding programs. We clearly
state in the report that the sample is small and that our results cannot be
generalized to all states. We recognize that the experience and trust
established through long-term relationships is critical to the establishment
of good coordination between federal and state programs. However,
given the amount of time the memorandum has been in place, we believe
that if good coordination between state SRF and state-level RUS
programs had been established prior to the transition in state-level RUS
leadership, it would have facilitated a smoother transition, and many of
the challenges identified in our report may have been avoided.


We will send copies of this report to the Administrator of EPA, the
Secretary of Agriculture, the appropriate congressional committees, and
other interested parties. In addition, the report will be available at no
charge on the GAO Web site at http://www.gao.gov. If you or your staff
members have any questions about this report, please contact me at
(202) 512-3841 or trimbled@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made major contributions to this report are
listed in appendix V.




David C. Trimble
Director
Natural Resources and Environment




Page 39                                     GAO-13-111 Rural Water Infrastructure
List of Congressional Addressees

The Honorable Daniel K. Inouye
Chairman
The Honorable Thad Cochran
Vice Chairman
Committee on Appropriations
United States Senate

The Honorable Kent Conrad
Chairman
The Honorable Jeff Sessions
Ranking Member
Committee on the Budget
United States Senate

The Honorable Joseph I. Lieberman
Chairman
The Honorable Susan M. Collins
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable James M. Inhofe
Ranking Member
Committee on Environment and Public Works
United States Senate

The Honorable Hal Rogers
Chairman
The Honorable Norm Dicks
Ranking Member
Committee on Appropriations
United States House of Representatives

The Honorable Paul Ryan
Chairman
The Honorable Chris Van Hollen
Ranking Member
Committee on the Budget
United States House of Representatives




Page 40                                  GAO-13-111 Rural Water Infrastructure
The Honorable Darrell Issa
Chairman
The Honorable Elijah Cummings
Ranking Member
Committee on Oversight and Government Reform
United States House of Representatives

The Honorable Bob Gibbs
Chairman
The Honorable Tim Bishop
Ranking Member
Subcommittee on Water Resources
and Environment
Committee on Transportation and Infrastructure
House of Representatives

The Honorable Scott Brown
United States Senate

The Honorable Tom Coburn
United States Senate

The Honorable Claire McCaskill
United States Senate

The Honorable Mark R. Warner
United States Senate




Page 41                                  GAO-13-111 Rural Water Infrastructure
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              The objectives of this report examine (1) the potential for fragmentation,
              overlap, and duplication between the Environmental Protection Agency’s
              (EPA) Drinking Water and Clean Water State Revolving Fund (SRF)
              programs and the U.S. Department of Agriculture’s (USDA) Rural Utilities
              Service (RUS) Water and Wastewater Disposal program, both of which
              address water and wastewater infrastructure needs in rural communities,
              and (2) the extent to which these programs coordinate with each other at
              the federal and state level to help meet the water infrastructure needs of
              rural communities. We selected these programs for this review because
              they provided the highest amount of federal funds to water and
              wastewater infrastructure projects, which include projects in rural
              communities—defined for this report as communities with populations of
              10,000 or less—in fiscal year 2011. The federal government has not
              established a formal or consistent definition of what constitutes a rural
              community; however, RUS defines a rural community as having a
              population of 10,000 or less. EPA, although it does not define
              communities as rural, gathers data on funding to communities of various
              sizes, including communities with populations of 10,000 or less. For both
              agencies, communities can include entities such as towns, cities, or
              counties, which make the decision whether to apply for funding from the
              programs. In some cases, regional water utilities or other utility
              associations can apply on behalf of a community or a group of
              communities. Using this definition allowed us to obtain and analyze
              similar data from both agencies.

