oversight

Bureau of Reclamation: Water Reuse Grant Program Supports Diverse Projects and Is Managed Consistently with Federal Regulations

Published by the Government Accountability Office on 2019-01-15.

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

                United States Government Accountability Office
                Report to Congressional Requesters




                BUREAU OF
December 2018




                RECLAMATION

                Water Reuse Grant
                Program Supports
                Diverse Projects and
                Is Managed
                Consistently with
                Federal Regulations




GAO-19-110
                                               December 2018

                                               BUREAU OF RECLAMATION
                                               Water Reuse Grant Program Supports Diverse
                                               Projects and Is Managed Consistently with Federal
Highlights of GAO-19-110, a report to
                                               Regulations
congressional requesters




Why GAO Did This Study                         What GAO Found
Population growth and drought are              The Bureau of Reclamation, within the Department of the Interior, awarded about
among the factors that have placed             $715 million in water reuse grants for 46 construction projects and 71 studies
increasing demands on the U.S. water           under the Title XVI Water Reclamation and Reuse Program (Title XVI) from fiscal
supply, particularly in the arid West.         year 1992 through fiscal year 2017, according to agency documents. Most of the
The reuse of wastewater can help               Title XVI funding—about $703 million—has been awarded for construction
address water management                       projects. Some construction projects remain eligible for Title XVI grant funding.
challenges by treating water that is           About $464 million in eligible Title XVI grant funding not yet awarded remains for
typically unusable and then reusing it         projects that Congress individually authorized; for projects eligible under the
for beneficial purposes, such as
                                               2016 amendments to the Title XVI program, about $513 million remains.
irrigation, according to the
Environmental Protection Agency.               Title XVI projects and studies cover various uses for reused water. For example,
Reclamation’s Title XVI program                many projects GAO reviewed produce reused water for landscape and
awards grants for the study and                agricultural irrigation, as well as water that may later be extracted for drinking
construction of water reuse projects in        water, as shown in the figure. Title XVI projects are located in western urban and
17 western states and Hawaii. From             rural areas, with California accounting for 36 construction projects.
fiscal years 1992 through 2009,
Congress individually authorized some          Typical Uses for Reused Water
Title XVI projects. In 2016, Congress
amended the Title XVI program to
allow grants to be awarded to
additional water reuse projects.
GAO was asked to review the Title XVI
program. This report describes, among
other things, for the Title XVI
program (1) grants Reclamation has
awarded for projects and studies and
remaining projects that are eligible for
grants, (2) the types and locations of
projects and studies that have received
grants, and (3) Reclamation’s process
for selecting projects and studies and
its consistency with federal grant
regulations as well as how the
program’s evaluation criteria have
changed since 2011. GAO reviewed
relevant laws, regulations, and agency
guidance; analyzed financial data for
fiscal years 1992 through 2017;
compared documents related to the              Reclamation’s process to select Title XVI projects and studies to receive grants
project selection process against              involves announcing the funding opportunity, establishing criteria to evaluate
federal grant regulations; and                 potential projects, and reviewing applications to make award decisions,
interviewed agency officials and               according to agency documents GAO reviewed. GAO found that Reclamation’s
nonfederal project sponsors with               grant award process is consistent with relevant federal regulations for awarding
different types of projects.                   grants. For example, the Title XVI funding opportunity announcements GAO
                                               reviewed contained information required by the regulations, such as the criteria
                                               used to evaluate applications. In recent years, Reclamation has changed the
View GAO-19-110. For more information,
contact Anne-Marie Fennell at (202) 512-3841
                                               criteria it uses to evaluate projects, eliminating or adding some criteria and
or fennella@gao.gov.                           changing the weighting of others. Reclamation officials said that these changes
                                               were made in part in response to statutory changes.
                                                                                       United States Government Accountability Office
Contents


Letter                                                                                   1
               Background                                                                6
               Reclamation Awarded About $715 Million for Title XVI Projects
                  and Studies, and Some Construction Projects Remain Eligible
                  for Title XVI Grants                                                 15
               Title XVI Projects and Studies Vary in Their Uses of Reused
                  Water and Include Urban and Rural Areas                              20
               Reclamation’s Project Selection Process Is Consistent with
                  Relevant Federal Grant Regulations, and Its Evaluation Criteria
                  Have Changed in Recent Years                                         32
               Reclamation’s Process for Monitoring Title XVI Grants Is
                  Consistent with Relevant Federal Grant Regulations                   37
               Agency Comments                                                         39

Appendix I     Information on Construction Projects Eligible under the Title XVI
               Water Reclamation and Reuse Program                                     41



Appendix II    Information on the Evaluation Criteria Used to Select Projects to Award
               Grants under the Title XVI Program                                      47



Appendix III   GAO Contact and Staff Acknowledgments                                   50


Tables
               Table 1: The Bureau of Reclamation’s Title XVI Water
                       Reclamation and Reuse Program Total Funding Awarded
                       by Project Category, Fiscal Years 1992-2017                     15
               Table 2: Status of Construction Projects and Remaining Eligible
                       Project Costs under the Bureau of Reclamation’s Title XVI
                       Water Reclamation and Reuse Program, as of August
                       2018                                                            17
               Table 3: Total Funding and Number of Studies and Construction
                       Projects Awarded under the Bureau of Reclamation’s Title
                       XVI Water Reclamation and Reuse Program by State,
                       Fiscal Years 1992 through 2017                                  28




               Page i                                                GAO-19-110 Water Reuse
          Table 4: Criteria the Bureau of Reclamation Used to Evaluate Title
                  XVI Water Reclamation and Reuse Construction Projects,
                  Fiscal Years (FY) 2017 and 2018                                48

Figures
          Figure 1: Timeline of Selected Key Events Related to the Bureau
                   of Reclamation’s Title XVI Water Reclamation and Reuse
                   Program                                                       10
          Figure 2: Examples of Treatment Process Options for Reused
                   Water                                                         12
          Figure 3: Typical Uses for Reused Water                                13
          Figure 4: Grounds at a Park Irrigated with Reused Water and a
                   Reservoir Storing Reused Water Funded in Part by the
                   Bureau of Reclamation’s Title XVI Water Reclamation
                   and Reuse Program                                             21
          Figure 5: Flowers Irrigated with Reused Water Funded in Part by
                   the Bureau of Reclamation’s Title XVI Water Reclamation
                   and Reuse Program                                             23
          Figure 6: A Wetland Receives Reused Water from a Project
                   Funded in Part by the Bureau of Reclamation’s Title XVI
                   Water Reclamation and Reuse Program                           24
          Figure 7: Indirect-Potable Reuse Project Funded in Part by the
                   Bureau of Reclamation’s Title XVI Water Reclamation
                   and Reuse Program                                             26
          Figure 8: Locations of Construction Projects and Areas Included in
                   Studies Awarded Grants under the Bureau of
                   Reclamation’s Title XVI Water Reclamation and Reuse
                   Program (Title XVI)                                           30
          Figure 9: Information on Individually Congressionally Authorized
                   Water Reuse Construction Projects under the Bureau of
                   Reclamation’s Title XVI Water Reclamation and Reuse
                   Program, as of August 2018                                    42
          Figure 10: Information on Bureau of Reclamation’s Title XVI Water
                   Reuse Construction Project Awards under the Water
                   Infrastructure Improvements for the Nation Act, as of
                   August 2018                                                   46




          Page ii                                              GAO-19-110 Water Reuse
Abbreviations

ARRA                       American Recovery and Reinvestment Act
FOA                        Funding Opportunity Announcement
OMB                        Office of Management and Budget
Title XVI                  Title XVI Water Reclamation and Reuse Program
Uniform Guidance           Uniform Administrative Requirements, Cost
                           Principles, and Audit Requirements for Federal
                           Awards
WIIN Act                   Water Infrastructure Improvements for the Nation
                           Act



This is a work of the U.S. government and is not subject to copyright protection in the
United States. The published product may be reproduced and distributed in its entirety
without further permission from GAO. However, because this work may contain
copyrighted images or other material, permission from the copyright holder may be
necessary if you wish to reproduce this material separately.




Page iii                                                          GAO-19-110 Water Reuse
                       Letter




441 G St. N.W.
Washington, DC 20548




                       December 13, 2018

                       The Honorable Jared Huffman
                       Ranking Member
                       Subcommittee on Water, Power and Oceans
                       Committee on Natural Resources
                       House of Representatives

                       The Honorable Grace F. Napolitano
                       Ranking Member
                       Subcommittee on Water Resources and Environment
                       Committee on Transportation and Infrastructure
                       House of Representatives

                       The Honorable Paul Tonko
                       Ranking Member
                       Subcommittee on Environment
                       Committee on Energy and Commerce
                       House of Representatives

                       Population growth and drought are among the factors that have placed
                       increasing demands on our nation’s water supply, particularly in the arid
                       West. The reuse and recycling of water helps address water management
                       challenges by treating wastewater or other water that is typically unusable
                       and then reusing it for beneficial purposes, such as irrigation, according to
                       the Environmental Protection Agency. The Bureau of Reclamation, within
                       the Department of the Interior, administers the only active federal
                       program focused on water reuse, reclamation, and recycling—the Title
                       XVI Water Reclamation and Reuse Program (Title XVI). 1 This program
                       helps states and communities create supplemental water supplies by
                       identifying opportunities for the reuse of municipal, industrial, domestic,
                       and agricultural wastewater and impaired ground and surface waters.

                       The Title XVI program provides grants for the study and construction of
                       water reuse projects in the 17 western states under Reclamation’s




                       1
                        Throughout this report, we refer to water reuse, reclamation, and recycling as water
                       reuse.




                       Page 1                                                            GAO-19-110 Water Reuse
purview and Hawaii. 2 Reclamation is responsible for awarding and
monitoring Title XVI grants to nonfederal project sponsors, who are
involved in the planning, designing, and constructing of these projects. 3
Title XVI grants generally require a cost share from the project sponsor.
For example, federal funding for construction projects under the Title XVI
program is generally limited to 25 percent of total project costs—up to $20
million in federal funding—and requires a 75 percent nonfederal cost
share from the project sponsor. 4 Reclamation generally awards Title XVI
grants for construction projects to project sponsors in installments over
multiple years before the federal funding maximum for each project is
reached. As a result, some projects may have remaining project costs
eligible for federal grant funding under Title XVI.

The Title XVI program was established by the Secretary of the Interior in
response to the enactment in 1992 of the Reclamation Wastewater and
Groundwater Studies and Facilities Act, which authorized several studies
as well as the construction of 5 wastewater reuse projects—4 in California
and 1 in Arizona. 5 From 1992 through 2009, Congress authorized a total
of 53 water reuse projects for construction under the Title XVI program. In
December 2016, the act was amended through Section 4009 of the Water
Infrastructure Improvements for the Nation Act (WIIN Act), which
authorized the Secretary of the Interior to provide grants for water reuse
projects with agency-approved feasibility studies. 6 The WIIN Act

2
 The eligible states are Arizona, California, Colorado, Hawaii, Idaho, Kansas, Montana,
Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, Oregon, South Dakota, Texas,
Utah, Washington, and Wyoming. Hawaii is generally not under Reclamation’s purview but
is included by statute in the Title XVI program.
3
 For the purpose of this report, the term project sponsors refers to the nonfederal
entities—such as tribes, water districts, and municipalities—that develop projects or
studies eligible for Title XVI grants. Eligible applicants include state, regional, or local
authorities; Indian tribes or tribal organizations; or other entities, such as water districts,
wastewater districts, or rural water districts.
4
 The $20 million ceiling on the federal share of funding for Title XVI construction projects
was enacted as a part of 1996 amendments to the program’s authorizing legislation.
Reclamation Recycling and Water Conservation Act of 1996, Pub. L. No. 104-266, § 7,
110 Stat. 3290, 3296 (1996) (codified as amended at 43 U.S.C. § 390h-13(d)(1)). The
federal ceiling for some projects is less than $20 million. In addition, legislation enacted
after 1996 specifically permitted some Title XVI projects to receive more than $20 million
in federal funding.
5
 Pub. L. No. 102-575, Title XVI, 106 Stat. 4600, 4663 (1992) (codified as amended at 43
U.S.C. §§ 390h to 390h-39).
6
 Pub. L. No. 114-322, § 4009(c), 130 Stat. 1628, 1868 (2016).




Page 2                                                                 GAO-19-110 Water Reuse
authorized Interior to award grants for projects that had not received
specific statutory authorization from Congress.

