prompt_front: You are given two reports by the government agency.



Question: Write a one-page summary of the report 1.

Report 1: According to Education, 50 3 million students were enrolled in more than 98,000 public elementary and secondary schools nationwide in the 2014- 2015 school year  These individual public schools are overseen by approximately 16,000 local educational agencies (referred to in this report as school districts) which are, in turn, overseen and supported by state educational agencies  School districts can range in size from one school (for example, in rural areas) to hundreds of schools in large urban and suburban areas  For example, the 100 largest districts in the United States together have approximately 16,000 schools and enroll about 11 million students  In addition, charter schools are public schools created to achieve a number of goals, such as encouraging innovation in public education  Oversight of charter schools can vary, with some states establishing charter schools as their own school district and other states allowing charter schools to be either a distinct school district in themselves or part of a larger district  Charter schools are often responsible for their own facilities; these may be located in non-traditional school buildings, and may lease part or all of their space  Typically, state educational agencies are responsible for administering state and federal education laws, disbursing state and federal funds, and providing guidance to school districts and schools across the state  State educational agencies frequently provide funds for capital improvements to school facilities, which school districts may use to address issues related to lead in school drinking water, among other things  Different state agencies, including agencies for education, health, and environmental protection, may provide school districts with guidance on testing and remediation of lead in school drinking water  Within a school district, responsibility for water management may be held by individuals in different positions, such as facilities managers or environmental specialists  Lead is a neurotoxin that can accumulate in the body over time with long- lasting effects, particularly for children  According to the CDC, lead in drinking water can cause health effects if it enters the bloodstream and causes an elevated blood lead level  Lead in a child’s body can slow down growth and development, damage hearing and speech, and lead to learning disabilities  For adults, lead can have detrimental effects on cardiovascular, renal, and reproductive systems and can prompt memory loss  In pregnant women, lead stored in bones (due to lead exposure prior to and during pregnancy) can be released as maternal calcium used to form the bones of the fetus, reduce fetal growth, and increase risk of miscarriage and stillbirth  The presence of lead in the bloodstream can disappear relatively quickly, but bones can retain the toxin for decades  Lead in bones may be released into the blood, re-exposing organ systems long after the original exposure  The concentration of lead, total amount consumed, and duration of exposure influence the severity of health effects  The health consequences of lead exposure can differ from person to person and are affected by the cumulative dose of lead and the vulnerability of the individual person regardless of whether the lead exposure is from food, water, soil, dust, or air  Although there are medical therapies to remove lead from the body, they cannot undo the damage it has already caused  For these reasons, EPA, CDC, and others recommend the prevention of lead exposure to the extent possible, recognizing that lead is widespread in the environment  The SDWA authorizes EPA to set standards for drinking water contaminants in public water systems  For a given contaminant the act requires EPA to first establish a maximum contaminant level goal, which is the level at which no known or anticipated adverse effects on the health of persons occur and which allows an adequate margin of safety  EPA must then set an enforceable maximum contaminant level as close to the maximum contaminant level goal as is feasible, or require water systems to use a treatment technique to prevent known or anticipated adverse effects on the health of persons to the extent feasible  Feasible means the level is achievable using the best available technology or treatment technique  In 1991 EPA issued the LCR, which it revised in 2000 and 2007, establishing regulations for water systems covered by the SDWA  Lead concentration in water is typically measured in micrograms of lead per liter of water (also referred to as “parts per billion” or ppb)  The rule established a maximum contaminant level goal of zero, because EPA concluded that there was no established safe level of lead exposure  EPA decided not to establish an enforceable maximum contaminant level, concluding that any level reasonably close to the goal would result in widespread noncompliance, and therefore was not feasible  Instead, the rule established an “action level” of 15 micrograms of lead per liter (15 ppb) in a one liter sample of tap water, a level that EPA believed was generally representative of what could be feasibly achieved at the tap  The action level is a screening tool for determining when certain follow-up actions are needed, which may include corrosion