              To address both objectives, we reviewed government reports, statutes,
              regulations, guidance, budgets, and other relevant documents to identify
              federal support for rural water infrastructure programs and specifically the
              support provided by the Clean Water SRF, Drinking Water SRF, and RUS
              programs. In addition, we interviewed officials from EPA and USDA and
              from relevant nonprofit organizations, including the environmental finance
              center at Boise State University and the Council of Infrastructure
              Financing Authorities to collect financial and other information on the
              extent of fragmentation, overlap, duplication, and coordination among
              these rural water funding programs, as well as the current challenges
              facing rural communities. We then selected a nongeneralizable sample of
              five states to visit—Colorado, Montana, North Carolina, Pennsylvania,
              and South Dakota—to review the extent of fragmentation, overlap, and
              duplication among the EPA and USDA programs and the extent of
              coordination among the programs at the state level. The information from
              this sample cannot be generalized to all states but provides illustrative
              examples of their experiences in applying for funding from the EPA and
              USDA programs. We conducted site visits to these states to observe


              Page 42                                     GAO-13-111 Rural Water Infrastructure
Appendix I: Objectives, Scope, and
Methodology




federally funded projects, discuss the funding process, and discuss
community experiences applying for funding from the EPA and USDA
programs. In each state, we judgmentally selected a nongeneralizable
sample of communities to visit and projects to observe by analyzing lists
of water and wastewater infrastructure projects we obtained from state
SRF and state-level RUS program officials, and obtaining
recommendations from officials we interviewed. We used the lists of
projects to identify communities and projects that had applied for or
received funding from the state SRF and RUS programs, or both. We
reviewed a total of 54 projects in a total of 31 communities across five
states, all of which had experience in applying for funds for a drinking
water or wastewater project, or both, from the SRF or RUS programs. As
with the state sample, the information from the communities and projects
we selected cannot be generalized to other communities and projects but
provide illustrative examples.

To address the first objective, we assessed fragmentation between the
Clean Water SRF, Drinking Water SRF, and RUS programs by examining
statutes, regulations, and guidance relevant to the programs. To
determine overlap between the programs, we calculated the proportion of
SRF funding that was allocated to communities with populations of
10,000 or less for state fiscal years 2007 through 2011 (state fiscal years
generally start in July and end in June). We used data from EPA’s
National Information Management System (NIMS), which collects and
summarizes data on Clean Water and Drinking Water SRF program
funding directed to communities of populations of all sizes, including
communities with populations of 10,000 or less by states—the same size
of communities toward which RUS directs its funding.1 We conducted
interviews with EPA officials to assess the reliability of the NIMS data and
found it reliable for our purposes of identifying state SRF funding for
communities with populations of 10,000 or less. We compared this
proportion of SRF funding with total RUS funding provided from USDA’s
accounting system. We interviewed RUS officials about how these
funding data are maintained and determined that it was reliable for our
purposes of identifying USDA funding for communities with populations of
10,000 or less.



1
 Data for the Drinking Water SRF program are reported for communities with populations
of 10,000 or less. Data for the Clean Water SRF program are reported for communities
with populations of 9,999 or less.




Page 43                                            GAO-13-111 Rural Water Infrastructure
Appendix I: Objectives, Scope, and
Methodology




To determine the potential for duplication at the project and activity level,
we collected funding data for projects that had been funded by the state
SRF programs, the state-level RUS programs, or both, as well as funding
data from the communities we visited or whose officials we spoke with. In
addition, we spoke with state SRF, state-level RUS, and community
officials and consulting engineers to assess the extent to which projects
were funded separately by state SRF or state-level RUS programs, or
were jointly funded by these programs, and what activities were
conducted. Duplication occurs when two or more agencies or programs
are engaged in the same activities or provide the same services to the
same recipients; however, in some instances, duplication may be
warranted because of the magnitude or nature of the federal effort.
Further, we collected and analyzed application materials—preliminary
engineering reports and environmental analyses—from communities if the
community had a project that was jointly funded by both the SRF and
RUS programs or had applied to both programs for the same project. On
the basis of this criterion, we obtained preliminary engineering reports for
four projects in four states and environmental analyses for four projects in
the same four states. To analyze the documents, we identified the
components of each document and compared them with the others to
determine those that were similar and different. We spoke with consulting
engineers in those communities to determine whether the communities
were required to submit separate documents with similar information to
both programs. Because of the limited size of each sample, the results of
our analysis are not generalizeable to all such documents.

