Detailed Information on the
EPA Tribal General Assistance Program Assessment

Implementation of the GAP tracking system proceeds. Regional training will occur Sept-Dec. 2007. System evaluation and updated recommendations are scheduled for Feb. 2008, with any necessary system updates occurring in March-May 2008.

Implementation of the GAP tracking system proceeds. Regional training will occur Sept-Dec. 2007. System evaluation and updated recommendations are scheduled for Feb. 2008, with any necessary system updates occurring in March-May 2008.

A long term measure for GAP related to solid waste issues and activities is being developed.

Measure: Percent of homes on tribal lands lacking access to basic sanitation

Explanation:2003 Baseline: Indian Health Service data indicate that 8.4 percent of homes on tribal lands lack access to basic sanitation (i.e., 26,777 homes lacking access out of an estimated 319,070 homes). Progress will be measured annually against the static year baseline (2003). To report annual progress, homes served by federally-funded projects will be subtracted from the baseline figures. By the year 2015, the goal is to reduce by half (from 8.4% to 4.2%) the number of homes on tribal lands lacking access (i.e., 13,389 homes lacking access out of an estimated total of 319,070 homes on tribal lands). Historical information is as follows: 2003 - 8%, 2004 - 7.63%, 2005 - 6.64, 2006 - 6.73%

Measure: Percent of homes on tribal lands lacking access to drinking water

Explanation:The measure closely tracks performance by focusing on individual measurable units (houses) rather than variable units (households, whose number per house is not consistent). This measure has been previously reviewed and accepted by OMB. Historical information is as follows: 2003 - 12.8%, 2004 - 11.3%, 2005 - 11.0%, 2006 - 10.5%

Measure: Number of baseline monitoring stations showing improved water quality in tribal waters.

Explanation:BRIEF: Improvment in water quality in tribal waters based on monitoring of seven key parameters - dissolved oxygen, pH, water temperature, total nitrogen, total phosphorus, pathogen indicators, and turbidity - at 185 monitoring stations located where water quality has been depressed and activities are underway or planned to improve water quality. The revised measures includes a broader set of parameters and a reporting structure consistent with EPA Guidance on Awards of Grants to Indian Tribes under Section 106 of the Clean Water Act available at http://www.epa.gov/owm/cwfinance/106tgg07.htm. and is consistent with the EPA 2008-2011 Strategic Plan. The revised target reflects improved understanding of how many tribal stations are planned, and where monitoring will occur relative to areas of depressed water quality and restoration activities.

Measure: Percent of tribes with an environmental program.

Explanation:BRIEF: GAP is a capacity building grant program that encourages Indian tribes to become self reliant in relation to their environmental needs and problems. One such indication of this is whether or not a tribe has an environmental program. This is considered the most basic measure of GAP, and is equivalent to Step One. This measure will track a tribe as having an environmental program if the tribal government has taken at least one of the following actions, in combination with having "an organizational structure which includes EPA-funded environmental office or coordinator that has been staffed in the most recent year": ?? complete a Tier III TEA, as evidenced by a document signed by the tribal government and EPA, ?? established environmental laws, codes, regulations, ordinances, resolutions, policies or environmental compliance program as evidenced by a document signed by the tribal government, ?? complete solid and/or hazardous waste implementation activities, or ?? complete an inter-governmental environmental agreement (e.g. state-Tribe MOA, Federal-Tribe MOA etc) ------------------------ This measure is viewed as step 1 in the progression toward actual implementation of environmental programs. This measure includes a variety of activities that are included in developing an environmental program. Activities such as the development of Tier III TEAs requires not only identifying specific environmental and programmatic issues and goals, but also developing a common agreement between EPA and the tribe on the resources to use to address the issues. The establishment of laws codes and ordinances are clear indicators of the establishement of an environmental program infrastructure. The completion of solid and hazardous waste implementation activities demonstrates success capacity building efforts. The completion of inter-governmental environmental agreements demonstrates the capability to communicate and interact successfully other environmental management entities.

Measure: Percent of tribes conducting EPA-approved environmental monitoring and assessment activities in Indian country.

Explanation:The GAp program is intended to help Indian tribes be able to administer environmental programs on their tribal lands. This measure represents the second step in achieving that result by focusing on tribes undertaking environmental monitoring and assessment activities on their lands. This step is a higher progression than the previous step, and will utlimately lead to step 3, which is actual implementation of regulatory programs.

Measure: Percent of tribes implementing federal regulatory environmental programs in Indian country

Explanation:BRIEF: One purpose of GAP is to build capacity to administer environmental regulatory programs that may be delegated by EPA. This measure allows EPA to specifically track federal regulatory environmental program delegations. This is considered step 3 in the progression of a tribe's ability to administer regulatory programs on their tribal lands. Not all tribes will be able to achieve this, nor should one expect them to.

Measure: Number of environmental programs implemented in Indian country per million of dollars

Explanation:The GAP efficiency measure, "Number of environmental programs implemented in Indian country per million of dollars," is calculated annually by summing the number of tribes receiving GAP grants, the number of TAS approvals or primacies, the number of Direct Implementation Cooperative Tribal Agreements (DICTAs), and the number of GAP grants that have provisions for the implementation of solid and hazardous waste programs and dividing that sum by the annual GAP appropriation (less rescissions and annual set-asides). See Table 4.3 for the targets and actual performance under the GAP efficiency measure.

Is the program purpose clear?

Explanation: GAP has a clear and unambiguous mission. The Indian Environmental General Assistance Program Act of 1992 ("GAP") clearly states Congressional intent. In authorizing the GAP, Congress clearly stated the purpose as: (1) provide general assistance grants to Indian tribal governments and intertribal consortia to build capacity to administer environmental regulatory programs that may be delegated by the Environmental Protection Agency on Indian lands; and

(2) provide technical assistance from the Environmental Protection Agency to Indian tribal governments and intertribal consortia in the development of multimedia programs to address environmental issues on Indian lands. EPA is responsible for administering federal environmental statutes on all U.S. lands, including Indian country. EPA recognizes tribal governments as the primary parties for making environmental policy decisions and implementing environmental programs that affect Indian communities. The primary purpose of GAP is to help federally-recognized tribes and tribal consortia build the basic components of a tribal environmental program, which may include planning, developing, and establishing the administrative, technical, legal, enforcement, communication, and outreach infrastructure. In fiscal year 2006, GAP distributed over $57.5 million in funds to over 400 tribes and tribal consortia. EPA implements the program through the provision of funding appropriated by Congress to tribal governments and eligible intertribal consortia, through the provision of direct technical support, and by providing access programmatic resources as they develop and establish environmental management programs. The GAP has become both a core tribal environmental program and a core EPA program, representing the largest single source of funding for tribal environmental programs awarded by EPA. The GAP has increased from an original $8.5 million in 1994 to over $57.5 million for the year 2006.