You asked us to review the Title XVI program for water reuse construction
projects and studies. This report describes for the Title XVI program
(1) grants Reclamation has awarded for projects and studies and
remaining projects that are eligible for grants, (2) the types and locations
of projects and studies that have received grants, (3) Reclamation’s
process for selecting projects and studies and its consistency with federal
grant regulations as well as how the program’s evaluation criteria have
changed since 2011, and (4) Reclamation’s process for monitoring grants
and its consistency with federal grant regulations.

For the first objective, we reviewed relevant laws, budget justifications,
and financial data maintained by Reclamation from fiscal years 1992
through 2017—the most recent data at the time of our review. We
selected this time period to cover funding from the inception of the
program through the most current data that were available at the time of
our review. To determine the reliability of Reclamation’s financial data, we
reviewed agency documents, compared publicly available information to
Reclamation’s Title XVI financial data, and interviewed agency officials.
We determined that the data were sufficiently reliable for the purpose of
our review. To determine the amount Reclamation has awarded to Title
XVI studies and projects, we analyzed the agency’s financial data. To
determine remaining project costs for individually congressionally
authorized projects, we further analyzed the financial data to determine
the federal share of remaining costs. For individually authorized projects
that have not received the full federal funding share, we verified with
project sponsors the status of projects in terms of planned construction. 7
To determine remaining project costs for Title XVI projects eligible under
the WIIN Act, we reviewed relevant feasibility studies to calculate the
federal share of remaining costs.

For the second objective, we reviewed documents from Reclamation and
project sponsors that describe the types of projects and studies funded
under the Title XVI program. We analyzed the information to categorize
each Title XVI project by the purpose or use of the reused water, such as

7
 This included contacting project sponsors to verify the status of 11 projects that
Reclamation’s documents listed as having no construction planned. We were unable to
contact one of these project sponsors because there was no longer anyone with
knowledge of the project at the water district, according to a Reclamation official.




Page 3                                                         GAO-19-110 Water Reuse
irrigation, commercial and industrial uses, and indirect-potable reuse. This
information was independently verified to confirm the categorization of
each project. To learn more about the types of Title XVI projects and
studies funded, we interviewed project sponsors from all 17 of the
individually authorized projects that Reclamation documents listed as
being ongoing at the time of our review, as well as all 3 of the WIIN Act-
eligible projects that Reclamation selected for grants in fiscal year 2017.
We also interviewed a nonprobability sample (11 of 25) of project
sponsors of projects that had been completed, or had already been
awarded their full federal cost share. We selected project sponsors from
different Reclamation regions and with a variety of project sizes (i.e.
amount of water to be delivered) and types. 8 Because this was a
nonprobability sample, the views of the sponsors we spoke with are not
representative of the views of all Title XVI project sponsors but provide
illustrative examples of the views of project sponsors for a range of Title
XVI projects. We conducted some of our interviews with project sponsors
by telephone and others in person. This included interviews conducted
during site visits to 14 Title XVI projects—selected to understand different
purposes and types of projects—in central and southern California in
March and April 2018. In addition to project sponsors, we also spoke with
representatives from eight nongovernmental organizations that sponsor
research, have an interest in water reuse, or represent water or
wastewater districts. We identified nongovernmental organizations to
interview through research and interviews with agency officials, project
sponsors, and other nongovernmental organizations.

For the third objective, we reviewed relevant federal grant regulations and
agency documents related to the project selection process, including
funding opportunity announcements for fiscal years 2011 through 2018
that describe Reclamation’s funding opportunities to applicants and
documentation related to Reclamation’s scoring of applications and final
selections. We selected this time frame because 2011 was the year that
Reclamation introduced a competitive selection process for annual Title
XVI grants. To assess the extent to which Reclamation’s process for
selecting projects is consistent with relevant federal grant regulations, we
compared the process Reclamation uses to select projects against the
Office of Management and Budget’s (OMB) Uniform Administrative

8
 To quantify the number of project sponsors, we use the following modifiers throughout
the report: some represents 2 to 3 project sponsors, several represents 4 to 7 project
sponsors, and many represents 8 to 18 project sponsors. We interviewed project sponsors
of both individually congressionally authorized projects and WIIN Act-eligible projects.




Page 4                                                         GAO-19-110 Water Reuse
Requirements, Cost Principles, and Audit Requirements for Federal
Awards (Uniform Guidance). 9 For this comparison, we selected relevant
provisions from the Uniform Guidance that pertain to the project selection
process. 10 To determine how evaluation criteria have changed since
2011, we analyzed the criteria listed in Reclamation’s funding opportunity
announcements for fiscal years 2011 through 2018 and discussed the
reasons for changes to the criteria with Reclamation officials. To identify
project sponsors’ views on the process and changes to the criteria, we
interviewed project sponsors and reviewed relevant documentation,
including letters project sponsors sent to Reclamation.

For the fourth objective, we reviewed relevant federal grant regulations
outlined in OMB’s Uniform Guidance as well as agency guidance related
to the monitoring process. To assess the extent to which the monitoring
process is consistent with relevant federal grant regulations, we
compared the process Reclamation uses to monitor grants against
relevant sections of OMB’s Uniform Guidance. 11 We analyzed financial
and performance reports related to all 56 Title XVI grants that were active
at the end of fiscal year 2017 using a standard document review tool to
determine the extent to which these reports contained information
required by the Uniform Guidance or Reclamation. For financial reports,
we determined whether project sponsors submitted required reports by
their due dates and whether they submitted these reports on the form
required by the agency. For performance reports, we determined whether

9
 79 Fed. Reg. 75,867 (Dec. 19, 2014) (joint interim final rule implementing OMB’s final
Uniform Guidance) (Interior’s implementing regulations codified at 2 C.F.R. pt. 1402); 78
Fed. Reg. 78,590 (Dec. 26, 2013) (OMB’s final Uniform Guidance) (codified as amended
at 2 C.F.R. pt. 200). The Uniform Guidance superseded and streamlined requirements
from eight OMB grants management circulars, including A–21, Cost Principles for
Educational Institutions; A–50, Audit Follow-up (specifically the guidance on Single Audit
Act follow-up); A–87, Cost Principles for State, Local and Indian Tribal Governments; A–
89, Federal Domestic Assistance Program Information; A–102, Grants and Cooperative
Agreements with State and Local Governments; A–110, Uniform Administrative
Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals,
and Other Non-Profit Organizations; A–122, Cost Principles for Non-Profit Organizations;
and A–133, Audits of States, Local Governments and Non-Profit Organizations. Although
the Uniform Guidance became effective in December 2014, it did not substantially revise
the provisions analyzed in this report.
10
  See 2 C.F.R. § 200.203, on information agencies are to include in public notices of
funding opportunities, such as key dates and the criteria to be used to evaluate
applications.
11
 These include 2 C.F.R. § 200.327, on financial reporting, and 2 C.F.R. § 200.328, on
monitoring and reporting program performance.




Page 5                                                            GAO-19-110 Water Reuse
                            project sponsors submitted reports by their due dates and whether these
                            reports contained information on progress made toward constructing the
                            Title XVI project. We also analyzed Reclamation documentation related to
                            site visits conducted by agency officials and compared it against
                            requirements outlined in agency guidance. In our interviews with project
                            sponsors, we also asked for their perspectives on Reclamation’s
                            monitoring process.

                            We conducted this performance audit from October 2017 to December
                            2018 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.



Background
Reclamation and the Title   As Interior’s primary water management agency, Reclamation’s mission
XVI Program                 has been to manage, develop, and protect water and water-related
                            resources in 17 western states since 1902. Reclamation has led or
                            provided assistance in the construction of most of the large dams and
                            water diversion structures in the West for the purpose of developing water
                            supplies for irrigation, municipal water use, flood control, and habitat
                            enhancement, among others. Reclamation is organized into five
                            regions—Great Plains, Lower Colorado, Mid-Pacific, Pacific Northwest,
                            and Upper Colorado 12—and the agency’s central office in Denver
                            provides technical and policy support. Each regional office oversees the
                            water projects, including Title XVI projects and studies, located within its
                            regional boundaries. The types of projects eligible under the Title XVI

                            12
                              The Great Plains Region covers the eastern part of Colorado, Kansas, Montana,
                            Nebraska, North Dakota, Oklahoma, South Dakota, most of Texas, and part of Wyoming.
                            The Lower Colorado Region covers most of Arizona, the southern part of California, and
                            parts of Nevada, New Mexico, and Utah. The Mid-Pacific Region covers the northern part
                            of California, most of Nevada, and parts of Oregon and Utah. The Pacific Northwest
                            Region covers Idaho and Washington, most of Oregon, and parts of Nevada, Utah, and
                            Wyoming. The Upper Colorado Region covers the northeastern part of Arizona, the
                            western part of Colorado, most of New Mexico, the far western part of Texas, most of
                            Utah, and the southwestern part of Wyoming. The Lower Colorado Region oversees Title
                            XVI projects in Hawaii.




                            Page 6                                                         GAO-19-110 Water Reuse
program include, among others, construction of water treatment facilities,
pipelines to distribute reused water, and tanks and reservoirs to store
reused water.

The Title XVI program is one of several programs under Interior’s
WaterSMART (Sustain and Manage America’s Resources for Tomorrow)
Program. The WaterSMART program is implemented by Reclamation and
the U.S. Geological Survey within Interior. According to an Interior
document, the WaterSMART program focuses on identifying strategies to
help ensure sufficient supplies of clean water for drinking, economic
activities, recreation, and ecosystem health. Reclamation carries out its
portion of the WaterSMART program by administering grants, including
Title XVI grants for water reuse, conducting research, and providing
technical assistance and scientific expertise. 13 Reclamation offers three
types of grants to project sponsors under the Title XVI program:

•   construction projects, which are projects to plan, design, or construct
    infrastructure for the treatment and distribution of reused water;
•   feasibility studies, which are documents that generally identify specific
    water reuse opportunities, describe alternatives, and incorporate other
    considerations, such as the financial capability of the project sponsor;
    and
•   research studies, which are studies to help states, tribes, and local
    communities establish or expand water reuse markets, improve
    existing water reuse facilities, or streamline the implementation of new
    water reuse facilities.




13
  Reclamation’s other WaterSMART programs include the Basin Study Program,
WaterSMART Grants, the Drought Response Program, and the Cooperative Watershed
Management Program.




Page 7                                                    GAO-19-110 Water Reuse
                                                         Federal awards for construction projects under the Title XVI program are
Key Terms Related to Water Reuse
                                                         generally limited to 25 percent of total project costs—up to $20 million in
•    Acre-foot of water: about 326,000 gallons
     of water, or enough water to cover an               federal funding—and require a 75 percent nonfederal cost share from the
     acre of land—about the size of a football           project sponsor. Federal funding for feasibility studies under the Title XVI
     field—1 foot deep.                                  program is generally limited to 50 percent of the total study costs, up to
•    Construction projects: projects to plan,
     design, or construct infrastructure for the
                                                         $450,000, and federal funding for research studies is generally limited to
     treatment and distribution of reused                25 percent of the total study costs, up to $300,000. Reclamation
     water.                                              generally awards Title XVI grants for construction projects to project
•    Feasibility studies: documents that                 sponsors in installments over multiple years before the federal funding
     generally identify specific water reuse
     opportunities; describe alternatives; and           maximum for each project is reached, whereas it generally awards the full
     incorporate other considerations, such as           amount for feasibility and research study grants in a single year.
     the financial capability of the project
     sponsor.
•    Nonpotable: water that is not suitable for          From fiscal year 1992, when the Title XVI program was established,
     drinking but may be suitable for other              through fiscal year 2009, Congress authorized 53 Title XVI projects. 14
     purposes.
                                                         Each of these projects was subject to a cap on the federal cost share. In
•    Potable: water that is suitable for drinking.
                                                         fiscal years 1992 through 2010, Congress generally directed funding for
•    Project sponsors: water districts,
     wastewater or sanitation districts,
                                                         these specific authorized projects each year. 15 Starting in fiscal year
     municipalities, tribes, and other entities          2011, Congress began appropriating funding for the Title XVI program
     that develop projects or studies eligible for       without directing specific funding to individual projects. 16 As a result,
     Title XVI grants.
•    Research studies: studies to help states,
                                                         Reclamation started using a competitive process to award Title XVI
     tribes, and local communities establish or          grants to projects and studies, through which project sponsors with
     expand water reuse markets, improve                 authorized projects applied for Title XVI grants. 17 Only the 53 projects
     existing water reuse facilities, or
     streamline the implementation of new                that were already authorized by Congress were eligible to apply for
     water reuse facilities.                             grants for construction projects. 18 Section 4009(c) of the WIIN Act,
Source: GAO analysis of information from the Bureau of
Reclamation and reports related to water reuse. |
GAO-19-110
                                                         14
                                                           Fiscal year 2009 was the last year that Congress authorized any specific Title XVI
                                                         projects.
                                                         15
                                                           Specifically, in fiscal years 1992 through 2010, Congress generally provided funding
                                                         direction for specific authorized projects in committee reports accompanying the
                                                         appropriations acts.
                                                         16
                                                           Since the beginning of the 112th Congress, convened in January 2011, the House and
                                                         Senate have observed a ban on earmarks, formally known as congressionally directed
                                                         spending. House and Senate rules define “congressionally directed spending” to be as a
                                                         provision in legislation or committee report language included primarily at the request of a
                                                         specific member of Congress authorizing or recommending specific spending in a specific
                                                         state, locality, or Congressional district. Congressional Research Service, Transportation
                                                         Spending Under an Earmark Ban, R41544 (Washington, D.C.: January 4, 2017).
                                                         17
                                                           Awards for Title XVI feasibility and research studies are not limited to project sponsors
                                                         with individually congressionally authorized projects.
                                                         18
                                                           To be eligible for Title XVI construction grants, projects also were required to meet Title
                                                         XVI pre-construction requirements, including having a completed and Reclamation-
                                                         approved feasibility study. See 43 U.S.C. § 390h-13(b).