To address the second objective, we reviewed documents and initiatives,
including a 1997 joint memorandum signed by EPA and USDA promoting
better coordination between the state SRF and state-level RUS programs
and interviewed headquarters officials at EPA and USDA to identify
national efforts to encourage better coordination at the state level. To
analyze whether EPA and USDA efforts and initiatives incorporated
leading practices for interagency collaboration, we compared guidance in
the 1997 memorandum with our prior work on practices that can help
federal agencies enhance and sustain collaboration.2 In the states we
visited, to determine how closely the state SRF and state-level RUS
programs coordinate and whether their efforts to coordinate are
consistent with the 1997 memorandum, we reviewed state-level guidance



2
GAO-06-15




Page 44                                      GAO-13-111 Rural Water Infrastructure
Appendix I: Objectives, Scope, and
Methodology




and documentation from state coordinating bodies and interviewed state-
level SRF and RUS program officials, community officials, consulting
engineers, and technical assistance providers. We identified actions
taken by states that were consistent with actions identified in the 1997
memorandum and assessed whether these fulfilled the actions identified
in the memorandum using “yes” to indicate the action was fully taken, “no”
to indicate that it was not taken at all, and “partial” to indicate the action
had not been fully taken.

We selected the five states we visited using a multistep process and
several sources of information: funding needs for rural areas; geographic
location; and level of coordination between state and community partners.
We first narrowed the number of states we could visit to 15 states by
analyzing EPA and USDA data on funding needs. To do so, we
determined the relative level of funding needed in each state using the
following data, by state, for communities with populations of 10,000 or
less: (1) per capita needs for drinking water infrastructure, (2) per capita
needs for clean water infrastructure, (3) drinking water infrastructure
needs as a percentage of total state drinking water needs, (4) clean water
infrastructure needs as a percentage of total state clean water needs, (5)
the number of backlogged RUS water and wastewater infrastructure
project requests, and (6) the total amount of RUS loan and grant funding
requested for the backlogged projects. We obtained and analyzed these
six categories of data from EPA’s Drinking Water and Clean Water Needs
Assessment reports, and USDA’s data on backlog of funding applications.
To assess the reliability of EPA’s data, we reviewed the agency’s quality
control efforts over the data. To assess the reliability of the USDA data,
we interviewed RUS officials on how they obtained and verified the data.
We determined that both sets of data were sufficiently reliable for our
purposes of selecting a sample of states to visit. Because not all states
had complete data, we created three groups of states for analysis: 35
states had full data, or data for all 6 categories; 11 states had partial data,
or data for 4 of the 6 categories; and 4 states had mixed data that we
determined was not sufficient to analyze. Because the amount of data
varied for each group, we determined that we would sample from each
group separately.

Next, for the 35 states that provided complete data, we ranked the states
from highest to lowest (numbering the highest 1 and so on) within each of
the six categories, basing the ranking on either percentage or dollars,
depending on the category. We then identified the top 10 states in each
category, selected the 10 states that appeared in three or more of the six
categories and added the scores across the six categories for each state.


Page 45                                       GAO-13-111 Rural Water Infrastructure
Appendix I: Objectives, Scope, and
Methodology




We then conducted a very similar process for the 11 states that had
partial data, except that we identified the states with the top five highest
values in each of the four categories of data and then selected the three
states that appeared in at least three of the four categories. This parallel
analysis gave us 10 states from the full data group and 3 states from the
partial data group. We then selected 2 states from the third group of
states, which had mixed data available, on the basis of their physical size
and the fact that they had the most data available in the group.

We further narrowed down the number of states we could visit using
geographic dispersion as a criterion. We located the 15 states selected
through our analysis of funding data in six Department of Census
divisions and selected five that were ranked first according to the six
categories.3 We also selected 2 states from the partial-data group and
one state from the mixed-data group, for a total of 8 states.