Evidence: The Indian General Environmental Assistance Program, 42 U.S.C. §4368b

Does the program address a specific and existing problem, interest, or need?

Explanation: GAP is the sole funding available for a capacity-building environmental presence. Tribes are far behind states in their ability to administer environmental regulatory programs delegated by EPA. Prior to GAP, Congress adopted statutory language making tribes eligible for delegated environmental programs, but tribes lacked the capacity to administer such program. In response to this clear need, Congress enacted GAP to allow tribes to develop the technical, legal and administrative infrastructure necessary for effective environmental regulation. Environmental issues are critically important to tribal governments who are responsible for maintaining viable, permanent homelands for their people. The historical disparity between the financial and technical assistance that EPA provides to states and the assistance that it has provided to tribes is significant. For the last 30 years, EPA has provided financial support for the efforts of state governments to develop comprehensive environmental protection programs and to develop capacities to directly administer federally delegated programs. For the most part, tribal governments were overlooked in the early federal efforts to regulate environmental quality and were progressively left further behind and less able to compete on even footing for available funding. For example: ?? EPA estimates current needs of $614 million for tribal wastewater treatment systems and $2.4 billion for safe drinking water. ?? Tribal drinking water systems reported more violations of health-based standards or significant violations of monitoring/reporting requirements than those outside of Indian country. ?? The vast majority of surface waters in Indian country have no water quality standards under the Clean Water Act. ?? Currently, there are 1,104 open dumps in Indian country, as reported to Congress by the Indian Health Service. [Sources: EPA Tribal Enterprise Architecture Data System] The GAP program is targeted for maximum impact by providing an environmental presence for each tribe. In the first four years after the enactment of the GAP in 1992, less than one-fifth of the approximately 570 tribes and Alaska Native villages were able to receive grant awards under this program. As Congress increased the GAP funding over the years, more tribal governments were able to receive assistance. Currently over 400 tribes receive assistance. The GAP program has and continues to serve a vital role in environmental capacity development. Tribes are still far behind states in their ability to administer environmental regulatory programs delegated by EPA. For example, 90 percent of states have delegated authority for water, compared to only 7.1 percent of tribes. [SOURCE: EPA Office of Water http://cfpub.epa.gov/npdes/statestats.cfm and http://www.epa.gov/waterscience/standards/wqslibrary/tribes.html].

Evidence: 1. The Indian General Environmental Assistance Program, 42 U.S.C. §4368b; 2. Indian Environmental General Assistance Program: Introduction to Senate, S. 654, 103rd Cong. (March 25, 1993)(statement of Senator John McCain)

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: BRIEF: GAP's focus on multi-media assessment and capacity building is unique in EPA and the federal agencies. There are no other significant resources available to tribes for purposes similar to GAP. ---------------------- GAP is designed to make a unique contribution in addressing environmental capacity building in Indian country. This is distinct from other federal efforts in that GAP is the only funding available to tribal governments that enables them to develop the multimedia technical, legal and administrative infrastructure necessary for effective multimedia environmental regulation. Tribes generally do not have the internal resources available to focus on environmental issues. Apart from the GAP, other program grants available to tribal governments are more narrowly focused, often competitive, and for very short funding durations. While there are some U.S. Health and Human Service (HHS) and U.S. Bureau of Indian Affairs (BIA) programs, such as the Administration for Native Americans (ANA) and Tribal Priority Allocation (TPA), as described below, where funds may be used for tribal environmental program development, GAP is the only program designed specifically for the purpose of building environmental capacity.

Evidence: 1. The Indian General Environmental Assistance Program, 42 U.S.C. §4368b; 2. GAP Program Guidelines, section II, part B (2000); 3. Description of Federal Programs

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: EPA has provided capacity-building flexibility in grants for environmental program development to states via categorical grants for over three decades and GAP follows a similar model by providing similar resources to tribes. There is no compelling evidence that another approach or mechanism would be more efficient or effective to achieve the intended purpose. The GAP is designed to make a unique contribution in addressing environmental capacity building in Indian country. The GAP is the only funding available to tribal governments that enable them to develop the multimedia technical, legal and administrative infrastructure necessary for effective multimedia environmental regulation. In addition, EPA implemented the Objective 5.3 Reporting System to standardize, centralize, and integrate EPA Regional data and assign accountability for data quality. EPA also developed the GAP Tracking System to improve data management and allow for rapid, real-time access to GAP information.

Evidence: 1. The Indian General Environmental Assistance Program, 42 U.S.C. §4368b; 2. FMFIA Memorandum (2006); 3. Objective 5.3 Reporting System; 4. GAP Tracking System; 5. EPA Indian Policy