control treatment, public education, and lead service line replacement  Sample results that exceed the lead action level do not by themselves constitute violations of the rule  If the lead action level is exceeded in more than 10 percent of tap water samples collected during any monitoring period (that is, if the 90th percentile level is greater than the action level), a water system must take actions to reduce exposure  Several amendments to the SDWA are relevant to testing for lead in school drinking water  In 1988, the SDWA was amended by the Lead Contamination Control Act (LCCA), which banned the manufacture and sale of drinking water coolers with lead-lined tanks containing more than 8 percent lead; the statute defined a drinking water cooler as containing 8 percent lead or less as “lead-free ” The LCCA also required states to establish testing and remediation programs for schools  However, in 1996 a federal circuit court held that this requirement was unconstitutional  In 2011, Congress passed the Reduction of Lead in Drinking Water Act, which amended the SDWA by lowering the maximum allowable lead content in “lead-free” plumbing materials such as pipes  This provision became effective on January 4, 2014  In 2016, Congress passed the Water Infrastructure Improvements for the Nation Act which, among other things, amended the SDWA, to establish a grant program for states to assist school districts in voluntary testing for lead contamination in drinking water at schools  As a condition of receiving funds, school districts are required to test for lead using standards that are at least as stringent as those in federal guidance for schools  In March 2018, Congress appropriated $20 million to EPA for this grant program  Lead can enter drinking water when service lines or plumbing fixtures that contain lead corrode, especially where the water has high acidity or low mineral content  According to EPA, lead typically enters school drinking water as a result of interaction with lead-containing plumbing materials and fixtures within the building  Although lead pipes and lead solder were not commonly used after 1986, water fountains and other fixtures were allowed to have up to 8 percent lead until 2014, as previously mentioned  Consequently, both older and newer school buildings can have lead in drinking water  Some water in a school building is not for consumption, such as water from a janitorial sink or garden hose, so lead in these water sources presents less risk to students  (See fig  1 ) The best way to know if a school’s water is contaminated with lead is to test the water after it has gone through a school’s pipes, faucets, and other fixtures  To facilitate testing efforts, EPA suggests that schools implement programs for reducing lead in drinking water and developed the 3Ts for Reducing Lead in Drinking Water in Schools: Revised Technical Guidance (3Ts guidance) in 2006, which provides information on: (1) training school officials about the potential causes and health effects of lead in drinking water; (2) testing drinking water in schools to identify potential problems and take corrective actions as necessary; and (3) telling students, parents, staff, and the larger community about monitoring programs, potential risks, the results of testing, and remediation actions  The purpose of the 3Ts guidance is to help schools minimize students’ and staffs’ exposure to lead in drinking water  The guidance provides recommendations and suggestions for how to address lead in school drinking water, but does not establish requirements for schools to follow  According to the guidance, if school districts follow the procedures described in guidance, they will be assured their facilities do not have elevated levels of lead in their drinking water  The guidance recommends taking 250 milliliter samples of water from every drinking water source in a school building and having the samples analyzed by an accredited laboratory  Based on the test results of the samples, the guidance recommends remedial action if the samples are found to have an elevated concentration of lead, which is identified by using an action level  While school districts may have discretion to set their own action level, the 3Ts guidance strongly recommends taking remedial action if a school district finds lead at or above 20 ppb in a 250 milliliter sample of water  School districts can take a variety of actions including replacing pipes, replacing fixtures, running water through the system before consumption (known as flushing), or providing bottled water  However, since the amount of lead in school drinking water may change over time for a variety of reasons—for example, the natural aging of plumbing materials or a disturbance nearby, such as construction—the results obtained by one test are not necessarily indicative of results which may be obtained in the future  With no federal law requiring testing for lead in school drinking water, federal agencies play a limited role: Education’s mission includes fostering educational excellence and promoting student achievement, and the agency disseminates guidance to states and school districts about lead in school drinking water, but does not administer any related grants  EPA’s Office of Ground Water and Drinking Water provides voluntary guidance to schools on how to test for and remediate lead in school drinking water, as part of