From the eight remaining states, we selected Colorado, Montana, North
Carolina, Pennsylvania, and South Dakota to visit based on the extent of
coordination among the state SRF and RUS programs and the
communities they served. We called the state SRF and RUS state-level
officials to discuss whether the programs met and how frequently they
jointly funded projects. We considered the range of coordination in each
of the eight states to judgmentally select the five states we visited.

We conducted this performance audit from September 2011 to
September 2012 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.




3
 The Census groups states and the District of Columbia into four regions and nine
divisions within those regions. In the Northeast region, there are two divisions, the Mid-
Atlantic Division and the New England Division. In the Midwest Region, there are two
divisions, the East North Central and West North Central divisions. In the Southern
Region, there are three divisions, the South Atlantic Division, the East South Central
Division, and the West South Central Division. Finally, in the Western Region, there are
two Divisions, the Mountain Division and the Pacific Division.




Page 46                                               GAO-13-111 Rural Water Infrastructure
Appendix II: Drinking Water and Clean Water
                                       Appendix II: Drinking Water and Clean Water
                                       State Revolving Fund Program Funds Provided
                                       to Communities with Populations of 10,000 or

State Revolving Fund Program Funds     Less



Provided to Communities with Populations of
10,000 or Less
                                       Table 6 provides information on the percentages and amounts of funding
                                       provided, by state, through EPA’s Drinking Water and Clean Water SRF
                                       programs to communities with populations of 10,000 or less.

Table 6: Drinking Water and Clean Water SRF Program Funds Provided to Communities with Populations of 10,000 or Less

Dollars in millions
                                         Drinking Water SRF                                 Clean Water SRF
                                                                a
                                     July 1, 1996-June 30, 2011                        July 1, 1987-June 30, 2011b
                                     Percentage of                                      Percentage of
State                              statewide funds     Amount of funding              statewide funds   Amount of funding
Alabama                                          33%                $115.4                       20%                 $204.1
Alaska                                            44                 106.7                         33                 127.3
Arizona                                           25                 160.9                         27                 370.8
Arkansas                                          36                  68.2                         37                 198.8
California                                        16                 196.2                          8                 409.1
Colorado                                          44                 174.9                         43                 394.0
Connecticut                                       24                  27.4                         19                 314.9
Delaware                                          31                  43.6                         57                 146.6
Florida                                           33                 203.2                         19                 682.3
Georgia                                           50                 143.9                         22                 291.6
Hawaii                                            30                  35.7                         24                 122.5
Idaho                                             76                 132.4                         52                 215.2
Illinois                                          44                 325.0                         23                 703.2
Indiana                                           44                 206.1                         28                 701.6
Iowa                                              52                 260.5                         47                 635.2
Kansas                                            43                 195.9                         44                 447.0
Kentucky                                          28                  58.5                         29                 286.7
Louisiana                                         33                  64.6                         19                 128.5
Maine                                             70                 115.8                         55                 320.6
Maryland                                          49                  93.5                         22                 322.6
Massachusetts                                      9                 111.4                         10                 486.5
Michigan                                          39                 257.6                         13                 456.9
Minnesota                                         53                 336.3                         33                 862.3
Mississippi                                       40                  87.4                         26                 160.5
Missouri                                          55                 167.6                         24                 523.4
Montana                                           66                 115.2                         56                 201.0
Nebraska                                          81                 144.7                         53                 208.6
Nevada                                            45                  72.3                         13                   49.8




                                       Page 47                                           GAO-13-111 Rural Water Infrastructure
                         Appendix II: Drinking Water and Clean Water
                         State Revolving Fund Program Funds Provided
                         to Communities with Populations of 10,000 or
                         Less