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: BRIEF: GAP only targets federally-recognized tribal governments and intertribal consortia. --------------------------------------------------------------------------------- The GAP was enacted by Congress to correct a serious deficiency of environmental protection in Indian country. Environmental protection in Indian country suffered from an inability to develop effective environmental programs due to a lack of ground level personnel and a lack of financial resources. Congress gave EPA the responsibility to award GAP grants to tribal governments and intertribal consortia to build their capacity to develop and establish specific environmental protection programs. GAP funds are allocated by EPA in two phases: 1) at the national level and 2) at the Regional level. At the national level, the American Indian Environmental Office (AIEO), as National Program Manager, distributes the funding via reprogramming to Regions. This is done through the GAP allocation formula. The GAP allocation formula was first developed in 1993 and modified in 1997 to adapt to program growth. It is based on population, number of tribes, and land area for the 9 EPA Regions that have federally-recognized tribes and revised annually based on tribal recognition. Once the potential funding level for each EPA region is determined by formula, the funds are allocated to each region so that at a minimum, if applicable funding levels are available, each region receives $110,000 per tribe. Under the GAP Act, the minimum award to a tribe is $75,000. The initial step recommended by EPA and taken by tribes is to hire a tribal government environmental professional. Hiring an environmental professional, including benefits, training, travel, equipment, supplies, contracts, indirect costs, and other basic costs associated with building capacity, indicate that $110,000 is a realistic but conservative estimate of a tribe's annual GAP funding needs. At the Regional level, after receiving the allocation of funding from AIEO, the region can distribute the funding to tribes through two approaches: 1) the continuity of funding method or 2) the priority funding method. The continuity method is used where tribes are continuing to develop environmental programs and are focused on specific program elements. In these cases, funding decisions are based on discussions of what elements of a program development proposal may be addressed via limited GAP funding. Under the priority method, the funding decisions may vary by tribe as determined by regional review. For both methods, regional decisions are contingent on grantee performance under the GAP agreement to meet timeframes and deliverables. In addition, the National Program Manager targets a limited amount of GAP set-aside funds towards projects of national program importance. The GAP National Set-Aside is a specific portion of the overall GAP appropriation that is "set aside" to support specific tribal or tribal consortia projects, as directed AIEO. The projects must have a national application or address a national program need identified by AIEO. Examples of National Set-Aside funded projects are financial management training to tribal financial managers on EPA's financial assistance agreements to ensure compliance with grant policies and program requirements and the implementation of Tribal EPA Agreements (TEAs). TEAs are a valuable tool in EPA's work with tribes to identify and address mutually shared environmental objectives.

Evidence: 1. The Indian General Environmental Assistance Program, 42 U.S.C. §4368b; 2. GAP program guidance , section 2 (2000); 3. GAP Allocation by Region; 4. EPA Tribal Environmental Agreement Template

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: BRIEF: The GAP long-term performance measures focus on outcomes and meaningfully reflect the purpose of the program. The goals are: 1) Percent decrease in the number of homes lacking access to basic sanitation; 2) Percent decrease in the number of homes on tribal lands lacking access to safe drinking water; and 3) Number (net) of baseline monitoring stations showing improved water quality in tribal waters. ----------------- The purpose of the GAP program is to: (1) provide general assistance grants to Indian tribal governments and intertribal consortia to build capacity to administer environmental regulatory programs that may be delegated by the Environmental Protection Agency on Indian lands; and (2) provide technical assistance from the Environmental Protection Agency to Indian tribal governments and intertribal consortia in the development of multimedia programs to address environmental issues on Indian lands. These measures reflect EPA's commitment to provide funds to help tribal governments improve the environment on Indian lands. The increase in the number of baseline monitoring stations showing improved water quality in tribal waters is based on monitoring of seven key parameters -dissolved oxygen, pH, water temperature, total nitrogen, total phosphorus, pathogen indicators, and turbidity - at 185 monitoring stations located where water quality has been depressed and activities are underway or planned to improve water quality, out of an estimated 1,661 stations operated by tribes. Tribes expected to begin reporting in 2008. EPA has changed the long-term measures in the EPA 2006-2011 Strategic Plan and intends to replace the GAP PART long-term performance measures with improved measures that much more precisely reflect the actual accomplishments generated by federal GAP funds. The method for collecting the information mirrors precisely the criteria of the proposed revised measure language. In addition to these measures, EPA's Strategic Plan includes a wider set of long term measures related directly to GAP's capacity building purpose. These will be further discussed in Section 2.3. See Table 2.1 for the explanation of the proposed measures and reason for change.

Evidence: 1. 42 U.S.C. §4368b; 2. EPA Strategic Plan Goal 2, Subobjectives 2.1.1 and 2.2.1; 3. Tribal Water Quality Improvement Measure Explanation for Revision; 4. Table 2.1 Long Term Measures

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: BRIEF: GAP has developed ambitious targets and timeframes for its long-term performance measures as described in the measures section. ------------------- The following long-term measures represent an innovative approach to measure performance that has not been attempted by federal agencies. It requires active cross-agency communication and involves specific long-term resource commitments to ensure success. They are also internationally recognized and adopted performance measures related to outcomes rather than a series of outputs. The baseline is the FY 2003 actual for some of the measures, and the FY 2007 actual for others. The targets represent ambitious, goals that reduce by half the percentage of homes lacking basic sanitation and drinking water. The water quality improvement target is set to show an improvement of over 25% (50 stations out of 185) by 2015, with an intermediate target of a 12% increase (25 stations out of 185) within the next 4 years (by 2011). See Table 2.2 for the targets and timeframes for the GAP long-term measures.

Evidence: 1. EPA Strategic Plan Goal 2, Subobjectives 2.1.1 and 2.2.1; 2. Tribal Water Quality Improvement Measure Explanation for Revision; 3. Table 2.2

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: BRIEF: The annual performance goals for GAP are a subset of the long-term goals set for the EPA Indian Program. They are: 1) Percent of tribes with an environmental program; 2) Percent of tribes implementing federal regulatory environmental program in Indian country; and 3) Percent of tribes conducting EPA-approved environmental monitoring and assessment activities in Indian country. ----------------- EPA established the following annual performance measures that accurately reflect the program's focus and demonstrate progress toward the long-term goals of the program. The GAP goal to provide funding for all eligible tribes and intertribal consortia directly reflects the purpose of the program which is building tribal environmental program capacity. Capacity building is the necessary prerequisite to environment assessment, program delegation, and receipt of technical assistance. The achievement of both annual and long-term goals is contingent on establishing the institutional capacity needed to understand, identify and address the priority issues for a specific tribe or for members of an intertribal consortia. GAP funding is both consistent and flexible in allowing tribes to put together the administrative and technical skills that are precursors to the full range of environmental programs that are possible under tribal law or delegated from EPA. See GAP Logic Model. The annual performance measures are: 1) Percent of tribes with an environmental program; 2) Percent of tribes implementing federal regulatory environmental program in Indian country; and 3) Percent of tribes conducting EPA-approved environmental monitoring and assessment activities in Indian country. AIEO is in the process of revising the GAP PART annual measures with improved measures that much more precisely reflect the actual accomplishments generated by federal GAP funds. The GAP program collects data in the Objective 5.3 Reporting System. This reporting system contains all the information for reporting on AIEO's performance measures and proposed PART measures. The method for collecting the information mirrors precisely the criteria of the proposed revised measure language. EPA tracks program performance based on specific performance data identified in the EPA Strategic Plan for the GAP annual measures listed here and the long-term measures listed under Section 2.1. See Table 2.3 for the explanation of the proposed measures and reason for the change.