                                                         Page 8                                                              GAO-19-110 Water Reuse
enacted in December 2016, authorized an additional $50 million to be
appropriated for water reuse projects. 19 To be eligible to receive Title XVI
grants under the WIIN Act, projects must submit a completed feasibility
study to Reclamation, and Reclamation must review the study to
determine whether, among other things, the project is technically and
financially feasible and provides a federal benefit in accordance with the
reclamation laws. Reclamation is then to submit a report with the results
of its review to Congress, and projects determined to be feasible are then
eligible to apply for grants under the competitive grant program
established by the WIIN Act. 20 Each feasibility study identifies an
estimated project cost. Like most projects individually authorized prior to
the WIIN Act, the federal share of this cost is generally capped at 25
percent, up to $20 million. In addition to construction projects,
Reclamation began awarding Title XVI grants to project sponsors for
feasibility studies in fiscal year 2011 and for research studies in fiscal
year 2016. 21 Figure 1 shows a timeline of the Title XVI program.




19
  Pub. L. No. 114-322, § 4009(c), 130 Stat. 1628, 1868 (2016).
20
  Specifically, the WIIN Act directs the Secretary of the Interior to send to Congress
(1) the results of the Secretary’s review of the feasibility study, including a determination of
whether the project is feasible; (2) any recommendations the Secretary may have
concerning the plan or design of the project; and (3) any conditions the Secretary may
require for construction of the project. 43 U.S.C. § 390h(e)(3).
21
  Reclamation awarded grants for some feasibility and research studies prior to fiscal
years 2011 and 2016 but did not award such grants through individual funding opportunity
announcements.




Page 9                                                               GAO-19-110 Water Reuse
Figure 1: Timeline of Selected Key Events Related to the Bureau of Reclamation’s Title XVI Water Reclamation and Reuse
Program




Water Reuse                             With water reuse, water that is typically unusable, such as municipal or
                                        industrial wastewater, undergoes additional treatment to make it suitable
                                        for certain purposes. For example, municipal wastewater typically
                                        undergoes primary and secondary treatment before it can be discharged




                                        Page 10                                                     GAO-19-110 Water Reuse
into a river, stream, or other body of water. 22 With water reuse,
wastewater generally undergoes further (tertiary) treatment to remove
additional nutrients and suspended solids and to disinfect the water. The
treated water can then be reused for nonpotable uses, such as landscape
or agricultural irrigation or industrial uses. In some cases, wastewater
undergoes additional, advanced treatment—such as microfiltration and
reverse osmosis—and may then be suitable for potable uses, such as
injection into a groundwater basin or reservoir where it may later be
extracted for drinking water. 23 Figure 2 shows some of the typical
treatment processes that may be applied to reused water, and figure 3
shows some of the typical uses of reused water.




22
  According to the Environmental Protection Agency, coarse solids are removed from
wastewater during the primary stage of treatment. Primary treatment generally includes a
sedimentation process, where wastewater enters a sedimentation tank and suspended
solids gradually sink to the bottom. After the water has been through primary treatment
processes, it flows into the next stage of treatment, called secondary. Secondary
treatment processes can remove up to 90 percent of the organic matter in wastewater by
using biological treatment processes. Environmental Protection Agency, Primer for
Municipal Wastewater Treatment Systems, EPA 832-R-04-001 (Washington, D.C.:
September 2004). Treated wastewater is generally disinfected before it is discharged into
a river, stream, or other water body, according to a Reclamation document.
23
  There are two types of potable reuse: indirect and direct. Indirect-potable reuse is the
intentional addition of treated municipal wastewater to a drinking water source such as a
lake or reservoir or groundwater aquifer, often referred to as an environmental buffer.
When reused water is added to a groundwater aquifer, it may be referred to as
groundwater recharge. Typically, groundwater recharge is accomplished through
spreading basins that allow the water to naturally percolate through the soil to the aquifer
or by means of injection wells that deliver the water directly to a specified location in the
aquifer. Direct potable reuse generally eliminates the environmental buffer from the
process and instead routes the highly treated wastewater into a drinking water treatment
facility for final treatment or into a potable water distribution system downstream of such a
facility.




Page 11                                                             GAO-19-110 Water Reuse
Figure 2: Examples of Treatment Process Options for Reused Water




                                       Note: While this figure provides examples of the types of treatment that reused water may undergo, it
                                       is not representative of the treatment processes for all reused water. For more information on various
                                       water treatment processes and technologies, see GAO, Technology Assessment: Municipal
                                       Freshwater Scarcity: Using Technology to Improve Distribution System Efficiency and Tap
                                       Nontraditional Water Sources, GAO-16-474 (Washington, D.C.: Apr. 29, 2016).




                                       Page 12                                                                   GAO-19-110 Water Reuse
Figure 3: Typical Uses for Reused Water




                                          Several reports have shown that water reuse could offer significant
                                          untapped water supplies, particularly in coastal areas facing water
                                          shortages. For example, in a 2012 report on municipal wastewater reuse,
                                          the National Research Council of the National Academies estimated that
                                          U.S. municipalities discharged about 12 billion gallons of treated
                                          municipal wastewater each day into coastal waters. 24 They estimated that
                                          reuse of these coastal discharges could directly augment available water
                                          sources by providing the equivalent of 27 percent of the municipal supply.
                                          Municipalities discharge another 20 billion gallons each day to inland
                                          24
                                            National Research Council of the National Academies, Water Reuse: Potential for
                                          Expanding the Nation’s Water Supply Through Reuse of Municipal Wastewater
                                          (Washington, D.C.: 2012).




                                          Page 13                                                        GAO-19-110 Water Reuse
                    locations. While reuse of inland discharges has the potential to affect the
                    water supply of downstream users by decreasing the amount of water
                    available to them, we previously found that at least some of this volume
                    could also be beneficial. 25 Even with such potential uses, the
                    Environmental Protection Agency reported in 2012 that only 7 to 8
                    percent of municipal wastewater was being intentionally reused in the
                    United States. 26


Grants Management   In our past work, we have highlighted the importance of awarding
                    competitive grants in a fair and transparent way and monitoring grants. 27
                    In recent years, OMB has taken actions to help improve the effectiveness
                    and efficiency of grantmaking across the federal government. In
                    particular, in December 2014, OMB’s Uniform Guidance became effective
                    for new grant awards after adoption by federal grantmaking agencies,
                    including Interior. 28 The Uniform Guidance requires, among other things,
                    that federal agencies provide public notices of funding opportunities, and
                    these notices are to contain information, such as key dates and the merit
                    and other criteria that the agency will use to evaluate applications. 29 The
                    Uniform Guidance also requires certain monitoring activities for federal
                    grants, such as generally requiring grant recipients to submit financial
                    reports. 30


                    25
                      GAO, Technology Assessment: Municipal Freshwater Scarcity: Using Technology to
                    Improve Distribution System Efficiency and Tap Nontraditional Water Sources,
                    GAO-16-474 (Washington, D.C.: Apr. 29, 2016).
                    26
                      Environmental Protection Agency, 2012 Guidelines for Water Reuse, EPA/600/R-12/618
                    (Washington, D.C.: September 2012).
                    27
                      See, for example, GAO, Wildlife and Sport Fish Restoration: Competitive Grant
                    Programs Managed Consistently with Relevant Regulations, but Monitoring Could Be
                    Improved, GAO-18-303 (Washington, D.C.: Feb. 22, 2018); Grants Management:
                    Selected Agencies Could Clarify Merit-Based Award Criteria and Provide Guidance for
                    Reviewing Potentially Duplicative Awards, GAO-17-113 (Washington, D.C.: Jan. 12,
                    2017); and Grants Management: EPA Could Improve Certain Monitoring Practices,
                    GAO-16-530 (Washington, D.C.: July 14, 2016).
                    28
                      79 Fed. Reg. 75,867 (Dec. 19, 2014) (joint interim final rule implementing OMB’s final
                    Uniform Guidance) (Interior’s implementing regulations codified at 2 C.F.R. pt. 1402); 78
                    Fed. Reg. 78,590 (Dec. 26, 2013) (OMB’s final Uniform Guidance) (codified as amended
                    at 2 C.F.R. pt. 200).
                    29
                     2 C.F.R. § 200.203.
                    30
                     See 2 C.F.R. § 200.327.




                    Page 14                                                           GAO-19-110 Water Reuse
                           From fiscal years 1992 through 2017, Reclamation awarded about $715
Reclamation Awarded        million for 46 construction projects and 71 studies under the Title XVI
About $715 Million for     program, based on our review of agency documents. 31 Most of this
                           funding—about $703 million—went toward construction projects, while
Title XVI Projects and     the remaining awards were for feasibility and research studies. Some
Studies, and Some          construction projects remain eligible for Title XVI grants. Specifically,
                           about $464 million in grant funding not yet awarded up to the federal
Construction Projects      ceiling remains for individually congressionally authorized Title XVI
Remain Eligible for        construction projects, and about $513 million remains in total estimated
                           projects eligible for Title XVI grants under the WIIN Act, as of August
Title XVI Grants           2018. 32


Most of the $715 Million   Across the three different types of grants offered under the Title XVI
Reclamation Awarded        program—construction projects, feasibility studies, and research
                           studies—Reclamation awarded about $715 million from fiscal years 1992
Was for Title XVI
                           through 2017, according to agency documents. This $715 million
Construction Projects      awarded under Title XVI leveraged more than $2.8 billion in nonfederal
                           cost share. Reclamation awarded most of this Title XVI funding for
                           construction projects, as shown in table 1.

                           Table 1: The Bureau of Reclamation’s Title XVI Water Reclamation and Reuse
                           Program Total Funding Awarded by Project Category, Fiscal Years 1992-2017

                           Dollars in thousands
                           Fiscal year                  Construction        Feasibility      Research                Total
                                                            projects          studiesa        studiesb
                           1992-2009c                         517,870              N/A              N/A        517,870
                           2010                                11,235              N/A              N/A         11,235
                           2011                                21,320            3,308              N/A         24,628
                           2012                                24,704              943              N/A         25,647
                           2013                                18,949                 0             N/A         18,949
                           2014                                20,047            2,258              N/A         22,304
                           2015                                23,390            1,648              N/A         25,037
                           2016                                34,328                 0           1,157         35,486

                           31
                             For this report, we report all amounts in nominal dollars, which are not adjusted for
                           inflation.
                           32
                             As discussed earlier, the WIIN Act authorized an additional $50 million to be
                           appropriated for Title XVI projects under the WIIN Act.




                           Page 15                                                            GAO-19-110 Water Reuse
    Dollars in thousands
    Fiscal year                        Construction                Feasibility      Research        Total
                                           projects                  studiesa        studiesb
    2017                                        30,980d                     1,792        848       33,619
    Total                                       702,823                     9,947      2,005      714,775
Source: GAO analysis of information provided by Reclamation. | GAO-19-110

Notes: Amounts are in nominal dollars, which are not adjusted for inflation. Totals may not add due to
rounding. Reclamation funded some feasibility and research studies prior to fiscal years 2011 and
2016 but did not award such grants through individual funding opportunity announcements.
a
 Feasibility studies are documents that generally identify specific water reuse opportunities, describe
alternatives, and incorporate other considerations such as the financial capability of the project
sponsor. Reclamation began making awards for feasibility studies under the Title XVI program
through separate funding opportunities in fiscal year 2011. Reclamation does not offer funding
opportunity announcements for feasibility studies every year and did not offer them in fiscal years
2013 and 2016.
b
 Research studies are for research to develop science and decision-support tools for reuse projects,
improve existing reuse facilities, and for state-of-the-art water reuse technology. Reclamation began
making awards for research studies under the Title XVI program through separate funding opportunity
announcements in fiscal year 2016.
c
 Reclamation generally does not maintain Title XVI funding data by year for fiscal years 1992 through
2009. In 2009, the Title XVI Water Reclamation and Reuse Program received a supplemental
appropriation under the American Recovery and Reinvestment Act (ARRA) of 2009, in addition to its
fiscal year 2009 appropriation. Pub. L. No. 111-5, 123 Stat. 115, 137 (2009). Of the nearly $518
million awarded from fiscal year 1992 through fiscal year 2009, about $127 million, or about 25
percent, was awarded under ARRA.
d
This figure includes grants for projects eligible under the Water Infrastructure Improvements for the
Nation Act (WIIN Act). Three projects were awarded a total of $10 million in fiscal year 2017.