Dollars in millions
                             Drinking Water SRF                                        Clean Water SRF
                                                             a
                       July 1, 1996-June 30, 2011                                July 1, 1987-June 30, 2011b
                        Percentage of                                            Percentage of
State                 statewide funds          Amount of funding               statewide funds       Amount of funding
New Hampshire                          55                           75.8                       30                    189.9
New Jersey                             13                           95.9                       14                    567.1
New Mexico                             33                            35.0                      23                     71.3
New York                               42                         1,304.1                        9                 1,084.3
North Carolina                         31                           88.8                       33                    431.3
North Dakota                           40                          114.2                       30                     93.2
Ohio                                   30                          248.8                       26                  1,397.9
Oklahoma                               26                          156.3                       22                    185.5
Oregon                                 71                          173.4                       48                    429.1
Pennsylvania                           44                          298.9                       74                  1,755.9
Puerto Rico                            27                           49.4                       33                    137.3
Rhode Island                             7                          15.3                       17                    189.2
South Carolina                         12                           21.1                       19                    149.7
South Dakota                           42                          121.6                       31                    136.2
Tennessee                              51                            83.0                      23                    257.9
Texas                                  27                          283.2                       18                  1,016.7
Utah                                   71                          108.5                       41                    154.4
Vermont                                89                          102.4                       66                    137.3
Virginia                               93                          211.0                       23                    569.5
Washington                             59                          250.0                       52                    616.0
West Virginia                          69                          100.3                       68                    530.0
Wisconsin                              40                          145.2                       23                    452.1
Wyoming                             41%                            $67.8                     20%                     $68.3
Total                                                            $8,170.9                                       $20,591.7
                         Source: GAO analysis of EPA data.


                         Note: For the Clean Water SRF program, EPA began to provide SRF funds in federal fiscal year
                         1988, or on October 1, 1987; states reported on the funds received beginning in their corresponding
                         fiscal year—starting on July 1, 1987—according to EPA documents. Similarly, for the Drinking Water
                         SRF program, EPA began to provide funds in federal fiscal year 1997, or on October 1, 1996, and
                         states reported these data from their corresponding fiscal year—starting on July 1, 1996—according
                         to EPA documents.

                         a
                          Data for the Drinking SRF program are reported for communities with populations of 10,000 or less.

                         b
                          Data for the Clean Water SRF program are reported for communities with populations of 9,999 or
                         less.




                         Page 48                                                    GAO-13-111 Rural Water Infrastructure
Appendix III: Comments from the
             Appendix III: Comments from the
             Environmental Protection Agency



Environmental Protection Agency




             Page 49                           GAO-13-111 Rural Water Infrastructure
Appendix III: Comments from the
Environmental Protection Agency




Page 50                           GAO-13-111 Rural Water Infrastructure
Appendix III: Comments from the
Environmental Protection Agency




Page 51                           GAO-13-111 Rural Water Infrastructure
Appendix III: Comments from the
Environmental Protection Agency




Page 52                           GAO-13-111 Rural Water Infrastructure
Appendix IV: Comments from the U.S.
               Appendix IV: Comments from the U.S.
               Department of Agriculture’s Office of Rural
               Development


Department of Agriculture’s Office of Rural
Development




               Page 53                                       GAO-13-111 Rural Water Infrastructure
Appendix IV: Comments from the U.S.
Department of Agriculture’s Office of Rural
Development




Page 54                                       GAO-13-111 Rural Water Infrastructure
Appendix IV: Comments from the U.S.
Department of Agriculture’s Office of Rural
Development




Page 55                                       GAO-13-111 Rural Water Infrastructure
Appendix IV: Comments from the U.S.
Department of Agriculture’s Office of Rural
Development




Page 56                                       GAO-13-111 Rural Water Infrastructure
Appendix V: GAO Contact and Staff
                  Appendix V: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  David C. Trimble, (202) 512-3841or trimbled@gao.gov
GAO Contact
                  In addition to the individual above, Susan Iott, Assistant Director; John
Staff             Barrett; Elizabeth Beardsley; Mark Braza; Elizabeth Curda; Richard
Acknowledgments   Johnson; Micah McMillan; Sara Ann Moessbauer; Dan Royer; Tina
                  Sherman; Carol Herrnstadt Shulman; and Kiki Theodoropoulos made key
                  contributions to this report.




(361341)
                  Page 57                                    GAO-13-111 Rural Water Infrastructure
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