Evidence: 1. Objective 5.3 Reporting System: 2. GAP Logic Model; 3. Table 2.3

Does the program have baselines and ambitious targets for its annual measures?

Explanation: BRIEF: Baseline targets have been established for GAP's annual measures. ------------ GAP has established baselines for all of its annual measures. The specific annual targets are quantified and provide a specific value with which performance can be compared. All targets are included for the years 2004 to 2007 with new targets developed for 2008 to 2011. The targets ensure continued improvement in public health benefits and environmental protection in Indian country. See Table 2.4 for the baselines and targets for the GAP annual measures.

Evidence: 1. Objective 5.3 Reporting System: 2. Table 2.4

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: BRIEF: GAP requires grantees to link their activities to meaningful program goals. ----------------------- The GAP work plans and quarterly reports (actual frequency may vary based on past recipient performance and regional oversight structure) are the primary tools for collecting timely and credible performance information. In the work plans, the recipient lays out clear goals, objectives and supporting activities. Additionally, the work plan negotiation requires certification by the EPA project officer that the work is in support of Objective 5.3 of EPA's Strategic Plan. The GAP program collects data in the Objective 5.3 Reporting System. This reporting system contains all the information for reporting on EPA's performance measures and proposed PART measures. All GAP grantees are required to use a standardized work plan format for FY2007 and beyond in negotiating GAP grant agreements. This standardized work plan format includes milestones, deliverables, link to the Agency's Strategic Plan, and environmental outcomes and outputs. The work plan ensures collection of the minimum information needed for national reporting purposes, consistent with statute, grant regulations, and EPA Orders. This allows AIEO, as the national program manager for GAP, to better characterize the environmental and public health benefits of these activities in a consistent manner. The structure of the standardized work plan format assists recipients in ensuring that they address applicable regulations in 40 CFR Part 35, Subpart B, the Indian General Assistance Program (GAP) 2006 Grant Administrative Guidance (71 FR 9547, Feb. 24, 2006), and assists EPA in complying with EPA Order 5700.7 "Environmental Results under EPA Assistance Agreements." In addition, Section 4 of the GAP 2006 Grant Administration Guidance provides examples of environmental outputs and outcomes for programmatic and administrative capabilities. It demonstrates the linkages to the Agency's goals, objectives, sub-objectives, and annual Program Activity Measures (PAMs) and provides samples of outputs and outcomes. Section 4 also contains a logic model, a graphical representation of the relationships between program inputs, outputs, and intended outcomes for GAP. Working with our tribal partners on the goals of GAP allows EPA and tribes to discuss alterations to the GAP program, such as addressing the need for a bridge between program development and implementation. It also demonstrates the effectiveness of resource investments in terms of public health and environmental improvement in Indian country. Additional benefits include promoting good grant management by tying in the goals in EPA's Strategic Plan with actual environmental results. Commitment to meeting the long term outcome goals of the GAP is visible both regionally and nationally. At the regional level, EPA has established Memorandum of Understanding (MOUs) with other federal agencies to focus their limited resources on tribal priorities. These MOUs identify federal responsibilities and provide a structure for identifying and addressing tribal priorities more effectively by specifying which resources from the respective agency that would be most effective to address that area. For example, EPA Region 8 is a signatory to the MOU 2000. Through this agreement, the region has been able to partner with other agencies to assist GAP-funded tribes addressing Emergency Response preparedness, and bombing range remediation. [Source: http://www.epa.gov/Region8/tribes/mou2000/projects.html]. At the national level, the Interagency Tribal Infrastructure Task Force has established MOUs that coordinate federal agency actions to meet public health commitments included in the Johannesburg Goals. A specific goal from this coordination is to streamlining the process for tribes to fund projects from multiple sources, allowing them to more effectively focus resources.

Evidence: 1. 40 CFR Part 35.507; 2. GAP Standardized Work Plan Template; 3. GAP program guidance, section 4 (2006); 4. EPA Order 5700.7 "Environmental Results under EPA Assistance Agreements; 5. R6 Tribal Work Plan; 6. Objective 5.3 Reporting System; 7. Draft MOUs under Johannesburg Agreements; 8. R8 MOU

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: The GAP Program Evaluation sponsored by the EPA Office of Policy, Economics and Innovation (OPEI) is of high quality and scope, unbiased and independent, and conducted to support program improvements, however it can not answer the question to what extent do GAP grants comport with OMB financial requirements. The American Indian Environmental Office (AIEO) applied for competitive funding assistance from OPEI for an evaluation to be conducted of the GAP program. Industrial Economics, Inc. (IEc) was selected to assess the impact of the GAP on tribal environmental capacity and help AIEO understand which elements of GAP contribute to the establishment of multi-media environmental programs, The final evaluation report was issued in May 2007. EPA also utilizes two principal methods for evaluating the GAP - programmatic and administrative evaluation. Programmatic evaluations are conducted on a regular basis through the review of grantee's quarterly reports and annual summaries by EPA project officers; joint EPA and grantee review of work plans; and close out activities related to the end of project periods. Administrative evaluations take three forms: 1) Tribes may commission audits by outside entities such as accounting firms; 2) EPA Regional grants administration staff may conduct regular reviews of financial work plan requests and financial statements; or 3) Regions may conduct site visits to review grantees administrative systems and compliance with grant responsibilities and work plan commitments. AIEO as the National Program Manager of the GAP conducts periodic site visits of Regional programs and grantees, and participates in Regionally-sponsored grant workshops to update tribes on basic grant management and technical program requirements. Finally, the EPA and DOI Offices of the Inspector General (OIG) recently reviewed a number of tribes to highlight the diversity of innovative tribal practices that will serve as models of success to other tribes in implementing natural resource and environmental programs. An additional review by EPA OIG of the GAP program is currently underway.