Overall, Reclamation awarded about $703 million under Title XVI to 46
construction projects from fiscal years 1992 through 2017. Of these 46
construction projects that received awards, 43 were individually
congressionally authorized construction projects and 3 were construction
projects that were eligible for Title XVI grants under the WIIN Act,
according to agency documents we reviewed. Additionally, Reclamation
made awards for 71 studies—58 feasibility study grants since fiscal year
2011 and 13 research study grants since fiscal year 2016. 33


33
  The number of feasibility and research projects that are eligible for Title XVI in a given
year is not static. Title XVI feasibility and research study sponsors must meet general
eligibility criteria at the time they choose to apply for grants. Feasibility and research study
project sponsors eligible to receive a Title XVI award include state, regional, or local
authorities; Indian tribes or tribal organizations; or other entities such as water districts,
wastewater districts, or rural water districts. Applicants must be located in the 17 western
states or Hawaii. Eligible feasibility studies must evaluate the sources and uses of
reclaimed water, as defined in the Reclamation Manual Directives and Standards on water
management and development. Eligible research studies must focus on supporting water
reuse, such as establishing or expanding water reuse markets, improving existing water
reuse facilities, or streamlining the implementation of new reuse facilities.




Page 16                                                                             GAO-19-110 Water Reuse
Some Construction                                               Based on our review of Reclamation financial data, some construction
Projects Remain Eligible                                        projects remain eligible for Title XVI grants. Eligible project costs fell into
                                                                two categories: (1) grant funding not yet awarded up to the federal ceiling
for Title XVI Grants
                                                                for individually congressionally authorized Title XVI construction projects,
                                                                and (2) the federal share of estimated costs identified in feasibility studies
                                                                for projects eligible for Title XVI grants under the WIIN Act. 34 About $464
                                                                million in not-yet-awarded funding remained for 28 individually
                                                                congressionally authorized Title XVI construction projects as of August
                                                                2018. Also, about $513 million remained in estimated project costs for the
                                                                40 construction projects that were eligible under the WIIN Act, as of
                                                                August 2018, as shown in table 2 below. 35

Table 2: Status of Construction Projects and Remaining Eligible Project Costs under the Bureau of Reclamation’s Title XVI
Water Reclamation and Reuse Program, as of August 2018

 Project status                                                                  Number of eligible         Remaining eligible     Number of projects with
                                                                                          projects                project costs        remaining eligible
                                                                                                       (dollars in thousands)a               project costs
 Individually congressionally authorized projectsb
       Projects that were completed or were awarded the                                          25                            0                             0
       maximum federal share
       Projects that were ongoing                                                                13                     233,157                            13
       Projects with no construction planned at the time                                         15                     230,795                            15
 Total                                                                                           53                     463,952                            28
 Projects eligible under the Water Infrastructure
 Improvements for the Nation Act (WIIN Act)
       Projects that applied in 2017c                                                            20                     268,500                            20
       Projects that were eligible as of August 2018 but                                         20                     244,106                            20
       did not apply in 2017d
 Total                                                                                           40                     512,606                            40
Source: GAO analysis of information provided by Reclamation and project sponsors. | GAO-19-110



                                                                34
                                                                  To calculate the remaining estimated costs for projects eligible for Title XVI grants under
                                                                the WIIN Act, we first gathered and analyzed the estimated project costs of these projects
                                                                as identified in each project’s feasibility study and then calculated the maximum federal
                                                                funding for each WIIN Act-eligible project. The maximum in federal funding for a WIIN Act-
                                                                eligible project is 25 percent of the total project cost, up to $20 million dollars. Generally,
                                                                there are no eligible project costs remaining for Title XVI feasibility and research studies,
                                                                as Reclamation generally awards the full amount for feasibility and research study grants
                                                                in a single year.
                                                                35
                                                                  As of November 2018, Reclamation had approved six additional feasibility studies for
                                                                WIIN Act-eligible projects but had not yet transmitted them to Congress, according to a
                                                                Reclamation document. The federal cost share for these six projects is about $86 million.




                                                                Page 17                                                              GAO-19-110 Water Reuse
Note: Amounts are in nominal dollars, which are not adjusted for inflation.
a
 Eligible Title XVI construction project costs (i.e. the amount of federal cost share project sponsors
could seek from Reclamation) include two categories: (1) individually congressionally authorized Title
XVI construction projects that have funding that has not yet been awarded up to the federal ceiling,
and (2) remaining total estimated costs for projects eligible under the WIIN Act. To be eligible to
receive Title XVI grants under the WIIN Act, projects must have completed a feasibility study that
Reclamation has reviewed and submitted to Congress.
b
    From 1992 through 2009, Congress authorized a total of 53 individual Title XVI projects.
c
 Two additional projects applied for Title XVI grants in fiscal year 2017, but, according to Reclamation
officials, the applications were deemed ineligible since the funding requested was for projects not
identified in the approved feasibility study. Of the 20 projects that applied for Title XVI grants through
the Title XVI WIIN Act funding opportunity announcement in fiscal year 2017, Reclamation awarded 3
projects a total of $10 million.
d
 As of November 2018, Reclamation had approved 6 additional feasibility studies for WIIN Act-eligible
projects but had not yet transmitted them to Congress, according to a Reclamation document. The
federal cost share for these 6 projects is about $86 million.


As of August 2018, of the 53 individually congressionally authorized
construction projects, more than half—28 projects—had remaining project
costs eligible for Title XVI grants.

•       The 13 ongoing congressionally authorized projects had about $233
        million in project costs that had not yet been awarded. Some project
        sponsors told us that they were in the process of designing or
        constructing projects. Others told us that while they were not currently
        designing or constructing projects, they had plans to pursue additional
        Title XVI grant awards in the future. More than one-third of the $233
        million in remaining eligible project costs was for two projects—
        located in San Diego and San Jose, California—that were two of the
        projects authorized when the Title XVI program was created in 1992.
•       The 15 congressionally authorized projects with no planned
        construction had remaining project costs of about $231 million eligible
        for Title XVI grants. Project sponsors identified several reasons why
        they were not planning to apply for further grant awards. Specifically,
        several project sponsors said they had faced challenges in applying
        for further grants because language in the statutes authorizing the
        projects limited the scope of their projects. For example, one project
        sponsor told us that it was interested in expanding its water reuse
        demonstration facility but that it was not eligible to apply for additional
        Title XVI grants because the statute that authorized the project
        specifically authorized a demonstration facility. In addition, one project
        sponsor stated that its project authorization had already reached its
        sunset date, which means the project can no longer apply for Title XVI




Page 18                                                                       GAO-19-110 Water Reuse
     grants. 36 Some of the project sponsors with no construction planned
     said that they may consider applying for additional Title XVI grants
     under their existing authorizations in the future, should they decide to
     move forward with construction. However, others said that they had
     decided not to move forward with authorized projects and had no
     plans to apply for Title XVI grants in the future. For example, one
     project sponsor said that it had determined that its project was no
     longer financially feasible.
In addition, as of August 2018, 40 projects had Reclamation-approved
feasibility studies that had been transmitted to Congress, based on our
review of agency documents, and were therefore eligible to apply for Title
XVI construction grants under the WIIN Act. 37 A total of about $513 million
in project costs across these 40 projects remained eligible for Title XVI
grants. 38 Of the 40 projects, 20 applied for Title XVI grants in fiscal year
2017, and Reclamation selected 3 for awards. These 20 projects had
about $269 million in project costs that remained eligible for Title XVI
grants. Twenty projects did not apply for Title XVI grants in fiscal year
2017 and had about $244 million in project costs that remained eligible for
these grants, as of August 2018.




36
  Of the 53 individually congressionally authorized projects, 5 had sunset dates listed in
their authorizations and the other 48 did not. Two Title XVI projects with such sunset dates
had already reached their sunset dates as of August 2018, and 3 projects will reach their
sunset dates on March 30, 2019. Three of the 5 projects with sunset dates were awarded
the full amount up to the federal ceiling under Title XVI prior to reaching their sunset
dates.
37
  The WIIN Act authorized an additional $50 million to be appropriated for Title XVI
projects. Of Reclamation’s fiscal year 2017 and 2018 appropriations to be used for Title
XVI, congressional direction in the explanatory statements accompanying the
appropriations acts provided that $10 million was to be used for WIIN Act projects in fiscal
year 2017 and $20 million in fiscal year 2018.
38
  As noted, Reclamation approved six additional feasibility studies for WIIN Act-eligible
projects but had not yet transmitted them to Congress as of November 2018, according to
a Reclamation document. The federal cost share for these six projects is about $86
million.




Page 19                                                            GAO-19-110 Water Reuse
                               Title XVI projects and studies for fiscal years 1992 through 2017 cover
Title XVI Projects and         various uses for reused water and include both urban and rural areas
Studies Vary in Their          throughout the West, based on our review of agency data as well as
                               documents from and interviews with project sponsors. For example, Title
Uses of Reused                 XVI construction projects produce both nonpotable and potable reused
Water and Include              water for a variety of purposes, such as landscape and agricultural
                               irrigation, habitat restoration, and extraction as drinking water. The
Urban and Rural                projects and studies funded by the Title XVI program include both urban
Areas                          and rural areas throughout the West, with California accounting for 36
                               construction projects and about 90 percent of total Title XVI funding.


Title XVI Projects Are         Title XVI construction projects are generally large-scale infrastructure
Generally Large-Scale          projects, such as water reuse treatment plants and pipelines, that
                               produce, store, and distribute reused water for a variety of purposes, both
Infrastructure Projects that
                               nonpotable and potable. Since the inception of the Title XVI program,
Produce Nonpotable and         Reclamation has awarded Title XVI grants to construction projects that
Potable Reused Water for       cumulatively provided nearly 390,000 acre-feet of reused water in 2017. 39
a Variety of Purposes          According to Reclamation data, the projects funded by Title XVI
                               individually delivered between 38 acre-feet of reused water and more
                               than 100,000 acre-feet of water in fiscal year 2017. Most of these
                               construction projects provided reused water for nonpotable uses across
                               four main categories: (1) landscape irrigation, (2) agricultural irrigation,
                               (3) commercial and industrial use, and (4) habitat restoration.

                               Landscape irrigation. Landscape irrigation—including irrigation of golf
                               courses, road medians, school grounds, parks, sport fields, and other
                               green spaces—is the most common use of reused water produced by
                               Title XVI projects, with 29 Title XVI projects producing reused water for
                               this purpose, based on our analysis of documents from Reclamation and
                               project sponsors. The reused, nonpotable water produced by such
                               projects is generally distributed through purple-colored pipes, to denote
                               that the water is not for drinking purposes. For example, the Title XVI
                               program provided grants to Eastern Municipal Water District—a water
                               district located in Southern California—to help build water reuse
                               39
                                 Not all of the projects that have been awarded Title XVI grants delivered reused water in
                               2017. Some of these projects are still under construction. In addition, Reclamation did not
                               collect information on the amount of reused water delivered in 2017 by the three projects
                               eligible under the WIIN Act that were selected for fiscal year 2017 Title XVI grants
                               because Reclamation only collects delivery information after projects have received Title
                               XVI grants. See appendix I for acre-feet water delivery information for Title XVI
                               construction projects.




                               Page 20                                                           GAO-19-110 Water Reuse
                                        infrastructure, including pipelines, pumping stations, and storage tanks.
                                        With this added storage capacity, the district has the ability to store more
                                        than 2 billion gallons of reused water, which is used to irrigate sports
                                        fields, golf courses, parks, school grounds, and medians, according to the
                                        project sponsor. By maximizing use of its reused water, the project
                                        sponsor noted that the district is reducing its dependence on water piped
                                        in from other parts of the state or region. Similarly, the Title XVI program
                                        provided grants to help build pipelines and reservoirs to distribute and
                                        store reused water for landscape irrigation and other purposes in other
                                        parts of California (see fig. 4).