EPA’s mission to inform the public about environmental risks  In addition, EPA’s Office of Children’s Health Protection is responsible for working with EPA’s 10 regional offices via their healthy schools coordinators, who communicate with schools and help to disseminate the 3Ts guidance  CDC administers the School Health Policies and Practices Study, a periodic survey to monitor national health objectives that pertain to schools and school districts  The 2016 data, the most recent available, provide information on the number of school districts that periodically test for lead in their drinking water  Under the 2005 memorandum signed by these three agencies to encourage lead testing and remediation in schools, Education’s role includes working with EPA and other groups to encourage testing, and disseminating materials to schools  EPA agreed to update guidance for schools, and provide tools to facilitate testing for lead in school drinking water  CDC’s role includes identifying public health organizations to work with and facilitating dissemination of materials to state health organizations  Lead in School Drinking Water Survey Results at a Glance An estimated 43 percent of school districts tested for lead in school drinking water, but 41 percent did not, and 16 percent did not know  o Some districts tested drinking water in all sources of consumable water in all of their schools, while other school districts tested only some sources  o Among the reasons for not testing, school districts said they either did not identify a need to test or were not required to do so  Of those that tested, an estimated 37 percent of school districts found elevated lead levels—levels of lead above the district’s threshold for taking remedial action—in school drinking water  o School districts varied in terms of the threshold they used, with some using 15 ppb or 20 ppb and others using a lower threshold  School districts varied in whether they tested for lead in school drinking water and whether they discovered elevated levels of lead  For example, an estimated 88 percent of the largest 100 school districts tested compared with 42 percent of other school districts  All school districts that found elevated lead reported taking steps to reduce or eliminate the lead, including replacing water fountains or providing bottled water  Nationwide, school districts vary in terms of whether they have tested for lead in school drinking water, with many not testing  According to our survey of school districts, an estimated 43 percent tested for lead in school drinking water in at least one school in the last 12 months, while 41 percent had not tested  An estimated 35 million students were enrolled in districts that tested as compared with 12 million students in districts that did not test  An estimated 16 percent of school districts, enrolling about 6 million students, reported that they did not know whether they had tested or not  (See fig  2 ) Of school districts that tested for lead in school drinking water, some tested all consumable water sources in all of their schools, while others may have only tested some sources in all schools or all sources in some schools  Among the reasons provided by survey respondents for not testing in all schools, some said the age of the building was the primary consideration  For example, an official in one school district we visited told us they began testing in buildings constructed before 1989, but after receiving results that some water sources had elevated lead levels, the district decided to test all of their school buildings  Other reasons reported for testing some, but not all, schools included testing schools only when a complaint about discolored water was received or testing only new schools or schools that were renovated  In addition, school districts varied in whether they sampled from every consumable water source, or just some of the sources, in their schools  For example, one district official told us they took one sample from each type of water fountain in each school, assuming that, if a sampled fountain was found to have an elevated level of lead, then all of the other fountains of that type would also have elevated lead levels  However, EPA’s 3Ts guidance recommends that every water source that is regularly used for drinking or cooking be sampled  Further, stakeholders and environmental and educational officials we interviewed said that results from one water fountain, faucet, or any other consumable water source cannot be used to predict whether lead will be found in other sources  In our survey, the median amount spent by school districts to test for lead in school drinking water during the past 12 months varied substantially, depending on the number of schools in which tests were conducted (see table 1)  School districts may have paid for services such as collecting water samples, analyzing and reporting results, and consultants  For example, an official in a small, rural school district—with three schools housed in one building—told us his district spent $180 to test all eight fixtures  In contrast, officials in a large, urban school district told us they spent about $2 1 million to test over 11,000 fixtures in over 500 schools  Some school districts, especially larger ones, incurred costs to hire consultants to advise them and help design a plan to take samples, among other things  EPA’s 3Ts guidance