Evidence: 1. Final Methodology for the Tribal GAP Evaluation (Dec. 6, 2006;) 2. Preliminary GAP Evaluation Findings (Draft); 3. Memorandum on OIG Audit of Tribal Grants (Feb. 8, 2007;) 4. EPA and DOI Offices of Inspector General, Tribal Success (2007)

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: BRIEF: This is a grant program whose overall funding level is not directly tied to performance. At the grantee level, awards are sometimes tied to a minimally acceptable level of performance. At the national level, the American Indian Environmental Office (AIEO), as National Program Manager, distributes the funding via reprogramming to Regions. This is done through the GAP allocation formula. The GAP allocation formula was first developed in 1993 and modified in 1997 to adapt to program growth. It is based on population, number of tribes, and land area for the 9 EPA Regions that have federally-recognized tribes and revised annually based on tribal recognition. Once the potential funding level for each EPA region is determined by formula, the funds are allocated to each region so that at a minimum, if applicable funding levels are available, each region receives $110,000 per tribe. Under the GAP Act, the minimum award to a tribe is $75,000. At the Regional level, after receiving the allocation of funding from AIEO, the region can distribute the funding to tribes through two approaches: 1) the continuity of funding method or 2) the priority funding method. The continuity method is used where tribes are continuing to develop environmental programs and are focused on specific program elements. The priority method is used where overall funding need exceeds available funding. In these cases, funding decisions are based on discussions of what elements of a program development proposal may be addressed via limited GAP funding. Under the priority method, the funding decisions may vary by tribe as determined by regional review. For both methods, regional decisions are contingent on grantee performance under the GAP agreement to meet timeframes and deliverables. EPA believes the budget methods for allocation of the GAP funds used above are a practical, reasonable and prudent way to assist the maximum number of tribes with building and strengthening environmental protection. The overall grant level reflects all direct costs. Indirect costs of grant oversight are spread throughout EPA accounts.

Evidence: 1. GAP Allocation by Region

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: BRIEF: EPA continues to improve GAP performance through a series of e-government efforts, such as the GAP Tracking System, the Objective 5.3 Reporting System and the Tribal Program Enterprise Architecture. ------------ AIEO has taken several steps to strengthen the program in response to concerns raised during the first GAP PART review in 2003: ?? EPA has been reporting on annual performance measures as part of its Strategic Plan commitments. ?? AIEO created and continued to improve the GAP Tracking System to enable EPA to review performance both of individual grantees and to look at the aggregate national level. The revised system will be in place by June 2007 ?? AIEO updated GAP annual and long-term PART measures with a focus on improving both their ability to be representative, and for EPA to report consistently and accurately on performance. ?? Based on recommendations from OMB, the GAP program has developed and collected data for an efficiency measure ?? In addition, EPA implemented the Objective 5.3 Reporting System to standardize, centralize, and integrate EPA Regional data and assign accountability for data quality. ?? We have also continued to expand the number of data sources used and the integration of tribal data available under the Tribal Program Enterprise Architecture (TPEA), a database system for air, water, solid waste, hazardous waste, and toxics so regulated facilities and monitoring sites can be reported on a per tribe basis. This database ties together several EPA data systems and overlaps Indian country boundary information we have from the Bureau of Indian Affairs Geographic Data Service Center. TPEA also helps EPA retain sufficient programmatic control by providing an overall snapshot in program management, accountability, and performance measures.

Evidence: 1. GAP Tracking System; 2. Tribal Program Enterprise Architecture; 3. Objective 5.3 Reporting System

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: BRIEF: To facilitate the regular collection of timely and credible performance information, EPA uses a standardized work plan format for the GAP program, conducts oversight reviews of the Regional GAP programs, and by June 2007, will collect information from grantees in the GAP Tracking System. This system will collect a wide range of performance data in an interactive electronic format. ----------------- The GAP work plans and quarterly reports (actual frequency may vary based on past recipient performance and regional oversight structure) are the primary tools for collecting timely and credible performance information. In the work plans, the recipient lays out clear goals, objectives and supporting activities. Additionally, the work plan negotiation requires certification by the EPA project officer that the work is in support of Objective 5.3 of EPA's Strategic Plan. The GAP program collects data in the Objective 5.3 Reporting System. This reporting system contains all the information for reporting on EPA's performance measures and proposed PART measures. All GAP grantees are required to use a standardized work plan format for FY2007 and beyond in negotiating GAP grant agreements. This standardized work plan format includes milestones, deliverables, links to the Agency's Strategic Plan, and environmental outcomes and outputs. The work plan ensures collection of the minimum information needed for national reporting purposes, consistent with statute, grant regulations, and EPA Orders. This allows AIEO, as the national program manager for GAP, to better characterize the environmental and public health benefits of these activities in a consistent manner. The structure of the standardized work plan format assists recipients in ensuring that they address applicable regulations in 40 CFR Part 35, Subpart B, the Indian General Assistance Program (GAP) 2006 Grant Administrative Guidance (71 FR 9547, Feb. 24, 2006), and assists EPA in complying with EPA Order 5700.7 "Environmental Results under EPA Assistance Agreements." The progress towards meeting the goals in the work plans is tracked in the quarterly reports. The reports specifically discuss the status of activities, related deliverables, and where appropriate, impediments to meeting planned activities and accomplishments. The GAP Tracking System will be able to collect and track performance information enabling EPA to review performance both of individual grantees and to look at the aggregate national level. The system will be in place by June 2007. AIEO, as the National Program Manager of the GAP, also conducts oversight reviews of the EPA Regional GAP programs. The reviews are a formal, systematic assessment of the region's performance of the management of GAP. AIEO is able to obtain direct knowledge on implementation of the GAP in order to improve its understanding of program's operating structure, its environment, and challenges so as to ensure maximum program effectiveness. This helps improve environmental protection in Indian country while meeting our statutory and regulatory responsibilities. The benefits of regular reviews to the management of GAP have highlighted successes and strengths, identified areas for improvement, and facilitated technology and information transfer between the Regions, tribes and intertribal consortia. In addition, EPA provides targeted training to tribal financial managers on EPA financial assistance agreements to ensure compliance with grant policies and program requirements.