Figure 4: Grounds at a Park Irrigated with Reused Water and a Reservoir Storing Reused Water Funded in Part by the Bureau
of Reclamation’s Title XVI Water Reclamation and Reuse Program




                                        Agricultural irrigation. Reused water produced by Title XVI projects is also
                                        used to irrigate a variety of agricultural products, including fruits and
                                        vegetables, flowers, and vineyards. For example, the North Valley
                                        Regional Recycled Water Program is helping to provide a reliable water
                                        source for the Del Puerto Water District, which provides water to
                                        approximately 45,000 acres of farmland in California’s San Joaquin
                                        Valley, according to the project sponsor. The Del Puerto Water District
                                        has encountered water shortages in recent years, which have created
                                        economic hardships on growers in the area, according to the project
                                        sponsor. Title XVI grants provided under WIIN Act authority helped the



                                        Page 21                                                    GAO-19-110 Water Reuse
district expand its reused water supply and distribution infrastructure and
ensure a reliable, drought-resistant water supply, according to the project
sponsor. In addition, reused water produced by the Watsonville Area
Water Recycling Project near Watsonville, California, is used to irrigate
strawberries and other fruits and vegetables as well as flowers. The
groundwater basin that serves the coastal region where Watsonville is
located has been overdrafted for a long time, causing groundwater
elevations to drop below sea level and leading to seawater intrusion that
makes the groundwater unusable in certain areas, according to the
project sponsor. 40 This sponsor noted that Watsonville’s Title XVI project
helps reduce demand on the overdrafted groundwater basin, which in turn
helps to protect against further seawater intrusion and also provides a
reliable, drought-tolerant water supply to help protect the region’s
agricultural economy. Figure 5 shows flowers in a greenhouse that are
irrigated with reused water from Watsonville’s Title XVI project.




40
  Groundwater overdraft occurs when groundwater use exceeds the amount of recharge
into an aquifer, which leads to a decline in groundwater level.




Page 22                                                     GAO-19-110 Water Reuse
Figure 5: Flowers Irrigated with Reused Water Funded in Part by the Bureau of
Reclamation’s Title XVI Water Reclamation and Reuse Program




Commercial and industrial use. Reused water produced by Title XVI
projects is used for cooling towers at power plants and data centers, oil
production, toilet flushing in university and commercial buildings, and for
other commercial and industrial purposes, according to project sponsors.
For example, some of the reused water produced by the Southern
Nevada Title XVI project is used for power plant cooling, and reused
water from San Jose’s Title XVI project is used for cooling at data centers
in California’s Silicon Valley. In addition, reused water from the Long
Beach Area Reclamation Project is injected into the ground after oil is
extracted, which helps prevent the ground from sinking, according to the
project sponsor. Having access to a secure source of reused water can
attract data centers and other businesses that require large amounts of
water to areas that can guarantee access to reused water, according to a
project sponsor and representatives from a nongovernmental water reuse
organization we interviewed.



Page 23                                                     GAO-19-110 Water Reuse
Habitat restoration. Some Title XVI projects use reused water to restore
wetlands or supply water to recreational lakes. For example, in
California’s Napa Valley, reused water from the North Bay Title XVI
project is being used to restore the Napa Sonoma Salt Marsh. Some
threatened and endangered species, such as the Chinook Salmon, have
started returning to the area since the restoration began, according to the
project sponsor. Reused water from this Title XVI project also provides
other habitat benefits. For example, wineries in the area that irrigate with
reused water do not need to divert as much water from streams, which
leaves more water for fish, according to the project sponsor. In addition,
the North Valley Regional Recycled Water Program in California’s San
Joaquin Valley supplies reused water to wildlife refuges and wetlands, in
addition to agricultural lands. This area has the largest remaining
freshwater marsh in the western United States, which provides critical
habitat for migratory birds as well as other species, according to the
project sponsor (see fig. 6).

Figure 6: A Wetland Receives Reused Water from a Project Funded in Part by the
Bureau of Reclamation’s Title XVI Water Reclamation and Reuse Program




Page 24                                                   GAO-19-110 Water Reuse
There are also several potable projects that have been funded by Title
XVI. These projects generally fall into two categories: (1) indirect-potable
reuse and (2) desalination.

Indirect-potable reuse. Title XVI has provided grants for indirect-potable
projects, in which wastewater undergoes advanced treatment to obtain
potable-quality water. The water is then injected into an environmental
buffer, such as a groundwater aquifer, where it is left for a certain amount
of time before it is extracted. The water is treated again before it is
distributed as drinking water. One use for highly-treated reused water is
for seawater barriers, where water is injected into the ground to prevent
the intrusion of high-salinity water into groundwater aquifers. Indirect-
potable reuse has been gaining prominence, according to some project
sponsors and representatives from nongovernmental water reuse
organizations, with Title XVI grants going to several project sponsors for
both the construction of facilities as well as research into optimal
treatment methods. For example, the Groundwater Replenishment
System in Orange County, California, which was partially funded by Title
XVI, takes highly-treated wastewater that would have previously been
discharged into the Pacific Ocean and purifies it using an advanced
treatment process. 41 The water is then injected into a groundwater aquifer
and is later extracted as drinking water that serves more than 800,000
people, according to the project sponsor. Figure 7 shows reused water at
several different points in the treatment process and reverse osmosis
treatment equipment at Orange County’s Groundwater Replenishment
System. 42




41
  Other funding sources for the Groundwater Replenishment System include state grants
and loans from California’s State Revolving Fund, according to the project sponsor.
42
  Reverse osmosis water treatment is used in the production of potable water. It uses high
pressure to force water through a nonporous membrane by diffusion, leaving most salts
and other dissolved substances trapped on one side of the membrane while fresher water
passes through to the other side.




Page 25                                                          GAO-19-110 Water Reuse
Figure 7: Indirect-Potable Reuse Project Funded in Part by the Bureau of Reclamation’s Title XVI Water Reclamation and
Reuse Program




                                         Desalination. Title XVI has provided grants for projects that treat brackish
                                         groundwater—water that has a salinity above freshwater but below
                                         seawater—and then feed it directly into potable water distribution systems
                                         or into a groundwater aquifer or surface water reservoir. 43 For example,
                                         the Mission Basin Groundwater Purification Facility in Oceanside,
                                         California, desalinates brackish groundwater using reverse osmosis and
                                         other treatment methods. The reused water supplies about 15 percent of
                                         the city’s water needs, according to the project sponsor.

                                         In addition to Title XVI construction projects, Reclamation’s feasibility and
                                         research studies also vary in their planned uses of reused water. For
                                         example, one feasibility study project sponsor we interviewed was

                                         43
                                           The Title XVI program also funded a demonstration project to conduct research on the
                                         long-term impacts of the desalination of seawater. In 2016, the WIIN Act authorized
                                         Reclamation to participate in eligible desalination projects. Pub. L. No. 114-322, §
                                         4009(a), 130 Stat. 1628, 1867 (2009). While some Title XVI projects in the past treated
                                         brackish groundwater, any new projects that began since the WIIN Act was enacted that
                                         treat brackish groundwater or seawater would not be eligible for grants under the Title XVI
                                         program and instead would need to apply for funding under Reclamation’s new program
                                         for desalination construction projects, according to Reclamation officials.




                                         Page 26                                                           GAO-19-110 Water Reuse
                          awarded a Title XVI grant to investigate the feasibility and potential
                          impacts of reusing produced water from oil and gas operations in
                          Oklahoma. 44 The study plans to investigate possible dual benefits of
                          reusing produced water, including (1) providing a new source of water for
                          irrigation and other purposes and (2) reducing the disposal of produced
                          water as a possible means for addressing increased seismic activity
                          associated with oil and gas operations, according to the project sponsor. 45
                          Another feasibility study project sponsor we interviewed from a rural,
                          landlocked community in Washington State is investigating the feasibility
                          of creating a virtual zero discharge system that would eliminate all
                          wastewater disposal by reusing the wastewater. Similar to feasibility
                          studies, Title XVI research studies address different topics. For example,
                          one project sponsor we interviewed was researching how to optimize
                          filtration of reused water using membrane filtration, which is a critical
                          treatment process to reduce contaminants in water. Another project
                          sponsor was researching impediments and incentives to using reused
                          water for agricultural irrigation.


Title XVI Projects and    Based on our review of agency documents, project sponsors in 12 of the
Studies Include Western   18 states eligible to participate in the Title XVI program were awarded at
                          least one type of funding under Title XVI since the inception of the
Urban and Rural Areas     program in 1992, as shown in table 3. 46




                          44
                            Produced water is a significant byproduct associated with oil and gas exploration and
                          may contain a variety of contaminants. If produced water is not appropriately managed or
                          treated, these contaminants may present a human health and environmental risk. See
                          GAO, Drinking Water: EPA Program to Protect Underground Sources from Injection of
                          Fluids Associated with Oil and Gas Production Needs Improvement, GAO-14-555
                          (Washington, D.C.: June 27, 2014).
                          45
                            In 2014, we found that seismic activity associated with injection wells has raised
                          awareness of the potential for earthquakes resulting from the underground injection of
                          produced water. GAO-14-555.
                          46
                            Some states have project sponsors that have been awarded more than one type of
                          grant (e.g., grants for both feasibility studies and construction projects).




                          Page 27                                                          GAO-19-110 Water Reuse
Table 3: Total Funding and Number of Studies and Construction Projects Awarded under the Bureau of Reclamation’s Title
XVI Water Reclamation and Reuse Program by State, Fiscal Years 1992 through 2017

Dollars in thousands
State                         Amount of                Number of            Amount of        Number of            Amount of              Number of            Total
                               feasibility              feasibility           research        research          construction           construction      amount of
                                 funding                  studies              funding          studies             funding                projects        funding
                                awardeda                 awarded             awardedb         awarded              awarded                awarded         awarded
                                                           grants                                grants                                     grantsc
Arizona                                     0                         0                0                0                2,810                       1        2,810
California                            6,210                         35            1,345                 9              632,681                      36     640,236
Colorado                                150                           1             150                 1                      0                     0         300
Hawaii                                      0                         0                0                0                    10                      1           10
Idaho                                       0                         0                0                0                      0                     0               0
Kansas                                    65                          1             199                 1                      0                     0         265
Montana                                     0                         0                0                0                      0                     0               0
Nebraska                                    0                         0                0                0                      0                     0               0
Nevada                                  150                           1                0                0               31,321                       3       31,471
New Mexico                              132                           1                0                0               20,000                       1       20,132
North Dakota                                0                         0                0                0                      0                     0               0
Oklahoma                                586                           4                0                0                      0                     0         586
Oregon                                      0                         0                0                0                   520                      1         520
South Dakota                                0                         0                0                0                      0                     0               0
Texas                                 2,205                         12              311                 2               12,072                       2       14,587
Utah                                    150                           1                0                0                3,409                       1        3,559
Washington                              300                           2                0                0                      0                     0         300
Wyoming                                     0                         0                0                0                      0                     0               0
Total                                 9,947                         58            2,005                13              702,823                      46     714,775
Source: GAO analysis of information provided by Reclamation. | GAO-19-110

                                                                Note: Amounts are in nominal dollars, which are not adjusted for inflation.
                                                                a
                                                                 Reclamation began funding feasibility studies under the Title XVI program as separate funding
                                                                opportunities in fiscal year 2011. Reclamation does not offer funding opportunity announcements for
                                                                feasibility studies every year and did not offer them in fiscal years 2013 and 2016.
                                                                b
                                                                 Reclamation began funding research studies under the Title XVI program as separate funding
                                                                opportunities in fiscal year 2016.
                                                                c
                                                                 This column represents the number of projects that were awarded a Title XVI construction grant in
                                                                fiscal years 1992 through 2017. Some Title XVI construction projects were awarded multiple grants
                                                                over several fiscal years.


                                                                From fiscal year 1992 through fiscal year 2017, Reclamation awarded
                                                                about $640 million—or about 90 percent of total awarded Title XVI
                                                                funding—to projects in California, the majority of which was for
                                                                construction projects. The concentration of projects in California reflects


                                                                Page 28                                                                       GAO-19-110 Water Reuse
the early emphasis of the Title XVI program on Southern California and
reducing its reliance on water provided by the Colorado River, as well as
the high level of interest in the program in the state, according to a 2010
Congressional Research Service report. 47 Overall, project sponsors in 9
states were awarded feasibility study grants, sponsors in 4 states were
awarded research study grants, and sponsors in 8 states were awarded
construction grants (see fig. 8).