recommends determining how to communicate information about lead testing programs with parents, governing officials, and other stakeholders before testing  Of school districts that reported testing for lead in school drinking water in our survey, an estimated 76 percent informed their local school board and 59 percent informed parents about their plans to test; similar percentages provided information about the testing results  We identified a range of approaches to communicating testing efforts in the 17 school districts we interviewed  Some school districts reported issuing press releases, putting letters in multiple languages in students’ backpacks, sending emails to parents, holding public meetings, and releasing information through social media  Before testing, one district created a website with a list of dates when it planned to test the drinking water in every one of its schools  In contrast, other school districts communicated with parents and the press only upon request  Officials in one district we visited said they did not post lead testing results on their website, because they wanted to avoid causing undue concern, adding that “more information isn’t necessarily better, especially when tests showed just trace amounts of lead ” School districts generally have discretion to determine how frequently they test for lead in school drinking water except when prescribed in state law, and most school districts responding to our survey had no specific schedule for recurring testing  Specifically, an estimated: 27 percent of school districts plan to test “as needed,” 25 percent have no schedule to conduct recurring tests, and 15 percent do not know  The remaining school districts reported a range of frequencies for conducting additional tests or said they were developing a schedule to conduct tests on a recurring basis  School district officials and stakeholders we interviewed told us that it is important to test for lead in drinking water on a recurring basis, because lead can leach into school drinking water at any time  In our survey, we asked school districts reporting that they had not tested for lead in school drinking water in the last 12 months (41 percent of districts) to provide us with one or more reasons why they had not tested  Of these school districts, an estimated 53 percent reported that they did not identify a need to test and 53 percent reported they were not required to test (see fig  3)  Of school districts that reported testing for lead in school drinking water, an estimated 37 percent of districts found elevated levels of lead in school drinking water, while 57 percent of districts did not find lead (see fig  4)  Of those that found lead in drinking water, most found lead above their selected action level in some of their schools, while some districts found lead above their action level in all of their schools  For example, officials in one large school district told us they tested over 10,000 sources of water, including drinking fountains and food preparation fixtures, and found that over 3,600 water sources had lead at or above the district’s action level of 15 parts per billion (ppb)  The findings resulted in extensive remediation efforts, officials said  Further, district officials reported different action levels they used to determine when to take steps such as replacing a water fountain or installing a filter  School districts generally may select their own action level, resulting in different action levels between districts  Of school districts that reported testing for lead in school drinking water, an estimated 44 percent set an action level between 15 ppb and 19 ppb  The action levels chosen by the rest of the school districts ranged from a low of 1 ppb whereby action would be taken if any lead at all was detected to a high 20 ppb where action would be taken if lead was found at or above 20 ppb  (See appendix II for the estimated percentage of school districts that set other action levels ) Though fewer than half of school districts reported testing for lead in school drinking water, our analysis of school districts’ survey responses shows that these estimates varied depending on the size and population density of the district as well as its geographic location  For example, among the largest 100 school districts, an estimated 88 percent reported they had tested for lead in school drinking water in at least one school in the last 12 months compared with 42 percent of all other districts nationwide  An estimated 59 percent of the largest 100 school districts that tested discovered elevated levels of lead compared to 36 percent of all other districts that tested (see table 2)  In addition, an estimated 86 percent of school districts in the Northeast region of the United States tested for lead in school drinking water, compared to less than half of school districts in other geographic regions  Similarly, about half of school districts in the Northeast and about 8 percent in the South found elevated levels of lead, compared to their selected action level  (See fig  5 ) In our survey, every school district that reported finding lead in school drinking water above their selected action level reported taking steps to reduce or eliminate the lead  For example, an estimated 71 percent said they replaced water fountains, 63 percent took water fountains out of service without replacing them, and 62 percent