Evidence: 1. GAP program guidance, section 4 (2006) 2. 40 CFR Part 35.507 3. GAP Standardized Work Plan Template 4. GAP Tracking System 5. Regional Oversight Review Protocols 6. Region 4 Oversight Review Report 7. R8 Oversight Review Report 8. Objective 5.3 Reporting System 9. EPA Order 5700.7 "Environmental Results under EPA Assistance Agreements; 10. Financial Managers Training Description

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: BRIEF: Accountability is maintained by review of periodic performance and financial reports, regular phone communications, and site visits. Federal responsibility is maintained individually through the performance standards of EPA Project Officers. ---------------- Accountability at EPA is in the form of Grant Project Officer project management requirements (see Grant PO PARS Standards). Grantee program performance is a key component in ensuring that continued funding is contingent on past grantee performance both towards program commitments and administrative accomplishments (see GAP program guidance). Performance for GAP is related to a tribe's ability to meet timelines and deliverables committed to in the work plan, as well as timely reporting and appropriate funds management. In instances of audit deficiencies, EPA Tribal officers have worked with recipients to develop concrete steps to ensure that the deficiencies are remedied. Where efforts to work with recipients have been rebuffed, or the grantee has otherwise not adequately responded, EPA has taken actions such as issuing stop work orders, or required reimbursements.

Evidence: 1. GAP Program Guidance (2000), Section IV - VII 2. Grant PARS Standards 3. R7 Tribal Correspondence

Are funds (Federal and partners') obligated in a timely manner, spent for the intended purpose and accurately reported?

Explanation: BRIEF: EPA monitors fund obligation to ensure timeliness for a current obligation rate: over 90% within two years; and Potential conflicts with GAP purposes are rectified during the work plan negotiations and monitored through quarterly report oversight. The work plan for the GAP is structured so that vast majority of activities are forward-funded. Work plan activities negotiated in FY2007 will take place in FY2008. Therefore, obligation and liquidation of funds will usually take place in the following fiscal year. Table 3.3 reflects recent obligation and liquidation rates for GAP funds. Regional grants staff monitor both the financial reports submitted by grant recipients and the rate at which recipients are drawing down on funds for work plan activities. As part of their project officer responsibilities, Regional staff works actively with recipients to ensure both that work plan activities are being accomplished, and that the periodic financial statements submitted by recipients reflect both the intended uses and goals outlined in the work plan. Where proposed activities would be outside the scope of what can be funded under GAP, or inappropriate for a tribe to be attempting at that time, the activities are usually identified during the work plan negotiation stage, and therefore actual divergences from grant purposes are minimized. Progress reports are submitted at least annually, in addition to regular contact with recipients, enables EPA to ensure that grantees use the GAP funds as intended. Audits of the GAP are performed by the Office of Inspector General. Tribes also are required to commission audits by outside accounting firms for their overall financial profile. EPA Regional grants administration staff also conduct regular reviews of financial work plan requests and financial statements. AIEO, as national program manager of the GAP, conducts reviews and site visits of Regional GAP programs and grantees. All of the above are designed to provide oversight capacity and to verify that the GAP funds are used for their designated purpose. In instances of audit deficiencies, EPA Tribal officers have worked with recipients to develop concrete steps to ensure that the deficiencies are remedied. Where efforts to work with recipients have been rebuffed, or the grantee has otherwise not adequately responded, EPA has taken actions such as issuing stop work orders, or required reimbursements.

Evidence: 1. Table 3.3 Summary of Obligation and Expenditures 2. Contractor report. May 2007

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: BRIEF: GAP has regular procedures in place to achieve efficiencies and cost effectiveness & the program has one efficiency measure with baseline and targets -------------- GAP has regular procedures in place to achieve efficiencies and cost effectiveness and the program has one efficiency measure with baseline and targets. The GAP efficiency measure, "Number of environmental programs implemented in Indian country per million of dollars," is calculated annually by summing the number of tribes receiving GAP grants, the number of TAS approvals or primacies, the number of Direct Implementation Cooperative Tribal Agreements (DICTAs), and the number of GAP grants that have provisions for the implementation of solid and hazardous waste programs and dividing that sum by the annual GAP appropriation (less rescissions and annual set-asides). EPA has taken a similar approach in addressing tribal needs as the federal government has to funding state capacity-building programs. Where funds to states fall short of meeting needs, the federal response has been to distribute funding as equitably as possible among the recipient states, rather than making the process competitive. Efficiency and cost effectiveness are reinforced by review of proposed work plan activities and costs. All work plans are subject to a technical cost review, and where there are specific media-related activities listed in the work plan (e.g., solid waste implementation, baseline air monitoring), those work plan activities are reviewed by the relevant EPA regional program staff to ensure their technical merit, as well as provide advice to grantees on procedures. This avoids unnecessary or inappropriate approaches and related costs.

Evidence: 1. Objective 5.3 Reporting System ; 2. R9 Technical Review of Work Plan Actitivities

Does the program collaborate and coordinate effectively with related programs?

Explanation: BRIEF: GAP enables effective collaboration and coordination with other related program ------------- GAP enables tribes to participate effectively with federal agencies in collaborative efforts that focus on aligning disparate federal agency efforts to address specific public health and environmental issues, such as drinking water system operation and Brownfields redevelopment At the regional level, EPA has established Memorandum of Understanding (MOUs) with other federal agencies to focus their limited resources on tribal priorities. These MOUs identify federal responsibilities and provide a structure for identifying and addressing tribal priorities more effectively by specifying which resources from the respective agency that would be most effective to address that area. For example, EPA Region 8 is a signatory to the MOU 2000. Through this agreement, the region has been able to partner with other agencies to assist GAP-funded tribes addressing Emergency Response preparedness, and bombing range remediation. At the national level, the Interagency Tribal Infrastructure Task Force has established MOUs that coordinate federal agency actions to meet public health commitments included in the Johannesburg Goals. A specific goal from this coordination is to streamlining the process for tribes to fund projects from multiple sources, allowing them to more effectively focus resources.

Evidence: 1. Region 10 Cost Review 2. Draft MOUs under Johannesburg Agreements 3. Region 8 MOU2000 (www.epa.gov/Region8/tribes/mou2000/projects.html).