47
  Congressional Research Service, Water Reuse and the Title XVI Program: Legislative
Issues (Washington, D.C.: November 9, 2010).




Page 29                                                       GAO-19-110 Water Reuse
Figure 8: Locations of Construction Projects and Areas Included in Studies Awarded Grants under the Bureau of
Reclamation’s Title XVI Water Reclamation and Reuse Program (Title XVI)




                                        Page 30                                                    GAO-19-110 Water Reuse
Examples of Sponsors for Projects and                      Title XVI projects and studies include western urban and rural areas. In
Studies under the Bureau of Reclamation’s                  particular, many Title XVI projects are sponsored by entities in urban
Title XVI Water Reclamation and Reuse
Program (Title XVI)
                                                           areas that serve a large population base. For example, the main part of
Title XVI projects and studies are sponsored by
                                                           the Los Angeles Area Water Supply Title XVI project is sponsored by the
various nonfederal entities, including:                    West Basin Municipal Water District, which has a service area of nearly 1
•    Water districts, such as West Basin                   million people in 17 cities and unincorporated areas in Los Angeles
     Municipal Water District in Los Angeles               County. This Title XVI project produces five different types of reused
     County, California, and the Albuquerque
     Bernalillo County Water Utility Authority in          water to meet the unique needs of West Basin’s municipal, commercial,
     Albuquerque, New Mexico;                              and industrial reuse customers, according to the project sponsor.
•    Wastewater or sanitation districts, such as           Similarly, the City of San Diego, which has a population of about 1.4
     Delta Diablo in the San Francisco Bay area
     and the Orange County Sanitation District in          million, was awarded Title XVI grants for a number of projects, including
     Orange County, California;                            an indirect-potable reuse project anticipated to provide one-third of San
•    Municipalities, such as San Diego,                    Diego’s water supply by 2035, according to the project sponsor. Other
     California, and Round Rock, Texas; and
                                                           Title XVI projects are sponsored by entities in rural areas and small cities.
•    Regional partnerships, such as the North
     San Diego Reuse Coalition and the North
                                                           For example, the Hi-Desert Water District project serves a rural and
     Bay Water Reuse Authority.                            economically disadvantaged community in the town of Yucca Valley,
Source: GAO analysis of information from the Bureau of
Reclamation and Title XVI project sponsors. | GAO-19-110
                                                           California, that has a population of about 20,000. This Title XVI project
                                                           will fund facilities to collect, treat, and reuse treated wastewater, thereby
                                                           eliminating degradation of the local groundwater supply and helping
                                                           ensure a safer, reliable water supply for this community, according to the
                                                           project sponsor. Similarly, the city of Round Rock, Texas, which has a
                                                           population of about 120,000, sponsored the Williamson County Title XVI
                                                           project. This project produces reused water for landscape irrigation, most
                                                           of which is used to irrigate a 650-acre park, according to the project
                                                           sponsor.

                                                           Some Title XVI projects are sponsored by regional partnerships
                                                           composed of different local entities. For example, in the late 1990s, 4
                                                           entities in Northern San Diego County—Carlsbad Municipal Water
                                                           District, Leucadia Wastewater District, Olivenhain Municipal Water
                                                           District, and San Elijo Joint Powers Authority—formed a coalition to
                                                           leverage their water reuse programs; the coalition has since grown to 10
                                                           entities. 48 This coalition sponsored an individually congressionally
                                                           authorized Title XVI project, the North San Diego County project, and
                                                           applied for a Title XVI grant for a new project eligible under the WIIN Act
                                                           in fiscal year 2017. Similarly, in the northern part of the San Francisco

                                                           48
                                                             As of September 2018, the North San Diego Reuse Coalition was composed of the
                                                           Carlsbad Municipal Water District, the City of Escondido, the City of Oceanside, Leucadia
                                                           Wastewater District, Olivenhain Municipal Water District, Rincon del Diablo Municipal
                                                           Water District, San Elijo Joint Powers Authority, Santa Fe Irrigation District, Vallecitos
                                                           Water District, and Vista Irrigation District.




                                                           Page 31                                                           GAO-19-110 Water Reuse
                            Bay Area, 10 local agencies formed a regional partnership covering 315
                            square miles across Sonoma, Marin, and Napa Counties to sponsor the
                            North Bay Water Reuse Program. According to the project sponsors
                            involved in this regional partnership, using a regional partnership
                            approach to water reuse projects provides an economy of scale;
                            maximizes the ability to obtain local, state, and federal funding for the
                            projects; and allows smaller, local entities to access funding and expertise
                            for projects that would be out of reach without regional collaboration. See
                            appendix I for more detailed information on specific Title XVI construction
                            projects.


                            Reclamation’s process for selecting projects and studies to award grants
Reclamation’s Project       under the Title XVI program involves announcing the funding opportunity,
Selection Process Is        establishing criteria to evaluate potential projects, and reviewing
                            applications to make award decisions. We found that this process is
Consistent with             consistent with relevant federal grant regulations outlined in OMB’s
Relevant Federal            Uniform Guidance, based on our review of agency documents and federal
                            grant regulations. The criteria Reclamation uses to evaluate Title XVI
Grant Regulations,          projects have changed in recent years, with the elimination or addition of
and Its Evaluation          some criteria and changes in the weighting of others.
Criteria Have
Changed in Recent
Years
Reclamation Publicly        To start its selection process, Reclamation announces funding
Announces Funding           opportunities by developing annual funding opportunity announcements
                            (FOA), which are publicly available on its website and on
Opportunities and Has a
                            www.grants.gov. These FOAs contain information for applicants to
Merit Review Process for    consider prior to applying, including the types of eligible projects and
Applications, which Is      studies, estimated funding available, information on the application review
Consistent with Relevant    process, the application due date, and the criteria that Reclamation will
                            use to score applications. 49
Federal Grant Regulations
                            49
                              Reclamation issues separate FOAs for Title XVI construction projects, feasibility studies,
                            and research studies. Reclamation has issued FOAs for construction projects annually
                            since fiscal year 2011 but has not offered FOAs for feasibility studies and research studies
                            each year (see table 1). Reclamation follows the same general process for selecting
                            construction projects, feasibility studies, and research studies to award grants to,
                            according to Reclamation officials.




                            Page 32                                                           GAO-19-110 Water Reuse
Project sponsors submit applications for Title XVI grants to Reclamation
in response to the FOAs, according to Reclamation officials. Reclamation
officials then review the applications to ensure the projects are eligible
and that applications are complete, according to agency officials we
interviewed and documents we reviewed related to the selection process.
Next, an application review committee scores eligible applications. The
application review committee is composed of Reclamation staff
representing the five regions and other staff with technical expertise.
Committee members individually review and score each Title XVI
application based on the evaluation criteria in the FOA. After the
individual scoring, the application review committee meets collectively to
discuss the scores; this meeting is generally facilitated by Title XVI
program staff from Reclamation’s central office in Denver. If there are any
outliers in the scores—e.g., if a committee member scores an application
significantly higher or lower than the other members—then they are to
discuss and may adjust the score to help ensure fairness and consistency
in how the applications are scored relative to the evaluation criteria,
according to agency officials. Following this discussion, Reclamation
averages the members’ scores for each application and then ranks the
applications based on the average scores. Reclamation creates a list of
recommended projects and funding amounts for these projects, based on
the rankings and congressional direction on the amount of funding for the
Title XVI program in any given year. 50

Reclamation’s process for selecting projects and studies to fund under
the Title XVI program is consistent with relevant federal grant regulations
outlined in the Uniform Guidance. Based on our review of Title XVI FOAs
from fiscal years 2011 through 2018, all FOAs met the requirements
prescribed by the Uniform Guidance. 51 Specifically, the Uniform Guidance
requires that grant funding opportunities be publicly announced and
contain certain information, such as the evaluation criteria, key dates, and
the process used to evaluate applications. 52 Based on our review of

50
  As discussed earlier, in fiscal year 2011, Congress began providing funding for the Title
XVI program without project-specific funding direction; Reclamation then determines how
much funding to award to specific projects. In fiscal years 2017 and 2018, Congress
provided direction on how much funding should go to individually congressionally
authorized versus WIIN Act-eligible projects.
51
  As noted previously, although the Uniform Guidance became effective in December
2014, it did not substantially revise the provisions analyzed in this report.
52
  2 C.F.R. § 200.203. See also 2 C.F.R. pt. 200, appx. I, for the required format and
contents of a notice of funding opportunity.




Page 33                                                           GAO-19-110 Water Reuse
FOAs, Reclamation’s FOAs were publicly announced and contained this
information.

Many project sponsors we interviewed said that Reclamation’s Title XVI
application selection process is generally clear and well-managed and
that Reclamation officials, at both the regional level and central office in
Denver, were responsive and transparent throughout the selection
process. Several project sponsors noted that Reclamation offered to
debrief with Title XVI applicants after it made its grant selections; further,
Reclamation officials provided constructive feedback to applicants to
improve their applications in future years.

Some project sponsors raised concerns about how long it takes WIIN Act-
eligible Title XVI projects to be awarded grants. In particular, the WIIN Act
provides that WIIN Act-eligible projects can only receive funding if an
enacted appropriations act designates funding by project name, after
Reclamation has recommended specific projects for funding and
transmitted its recommendations to Congress. 53 Given the timing of
Reclamation’s FOA process, WIIN Act-eligible projects selected in a given
fiscal year generally need to be included in the subsequent fiscal year’s
appropriations act. 54 For example, congressional direction in May 2017
provided that $10 million of the total Title XVI funding was to go to Title
XVI WIIN Act-eligible projects, and Reclamation sent Congress its fiscal
year 2017 selections for WIIN Act-eligible projects to fund in November
2017. However, according to Reclamation officials, Reclamation could not
begin awarding fiscal year 2017 funding to selected projects until March
2018, after enactment of the fiscal year 2018 appropriations act, which
listed the selected projects by name. One project sponsor noted that this
two-part process created challenges related to the project timeline and
budget. Reclamation officials said that project sponsors have also
expressed concerns to Reclamation about how any resulting delays may
affect the ability of projects to move forward. Reclamation officials noted
that this is a statutory requirement and that they had discussed this
process with project sponsors to make them aware of the timing for the
grants.

53
 43 U.S.C. § 390h(g)(2).
54
  Title XVI projects are funded through the Water and Related Resources account, which
generally receives no-year appropriations. Such appropriations are available for obligation
for an indefinite period of time. A no-year appropriation is generally identified by
appropriation language, such as “to remain available until expended.”




Page 34                                                           GAO-19-110 Water Reuse
Criteria Used to Evaluate   Reclamation has changed the evaluation criteria it uses to select projects
Projects Have Changed in    to fund under the Title XVI program since it began using a competitive
                            process in fiscal year 2011. Reclamation first developed criteria for the
Recent Years
                            annual Title XVI project selection process in 2010, which it applied
                            starting in fiscal year 2011. Prior to that, Congress generally provided
                            project-specific funding direction for individually authorized Title XVI
                            projects. According to agency officials, Reclamation developed the initial
                            evaluation criteria for the annual Title XVI selection process based on
                            (1) the language in the Reclamation Wastewater and Groundwater
                            Studies and Facilities Act, as amended; (2) Reclamation goals and
                            priorities for the program; and (3) the criteria Reclamation used to select
                            projects to fund under the American Recovery and Reinvestment Act of
                            2009. 55 Reclamation sought and incorporated public comments on the
                            criteria in 2010. After that, Reclamation’s evaluation criteria for Title XVI
                            construction projects generally remained unchanged from fiscal years
                            2011 through 2016. 56

                            In fiscal years 2017 and 2018, Reclamation eliminated some criteria in
                            the Title XVI FOAs for construction projects, added some new criteria,
                            and changed the weighting of some criteria, based on our review of FOAs
                            for those years. 57 For example, in 2017, Reclamation more than doubled
                            the weight of the economic criterion for the fiscal year 2017 FOA for WIIN
                            Act-eligible projects, making it worth 35 percent of the points as
                            compared to the previous 13 percent. Reclamation officials told us that
                            these changes were made in response to the language of the WIIN Act—
                            which listed a number of criteria for projects, including projects that
                            provide multiple benefits—and comments they received from OMB during

                            55
                              After the American Recovery and Reinvestment Act of 2009, which provided a
                            supplemental appropriation to the Title XVI program, was enacted, Reclamation quickly
                            developed criteria to use in awarding funding to authorized Title XVI projects, according to
                            Reclamation officials.
                            56
                              According to agency officials and documents, Reclamation reviews the Title XVI
                            evaluation criteria every year and made some edits to clarify or otherwise improve the
                            criteria it used in fiscal years 2011 through 2016.
                            57
                              For example, in fiscal year 2018, Reclamation added a criterion related to Interior
                            priorities and eliminated a criterion related to energy efficiency. See appendix II for a
                            description of the changes Reclamation made in fiscal years 2017 and 2018 to the
                            evaluation criteria for construction projects. The evaluation criteria for feasibility studies
                            have generally remained the same since they were first used in fiscal year 2011.
                            Reclamation made some changes to the evaluation criteria for research studies in fiscal
                            year 2017.