Does the program use strong financial management practices?

Explanation: BRIEF: Financial status reports are submitted by tribes quarterly. Technical assistance training is provided. GAP has not been targeted for erroneous payments and is free of material or agency weaknesses. ----------------------------- The GAP program follows EPA's financial management guidelines for committing, obligating, reprogramming, and reconciling appropriated funds. Agency officials have a system of controls and accountability (EPA's Resources Management Directives System), based on GAO, Treasury and OMB guidance as well as generally accepted accounting practices (GAAP), to ensure that improper payments are not made. At each step in the process, the propriety of the payment is reviewed. EPA trains individuals to ensure that they understand their roles and responsibilities for invoice review and for carrying out the financial aspects of program objectives. EPA received an unqualified audit opinion on its FY 2006 financial statements. The audit found no Agency level material weaknesses and no substantial noncompliance. EPA successfully accelerated the audited financial statements process to meet the 2006 submission requirement. EPA has worked to strengthen tribal financial management of EPA grants to tribal financial management staff. Each region has facilitated training for tribes in their region, and in some cases has supplemented the training through the establishment of circuit rider programs to assist tribes in ensuring effective grant management. The circuit rider programs are designed to provide tribal staff with hands on technical assistance from an EPA trained person (the Circuit Rider) to guide and assist them in managing GAP grants. The circuit riders also help tribes meet and understand EPA's reporting and accounting requirements, and allow EPA to establish internal systems to maintain best practices as needed to continue future EPA funding.

Evidence: 1. FMFIA Memo (2006); 2. R10 Circuit Rider Program (http://www.ccthita-igap.org/circuit_rider/default.htm)

Has the program taken meaningful steps to address its management deficiencies?

Explanation: BRIEF: Current evaluation efforts are primarily based upon identification of management deficiencies through analysis of program data variations in the GAP Tracking System, Regional oversight reviews, and input from program partners. ---------- GAP Tracking System. The GAP has become both a core tribal environmental program and a core EPA program, representing the largest single source of funding for tribal environmental programs awarded by EPA. The GAP has increased from an original $8.5 million in 1994 to over $57.5 million for the year 2006. EPA developed the GAP Tracking System - a national database that enables EPA to look both at the staffing involved in meeting the GAP objectives and the activities that are being carried out by grantees. The GAP Tracking System is a reporting tool for EPA Regions and GAP grantees. It allows Regional officers to access GAP-related records for their regions; enter and store GAP-related information in a central GAP-specific database; and to generate reports used by EPA Regional officers, tribal officials, EPA programs and the U.S. Congress and OMB. It also allows users to read data from existing databases that are part of the larger Tribal Program Enterprise Architecture (TPEA), a database system for air, water, solid waste, hazardous waste, and toxics so regulated facilities and monitoring sites can be reported on a per tribe basis. Regional Oversight Review: AIEO, in its role as the National Program Manager for GAP, conducts annual regional reviews of the GAP program. The reviews are a formal, systematic assessment of the region's performance of the management of GAP. AIEO is able to obtain direct knowledge on implementation of the GAP in order to improve its understanding of the program's operating structure, its environment, and challenges so as to ensure maximum program effectiveness. This helps improve environmental protection in Indian country while meeting our statutory and regulatory responsibilities. The benefits to regular reviews of the management of GAP has highlighted successes and strengths, identified areas for improvement, and facilitated technology and information transfer between the Regions, tribes and intertribal consortia. Regional-HQ Meetings. These monthly meetings serve to share information and coordinate the GAP management on issues such as post-award management, grant review procedures, and environmental results. In addition to monthly conference calls, AIEO and regional programs meet in person every February in working sessions designed to address program-wide concerns and initiatives.

Evidence: 1. Regional Oversight Review Protocols 2. GAP Tracking System 3. R4 Oversight Review Report 4. R8 Oversight Review Report

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: BRIEF: EPA is currently in the process of implementing an electronic GAP Tracking System that will view grant activity by tribe, region or nationwide. This will greatly limprove the ability to monitor and evaluate grantee performance. Although the regions conduct regular meetings with grantee and National staff conduct yearly meetings with Regions and conduct regional oversight reviews this does not allow timely and comprehensive review. ------------------ There are several oversight practices in place to provide sufficient knowledge of grantee performance. Regional EPA project officers directly engage tribal grantees in discussion of work plans and negotiation of work plans, agreements or activities. Financial status reports and programmatic progress reports are submitted to EPA on a consistent basis, as negotiated with the Regional Indian Coordinator. Regional tribal project officers and grants staff review the reports, and follow up through phone contact and site visits as a core function of their responsibilities in working with tribes. Audits of the GAP are performed by the Office of Inspector General. Tribes also are required to commission audits by outside accounting firms for their overall financial profile. EPA Regional grants administration staff also conduct regular reviews of financial work plan requests and financial statements. AIEO, as national program manager of the GAP, conducts reviews and site visits of Regional GAP programs and grantees. All of the above are designed to provide oversight capacity and to verify that the GAP funds are used for their designated purpose. The GAP Tracking System is a reporting tool for EPA Regions and GAP grantees. It allows Regional officers to access GAP-related records for their regions; read data from existing databases that are part of the larger Tribal Information Management System (using Baseline Assessment information); enter and store GAP-related information in a central GAP-specific database; and to generate reports used by EPA Regional officers, tribal officials, EPA programs and the U.S. Congress and OMB. The updated GAP Tracking System, which is based on the standardized GAP Work Plan template and will allow for direct tribal data entry, will be in place by June 2007

Evidence: 1. GAP program guidance (2000 & 2006) 2. Regional Oversight Review Protocols 3. R4 Oversight Review Report 4. R8 Oversight Review Report 5. GAP Tracking System

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: BRIEF: EPA reviews of grantee performance is available for public review though the Objective 5.3 Reporting System. Web-based performance information, collected through the GAP Tracking System will enable public review of grant results at tribal, regional, and national levels and integration with other data. --------------- The Objective 5.3 Reporting System contains all the information for reporting on EPA's tribal performance measures and proposed PART measures. GAP Tracking System is a national database that enables EPA to look both at the staffing involved in meeting the GAP objectives and the activities that are being carried out by grantees. The GAP Tracking System is a reporting tool for EPA Regions and GAP grantees. It allows Regional officers to access GAP-related records for their regions; enter and store GAP-related information in a central GAP-specific database; and to generate reports used by EPA Regional officers, tribal officials, EPA programs and the U.S. Congress and OMB. It also allows users to read data from existing databases that are part of the larger Tribal Program Enterprise Architecture (TPEA), a database system for air, water, solid waste, hazardous waste, and toxics so regulated facilities and monitoring sites can be reported on a per tribe basis. The GAP Tracking System will be in place by June 2007.