                            Page 35                                                               GAO-19-110 Water Reuse
the review process for the revised criteria. 58 In March 2018, Reclamation
proposed further revisions to the evaluation criteria for the fiscal year
2018 Title XVI program and held a public comment period to solicit input
on the proposed changes. 59 The proposed FOA contained one set of
criteria applicable to both types of eligible Title XVI construction
projects—individually congressionally authorized and WIIN Act-eligible
projects. 60 Reclamation received 21 comment letters on the criteria and,
after analyzing the comments, officials said that they made additional
changes to some of the criteria before issuing the final fiscal year 2018
FOA on May 30, 2018. For example, Reclamation added clarification to
the economic criteria. See appendix II for a more detailed description of
the final fiscal year 2018 Title XVI criteria, as well as changes to the
criteria in fiscal years 2017 and 2018.

Several project sponsors noted that changes to the evaluation criteria
may affect which projects are more competitive in Reclamation’s
application scoring and project selection process. In particular, several
project sponsors and representatives from nongovernmental
organizations we interviewed told us they believed that recent changes—
particularly the increased weight on economic criteria, including cost
effectiveness—may disadvantage small projects. Others said increasing

58
  Specifically, under the WIIN Act, Reclamation is to give funding priority to Title XVI
projects that, among other things, meet one or more of the statutory criteria, which are
projects (1) that are likely to provide a more reliable water supply for states and local
governments; (2) that are likely to increase the water management flexibility and reduce
impacts on environmental resources from projects operated by federal and state agencies;
(3) that are regional in nature; (4) with multiple stakeholders; and (5) that provide multiple
benefits, including water supply reliability, eco-system benefits, groundwater management
and enhancements, and water quality improvements. 43 U.S.C. § 390h(f)(2), (3).
According to Reclamation officials, OMB does not review the Title XVI evaluation criteria
every year but did so in fiscal year 2017.
59
  Reclamation officials stated that they would have preferred to hold a formal comment
period on these changes before issuing the fiscal year 2017 FOA for WIIN Act-eligible
projects, as they said it is general practice within the program to hold a comment period
when substantial changes are made. However, Reclamation officials stated they did not
have time to hold a comment period and also issue the fiscal year 2017 FOA for WIIN Act-
eligible projects and select projects to fund before the end of the fiscal year, given that the
WIIN Act was enacted in December 2016.
60
  While Reclamation issued one FOA with one set of criteria for individually
congressionally authorized and WIIN Act-eligible construction projects in fiscal year 2018,
the funding is split, since congressional direction indicated that out of the total for Title XVI
projects, $20 million should go toward WIIN Act-eligible Title XVI projects, leaving the
remainder, approximately $34 million, for individually congressionally authorized Title XVI
projects.




Page 36                                                               GAO-19-110 Water Reuse
                        the weight on cost effectiveness may disadvantage new projects that are
                        just beginning construction of costly new treatment facilities versus
                        projects that are expanding existing facilities. Reclamation officials we
                        interviewed stated that the economic criteria take into account the extent
                        to which projects would provide multiple benefits—not just cost
                        effectiveness. They also pointed out that they clarified in the fiscal year
                        2018 FOA that there are a number of ways to provide information on
                        project benefits in Title XVI applications, including by describing benefits
                        in a qualitative manner. They added that feedback from project sponsors
                        had been positive on the additional changes Reclamation made in
                        response to earlier stakeholder comments on the economic criteria for the
                        final fiscal year 2018 FOA. Furthermore, Reclamation’s increased
                        emphasis on economic criteria is consistent with federal principles on
                        federal spending for water infrastructure projects, which states that
                        federal infrastructure investments are to be based on systematic analysis
                        of expected benefits and costs. 61


                        To monitor Title XVI grants, Reclamation reviews financial and
Reclamation’s           performance reports submitted by project sponsors, regularly
Process for             communicates and visits with project sponsors to obtain information on
                        the status of the projects, and collects information on the amount of water
Monitoring Title XVI    Title XVI projects deliver each year, which is included in Interior’s annual
Grants Is Consistent    performance report.
with Relevant Federal   •    Financial and Performance Reports. In its financial assistance
Grant Regulations            agreements for Title XVI grants, Reclamation generally requires
                             project sponsors to submit financial and performance reports.
                             Specifically, Reclamation generally requires that project sponsors
                             submit financial and performance reports at least once per year and
                             sometimes more frequently, as determined by the risk that each
                             project poses, according to agency officials. Based on our review of
                             reports, the financial reports list transactions related to Title XVI
                             grants, such as expenditures, and the performance reports provide
                             updates on the status of the Title XVI projects. Reclamation
                             delineates its monitoring requirements, which generally include
                             requirements for financial and performance reports, in the financial

                        61
                          For example, Executive Order 12893 directs executive agencies to base decisions about
                        federal infrastructure investments on an analysis of benefits and costs, including both
                        quantitative and qualitative measures. Exec. Order No. 12,893, 59 Fed. Reg. 20 (Jan. 26,
                        1994).




                        Page 37                                                        GAO-19-110 Water Reuse
     assistance agreements for Title XVI grants that each project sponsor
     agrees to prior to receiving funding. In our review of documents
     related to Reclamation’s monitoring process for Title XVI construction
     grants active in fiscal year 2017, we found that project sponsors
     submitted all but one financial and performance reports that
     Reclamation had required, and submitted all but two by their due date
     or within 2 weeks of this date. 62 We found that Reclamation’s
     requirements are consistent with relevant federal grant regulations in
     OMB’s Uniform Guidance, which provide that federal awarding
     agencies, including Reclamation, generally are to collect financial
     reports from project sponsors at least annually. 63
•    Ongoing Communication and Site Visits. To further monitor the
     performance of Title XVI grants, Reclamation officials communicate
     regularly with project sponsors via telephone and email and conduct
     site visits to obtain information on the status of the projects, according
     to Reclamation officials and project sponsors. Based on our review of
     agency guidance, Reclamation generally is to conduct at least one
     site visit per year for projects with significant on-the-ground activities,
     such as construction projects. During the visits, agency officials
     generally are to receive updates on progress made on the project and
     determine if it is on schedule and meets the scope of work identified in
     the financial assistance agreement. 64 Reclamation generally requires
     officials to document these visits and other monitoring activities in
     project files, according to agency documents. Through the site visits

62
   Of the 18 construction project grants active in fiscal year 2017 with reports required by
their financial assistance agreements, all 18 project sponsors submitted all required
financial reports and 17 project sponsors submitted all required performance reports. One
project sponsor did not submit a financial report and a performance report by their due
date or within 2 weeks of this date. In addition, for two grants, it was unclear whether the
project sponsors submitted financial and performance reports on time because the reports
did not contain dates.
63
  2 C.F.R. § 200.327. For construction performance monitoring, the Uniform Guidance
does not prescribe how or in what frequency this monitoring should occur, but says that
onsite inspections and certified percentage of completion data are relied on heavily by
federal awarding agencies to monitor progress under federal awards for construction. 2
C.F.R. § 200.328(c). As noted previously, although the Uniform Guidance became
effective in December 2014, it did not substantially revise the provisions analyzed in this
report.
64
  Department of the Interior, Bureau of Reclamation, The Bureau of Reclamation
Acquisition Circular (RAC) No. 16-08, Fiscal Year (FY) 2016 Implementation
Requirements for the Reclamation Manual, Directive and Standard (D&S), ACM 01-01
(Denver, CO: March 17, 2016). According to Reclamation, as of September 2018, this was
the current version of the implementation policies.




Page 38                                                             GAO-19-110 Water Reuse
                        and other communication with project sponsors, agency officials may
                        also provide information on program requirements and respond to
                        project sponsors’ questions about the Title XVI program. For example,
                        during site visits, Reclamation officials have responded to project
                        sponsors’ questions about the status of payments and allowable
                        project costs and clarified requirements for financial and performance
                        reports, according to our review of agency documents and interviews
                        with project sponsors. In our review of Reclamation’s Title XVI
                        construction grants active in fiscal year 2017, we found that
                        Reclamation generally conducted annual site visits for Title XVI
                        construction projects that year. We found that this is consistent with
                        federal grant regulations in OMB’s Uniform Guidance, which state that
                        federal awarding agencies may make site visits as warranted by
                        program needs. 65
                  •     Data Collection. Reclamation also annually collects data on the
                        amount of water delivered from each Title XVI construction project, as
                        well as projected water deliveries for the coming year. Reclamation
                        analyzes the water delivery data, compares projected data to actual
                        deliveries, and follows up with project sponsors to understand any
                        discrepancies, according to agency officials. For example, actual
                        water deliveries could be lower than projected deliveries if
                        communities implement water conservation measures that result in
                        projects having less wastewater to treat and deliver for reuse.
                        According to Reclamation officials, information on the amount of
                        reused water delivered from Title XVI projects helps them to monitor
                        progress on Title XVI projects and helps demonstrate the benefits and
                        accomplishments of the Title XVI program. These data are
                        consolidated and included in Interior’s annual performance report to
                        demonstrate how the agency is meeting Interior’s objective of
                        achieving a more sustainable and secure water supply. Collecting
                        data on Title XVI water deliveries is consistent with the Title XVI
                        program’s purpose of supporting water supply sustainability by
                        providing financial and technical assistance to local water agencies for
                        the planning, design, and construction of water reuse projects.

                  We provided a draft of this report to the Department of the Interior for
Agency Comments   review and comment. The Department of the Interior provided technical
                  comments, which we incorporated as appropriate.


                  65
                      2 C.F.R. § 200.328(e).




                  Page 39                                                  GAO-19-110 Water Reuse
As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies to the appropriate
congressional committees, the Secretary of the Interior, and other
interested parties. In addition, the report will be available at no charge on
the GAO website 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 fennella@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 III.




Anne-Marie Fennell
Director, Natural Resources and Environment




Page 40                                                 GAO-19-110 Water Reuse
Appendix I: Information on Construction
               Appendix I: Information on Construction
               Projects Eligible under the Title XVI Water
               Reclamation and Reuse Program


Projects Eligible under the Title XVI Water
Reclamation and Reuse Program
               This appendix provides information on construction projects that are
               individually congressionally authorized under the Bureau of Reclamation’s
               Title XVI Water Reclamation and Reuse Program (Title XVI), as well as
               projects to which Reclamation awarded grants under the Water
               Infrastructure Improvements for the Nation Act (WIIN Act) funding
               opportunity in fiscal year 2017. Figure 9 below provides information on
               the 53 construction projects that have been individually authorized by
               Congress under the Title XVI program. The projects are ordered by the
               total amount of Title XVI funding each was awarded from fiscal years
               1992 through 2017, from highest to lowest.




               Page 41                                              GAO-19-110 Water Reuse
                                        Appendix I: Information on Construction
                                        Projects Eligible under the Title XVI Water
                                        Reclamation and Reuse Program




Figure 9: Information on Individually Congressionally Authorized Water Reuse Construction Projects under the Bureau of
Reclamation’s Title XVI Water Reclamation and Reuse Program, as of August 2018




                                        Page 42                                                     GAO-19-110 Water Reuse
Appendix I: Information on Construction
Projects Eligible under the Title XVI Water
Reclamation and Reuse Program




Page 43                                       GAO-19-110 Water Reuse
Appendix I: Information on Construction
Projects Eligible under the Title XVI Water
Reclamation and Reuse Program




Page 44                                       GAO-19-110 Water Reuse
Appendix I: Information on Construction
Projects Eligible under the Title XVI Water
Reclamation and Reuse Program




Note: Amounts are in nominal dollars, which are not adjusted for inflation.
a
 This column describes some uses of the reused water produced by each Title XVI project but may
not encompass all uses for each project.
b
    This project is a demonstration project with no stated uses of the reused water.
c
    This project was under construction or had plans to be constructed.
d
    There were no plans to move forward with this project as of August 2018.
e
 According to Bureau of Reclamation data, the full federal cost share for this project was met with
funding from the Department of the Interior’s Bureau of Indian Affairs. The Bureau of Reclamation did
not collect water delivery information for this project in 2017.