Evidence: 1. GAP Tracking System; 2. Objective 5.3 Reporting System

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: EPA is making strides in achieving its long-term performance goals. Tribal participation continues to increase as per Congress' expressed desires for the program. This increase is both in numbers of tribal governments participating in the GAP and the variety of environmental issues in which they are developing capacity. In the first four years after the enactment of GAP in 1992, less than one-fifth of the approximately 570 Tribes and Alaska Native villages were able to receive grant awards under this program. Today, over 400 tribes are funded through the GAP to build environmental capacity. As a result of building this capacity, the percent of tribes without basic sanitation is decreasing as is the percentage of homes without access to safe drinking water.

Evidence: 1. EPA Strategic Plan Goal 2, Subobjectives 2.1.1 and 2.2.1 2, EPA FY 2006 Performance and Accountability Report

Does the program (including program partners) achieve its annual performance goals?

Explanation: EPA has made significant progress towards achieving its annual performance goals, meeting or exceeding 8 of 9 targets over a 3 year period. For the single target that was not met- the performance measure tracking percent of tribes with EPA approved multimedia work plans- it did achieve 33 of the promised 39 percent target in 2005, but achieved its target in 2006. Six percent was not achieved because some of the tribes were focusing on a single area rather than a multimedia approach. Achievement of the GAP is directly related to the number of tribes with tribal environmental programs that will improve environmental quality and human health in Indian country by increasing access to safe drinking water and basic sanitation. Measure: Percent of tribes with EPA reviewed monitoring and assessment 2004: Baseline 20; 2005-T- 25, A-

Evidence: 1. Objective 5.3 Reporting System: 2. Tribal Enterprise Architecture (TPEA) database Measure 1: percent of tribes with EPA reviewed monitoring and assessment. 2004: Target (T) - 20; Actual (A) 44 2005: T-25; A-29 2006 T-30; A- 31 Measure 2: Percent of tribes wtih EPA approved multimedia plan 2004: T- 18, A- 26 2005: T- 39; A- 33 2006: T-39: A-42 Measure 3: Percent of tribes with delegated and non-delegated programs 2004: T-5; A-28 2005: T-44; A-47 2006: T- 48; A-57

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: BRIEF: GAP has demonstrated improved efficiency over the prior years by consistently meeting its efficiency target. The annual savings per million dollars was 13.7 in 2006. The GAP efficiency measure is the number of environmental programs implemented in Indian country per million dollars ---------------------------- GAP has regular procedures in place to achieve efficiencies and cost effectiveness and the program has one efficiency measure with baseline and targets. EPA has taken a similar approach in addressing tribal needs as the federal government has to funding state capacity-building programs. Where funds to states fall short of meeting needs, the federal response has been to distribute funding as equitably as possible among the recipient states, rather than making the process competitive. Efficiency and cost effectiveness are reinforced by review of proposed work plan activities and costs. All work plans are subject to a technical cost review, and where there are specific media-related activities listed in the work plan (e.g., solid waste implementation, baseline air monitoring), those work plan activities are reviewed by the relevant EPA regional program staff to ensure their technical merit, as well as provide advice to grantees on procedures. This avoids unnecessary or inappropriate approaches and related costs. The GAP efficiency measure, "Number of environmental programs implemented in Indian country per million of dollars," is calculated annually by summing the number of tribes receiving GAP grants, the number of TAS approvals or primacies, the number of Direct Implementation Cooperative Tribal Agreements (DICTAs), and the number of GAP grants that have provisions for the implementation of solid and hazardous waste programs and dividing that sum by the annual GAP appropriation (less rescissions and annual set-asides). See Table 4.3 for the targets and actual performance under the GAP efficiency measure.

Evidence: 1. Objective 5.3 Reporting System; 2. Table 4.3

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: BRIEF: GAP is the only federal resource widely available to tribes for the development of multimedia environmental program capacity building, such as planning, developing, and establishing environmental protection programs ---------------- The GAP was instituted by Congress in order to fulfill a need to address multimedia environmental issues in Indian country. While other Federal programs have expanded to address program implementation, GAP continues to be the only multimedia program to meet tribes' need to build the overall environmental program capacity and help prepare tribes to receive program specific grants.

Evidence: 1. Indian Environmental General Assistance Program Act Reauthorization, S. 1834, 104th Cong. (Sept. 25, 1996)

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: BRIEF: AIEO is conducting an evaluation of the GAP program through an independent contractor. The contractor has found that GAP has been effective in building the foundation of environmental capacity among tribes, as defined as capability in one or more of five indicator areas- technical, legal, enforcement, adminstrative and communications. The American Indian Environmental Office (AIEO) initiated a program evaluation to determine how effective GAP has been in building tribal environmental capacity. The evaluation is being conducted as part of a larger effort within EPA to promote environmental programs that achieve measurable results. AIEO applied for, and received limited technical and funding support from EPA's Office of Policy, Economics, and Innovation (OPEI) to carry out its evaluation of the GAP. Industrial Economics, Inc. (IEc) was selected to conduct this evaluation. IEc has produced a report with findings based on their analysis of data contained in the databases. The final report was issued in May 2007. The Inspectors General of EPA and the Department of Interior have jointly released a report on May 3, 2007 ," Tribal Successes, Protecting the Environment and Natural Resources" which highlight successful environmental protection practices by selected tribes.

Evidence: 1. Final Methodology for the Tribal GAP Evaluation (Dec. 6, 2006) 2. Final GAP Evaluation Findings (May 2007) 3. Tribal Successes: Protecting the Environment and Natural Resources by the US EPA and the Department of Interior Offices of Inspector General (May 2007).