Page 45                                                                       GAO-19-110 Water Reuse
Appendix I: Information on Construction
Projects Eligible under the Title XVI Water
Reclamation and Reuse Program




f
 Indirect-potable reuse is the intentional addition of treated municipal wastewater to a drinking water
source such as a lake or reservoir or groundwater aquifer, often referred to as an environmental
buffer. When reused water is added to a groundwater aquifer, it may be referred to as groundwater
recharge. Typically, groundwater recharge is accomplished through spreading basins that allow the
water to naturally percolate through the soil to the aquifer or by means of injection wells that deliver
the water directly to a specified location in the aquifer.
g
Desalination treats brackish groundwater or seawater and then generally feeds it directly into potable
water distribution systems or into a groundwater aquifer or surface water reservoir.
h
 Habitat restoration includes one Title XVI project that built constructed wetlands, which are treatment
systems that use natural processes to treat wastewater.
i
According to Bureau of Reclamation data, this project also received $334,500 in other federal
funding, which is not included in the Title XVI funding awarded but does count toward the federal
ceiling.


Figure 10 below provides information on the three construction projects to
which Reclamation awarded grants under the Title XVI WIIN Act funding
opportunity in fiscal year 2017. The projects are ordered by the total Title
XVI funding each was awarded in fiscal year 2017—the first year that
grants were awarded under the WIIN Act—from highest to lowest.

Figure 10: Information on Bureau of Reclamation’s Title XVI Water Reuse
Construction Project Awards under the Water Infrastructure Improvements for the
Nation Act, as of August 2018




Note: Amounts are in nominal dollars, which are not adjusted for inflation.
a
 This column describes some uses of the reused water produced by each Title XVI project but may
not encompass all uses for each project.
b
 Indirect-potable reuse is the intentional addition of treated municipal wastewater to a drinking water
source such as a lake or reservoir or groundwater aquifer, often referred to as an environmental
buffer. When reused water is added to a groundwater aquifer, it may be referred to as groundwater
recharge. Typically, groundwater recharge is accomplished through spreading basins that allow the
water to naturally percolate through the soil to the aquifer or by means of injection wells that deliver
the water directly to a specified location in the aquifer.



Page 46                                                                       GAO-19-110 Water Reuse
Appendix II: Information on the Evaluation
               Appendix II: Information on the Evaluation
               Criteria Used to Select Projects to Award
               Grants under the Title XVI Program


Criteria Used to Select Projects to Award
Grants under the Title XVI Program
               This appendix provides detailed information on the evaluation criteria the
               Bureau of Reclamation used to select projects to award grants under the
               Title XVI Water Reclamation and Reuse Program (Title XVI). The six
               evaluation criteria Reclamation used to select construction projects to
               fund in fiscal year 2018 are as follows (points are out of a total of 110
               points).

               1. Water Supply (35 points)
                   a. Stretching Water Supplies (18 points): Points will be awarded
                      based on the extent to which the project is expected to secure and
                      stretch reliable water supplies. Consideration will be given to the
                      amount of water expected to be made available by the project and
                      the extent to which the project will reduce demands on existing
                      facilities and otherwise reduce water diversions.
                   b. Contributions to Water Supply Reliability (17 points): Points will be
                      awarded for projects that contribute to a more reliable water
                      supply.
               2. Environment and Water Quality (12 points): Points will be awarded
                  based on the extent to which the project will improve surface,
                  groundwater, or effluent discharge quality; will restore or enhance
                  habitat for nonlisted species; will address problems caused by
                  invasive species; or will provide water or habitat for federally listed
                  threatened or endangered species. Indirect benefits of the project will
                  also be considered under this criterion.
               3. Economic Benefits (35 points)
                   a. Cost Effectiveness (10 points): Points will be awarded based on
                      the cost per acre-foot of water expected to be delivered upon
                      completion of the project and how the cost of the project
                      compares to a nonreclaimed water alternative.

                   b. Economic Analysis and Project Benefits (25 points): Points will be
                      awarded based on the analysis of the project’s benefits relative to
                      the project’s costs.

               4. Department of Interior Priorities (10 Points): Points will be awarded
                  based on the extent that the proposal demonstrates that the project
                  supports the Department of the Interior priorities, such as utilizing
                  natural resources and modernizing infrastructure.
               5. Reclamation’s Obligations and Benefits to Rural or Economically
                  Disadvantaged Communities (8 points)



               Page 47                                                GAO-19-110 Water Reuse
                                            Appendix II: Information on the Evaluation
                                            Criteria Used to Select Projects to Award
                                            Grants under the Title XVI Program




                                                a. Legal and Contractual Water Supply Obligations (4 Points): Points
                                                   will be awarded for projects that help to meet Reclamation’s legal
                                                   and contractual obligations.

                                                b. Benefits to Rural or Economically Disadvantaged Communities (4
                                                   Points): Points will be awarded based on the extent to which the
                                                   project serves rural communities or economically disadvantaged
                                                   communities in rural or urban areas.

                                            6. Watershed Perspective (10 Points): Points will be awarded based on
                                               the extent to which the project promotes or applies a watershed
                                               perspective by implementing an integrated resources management
                                               approach, implementing a regional planning effort, forming
                                               collaborative partnerships with other entities, or conducting public
                                               outreach.
                                            Reclamation changed some of its evaluation criteria in fiscal years 2017
                                            and 2018. The fiscal year 2017 changes were made in response to
                                            requirements in the Water Infrastructure Improvements for the Nation Act
                                            (WIIN Act)—which listed several criteria for projects, including projects
                                            that provide multiple benefits—and comments from the Office of
                                            Management and Budget, according to Reclamation officials. The fiscal
                                            year 2018 changes were generally made in response to comments
                                            Reclamation received during the formal comment period it held in March
                                            and April 2018 to solicit input on the criteria, according to Reclamation
                                            officials. The changes to the criteria are shown in table 4.

Table 4: Criteria the Bureau of Reclamation Used to Evaluate Title XVI Water Reclamation and Reuse Construction Projects,
Fiscal Years (FY) 2017 and 2018

                                                            Evaluation criterion score in Funding Opportunity Announcement
                                                                   (FOA) as a percentage of the total evaluation score
Evaluation criterion                                     FY2017 FOA for individually          FY2017 FOA for WIIN       FY2018 FOA for
                                                          congressionally authorized           Act-eligible Title XVI       all Title XVI
                                                                   Title XVI projects                      projectsa            projects
Water Supply                                                                             28                       28                  32
   Stretching Water Supplies                                                             18                       18                  16
                                            b
   Contributions to Water Supply Reliability                                             10                       10                  15
Economic Benefitsc                                                                    13                          35                  32
   Cost-Effectivenessd                                                              N/Ae                          10                   9
                                          f
   Economic Analysis and Project Benefits                                            N/A                          25                  23
Environment and Water Quality                                                            15                       12                  11
Watershed Perspective                                                                     8                        7                   9




                                            Page 48                                                              GAO-19-110 Water Reuse
                                                           Appendix II: Information on the Evaluation
                                                           Criteria Used to Select Projects to Award
                                                           Grants under the Title XVI Program




                                                                             Evaluation criterion score in Funding Opportunity Announcement
                                                                                    (FOA) as a percentage of the total evaluation score
Evaluation criterion                                                      FY2017 FOA for individually            FY2017 FOA for WIIN            FY2018 FOA for
                                                                           congressionally authorized             Act-eligible Title XVI            all Title XVI
                                                                                    Title XVI projects                        projectsa                 projects
Reclamation’s Obligations and Benefits to Rural or                                                         10                            10                        7
Economically Disadvantaged Communities                                                                      5                             5                        4
    Legal and Contractual Water Supply Obligations                                                          5                             5                        4
    Benefits to Rural or Economically Disadvantaged
    Communities
Department of Interior Priorities                                                                        N/A                            N/A                        9
Energy Efficiencyg                                                                                         13                              8                  N/A
Status of Title XVI Project                                                                                15                           N/A                   N/A
    Progress Toward Completion of Title XVI Project                                                        10                           N/A                   N/A
    Readiness to Proceed                                                                                    5                           N/A                   N/A
Source: GAO analysis of Reclamation’s FOAs. | GAO-19-110

                                                           Note: Due to rounding, percentages may not total when summed.
                                                           a
                                                            The Water Infrastructure Improvements for the Nation Act (WIIN Act) provided that projects with
                                                           feasibility studies that Reclamation had reviewed and submitted to Congress would be eligible for
                                                           Title XVI grants.
                                                           b
                                                            In the fiscal year 2017 FOAs for individually congressionally authorized and WIIN Act-eligible Title
                                                           XVI projects, Reclamation titled this criterion “contributions to water supply sustainability.”
                                                           c
                                                            In the fiscal year 2017 FOA for individually congressionally authorized projects, Reclamation titled
                                                           this criterion “cost per acre-foot of water and other project benefits.”
                                                           d
                                                            In the fiscal year 2017 FOA for WIIN Act-eligible Title XVI projects, Reclamation titled this
                                                           subcriterion “cost per acre-foot.”
                                                           e
                                                            Reclamation made changes to the evaluation criteria and in certain years, certain evaluation criterion
                                                           or subcriterion were not included. If an evaluation criterion was not included in a certain FOA, this is
                                                           indicated as not applicable (N/A).
                                                           f
                                                           In the fiscal year 2017 FOA for WIIN Act-eligible Title XVI projects, Reclamation titled this
                                                           subcriterion “economic analysis.”
                                                           g
                                                            In the fiscal year 2017 FOA for individually congressionally authorized projects, Reclamation titled
                                                           this criterion “renewable energy and energy efficiency.”




                                                           Page 49                                                                      GAO-19-110 Water Reuse
Appendix III: GAO Contact and Staff
                  Appendix III: GAO Contact and Staff
                  Acknowledgments



Acknowledgments


                  Anne-Marie Fennell, (202) 512-3841 or fennella@gao.gov
GAO Contact
                  In addition to the individual named above, Elizabeth Erdmann (Assistant
Staff             Director), Lesley Rinner (Analyst-in-Charge), Margaret Childs, and Sierra
Acknowledgments   Hicks made key contributions to this report. Ellen Fried, Timothy Guinane,
                  Thomas M. James, John Mingus, Patricia Moye, Anne Rhodes-Kline,
                  Sheryl Stein, and Sara Sullivan made additional contributions.




(102402)
                  Page 50                                              GAO-19-110 Water Reuse
                         The Government Accountability Office, the audit, evaluation, and investigative
GAO’s Mission            arm of Congress, exists to support Congress in meeting its constitutional
                         responsibilities and to help improve the performance and accountability of the
                         federal government for the American people. GAO examines the use of public
                         funds; evaluates federal programs and policies; and provides analyses,
                         recommendations, and other assistance to help Congress make informed
                         oversight, policy, and funding decisions. GAO’s commitment to good government
                         is reflected in its core values of accountability, integrity, and reliability.

                         The fastest and easiest way to obtain copies of GAO documents at no cost is
Obtaining Copies of      through GAO’s website (https://www.gao.gov). Each weekday afternoon, GAO
GAO Reports and          posts on its website newly released reports, testimony, and correspondence. To
                         have GAO e-mail you a list of newly posted products, go to https://www.gao.gov
Testimony                and select “E-mail Updates.”

Order by Phone           The price of each GAO publication reflects GAO’s actual cost of production and
                         distribution and depends on the number of pages in the publication and whether
                         the publication is printed in color or black and white. Pricing and ordering
                         information is posted on GAO’s website, https://www.gao.gov/ordering.htm.
                         Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
                         TDD (202) 512-2537.
                         Orders may be paid for using American Express, Discover Card, MasterCard,
                         Visa, check, or money order. Call for additional information.

                         Connect with GAO on Facebook, Flickr, Twitter, and YouTube.
Connect with GAO         Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts.
                         Visit GAO on the web at https://www.gao.gov.

                         Contact:
To Report Fraud,
                         Website: https://www.gao.gov/fraudnet/fraudnet.htm
Waste, and Abuse in
                         Automated answering system: (800) 424-5454 or (202) 512-7700
Federal Programs
                         Orice Williams Brown, Managing Director, WilliamsO@gao.gov, (202) 512-4400,
Congressional            U.S. Government Accountability Office, 441 G Street NW, Room 7125,
Relations                Washington, DC 20548

                         Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800
Public Affairs           U.S. Government Accountability Office, 441 G Street NW, Room 7149
                         Washington, DC 20548

                         James-Christian Blockwood, Managing Director, spel@gao.gov, (202) 512-4707
Strategic Planning and   U.S. Government Accountability Office, 441 G Street NW, Room 7814,
External Liaison         Washington, DC 20548




                            Please Print on Recycled Paper.