flushed the school’s water system (see fig  6)  School districts officials we interviewed told us they took a range of remedial actions generally consistent with those reported to us in our survey  For example, an official in one district told us that 129 of the 608 fixtures tested above the district’s action level of “any detectable level ” He said they installed filters on all of the 106 sink faucets with elevated lead and replaced all of the 23 drinking fountains with elevated lead  The district official explained that they re-tested fixtures after the filters and new fountains were installed, and did not detect any lead in their drinking water  Officials in another school district told us that approximately 3,600 of their fixtures were found to have lead above their action level of 15 ppb  They told us the district turned off the water at the affected fixtures as an interim measure and provided bottled water to students and staff  Though they had not yet finalized their plans at the time of our interview, they said they were planning to replace the fixtures and replace old pipes with new pipes  District officials said they plan to pay for their remediation efforts using local capital improvement funds from a recently-approved bond initiative  Similar to the cost of testing, the median amount spent by school districts to remediate lead in school drinking water during the past 12 months varied substantially, depending on the number of schools in which a district took action to remediate lead (see table 3)  The median expenditure for school districts taking action in one to four schools was $4,000 compared to a median expenditure for school districts taking action in 51 or more schools of $278,000  EPA regional officials provided examples of eight states that have requirements for schools to test for lead in drinking water as of September 2017: California, Illinois, Maryland, Minnesota, New Jersey, New York, Virginia, and the District of Columbia  State requirements differ in terms of which schools are included, testing protocols, communicating results, and funding  (See fig  7 ) (For a list of testing components for the eight states, see appendix IV ) According to stakeholders we interviewed, most state legislation on testing for lead in school drinking water has been introduced in the past 2 years  Of the eight states, three states have completed one round of required testing, while other states are in the early stages of implementation or have not yet begun, according to state officials  School districts in Illinois, New Jersey, and New York completed a round of testing for lead in school drinking water by December 2017  Testing in the District of Columbia was in progress as of April 2018  Minnesota requires school districts to develop a plan to test by July 2018 and California requires that water systems sample all covered public schools in their service area by July 2019  According to state officials, schools in Maryland must test by July 2020  In Virginia, no timeline for testing is indicated in the requirement  In addition, requirements in these eight states vary in terms of covered schools and frequency of testing  For example, in Maryland, all schools, including charter and private schools, are required to test their water for lead by July 2020 and must re-test every 3 years  After regulations were approved in July 2016, New Jersey required testing within a year in all traditional public schools, charter schools, and certain private schools, and re-testing every 6 years, according to state officials  Illinois’ requirement is for public and private elementary schools constructed before 2000 to test their drinking water for lead, and does not mandate re- testing  Seven of the eight states include at least some charter schools in their testing requirements (New York does not)  State testing requirements also differ in terms of action level, sample sizes, and number of samples, according to state documents  States can choose their own lead threshold or action level for remediation, and the eight states have chosen levels ranging from any detectable level in Illinois to 20 ppb in Maryland  Six of the eight states have chosen to use 250 milliliter samples of water, while California is using a one liter sample size, and Virginia delegates to school districts to choose their action level and sample size  Some states specify that all drinking water sources in a building must be tested, such as in New York and New Jersey, or allow a smaller number of samples to be tested, such as in California, which recommends that water systems take between one and five samples per school  To implement its testing requirement, the District of Columbia has installed filters in all school drinking water sources, and plans to test the filtered water from each fixture for elevated lead annually  The responsibility for the costs of testing and remediation also differ by state  According to state officials, in Minnesota, the costs of testing may be eligible for reimbursement from the state, and in the District of Columbia, the Department of General Services is responsible for the cost  California requires that public water systems cover the cost of testing for all public schools in their jurisdiction  In all other states we looked at, schools or school districts are at least partially responsible for the costs of testing  Additionally, most schools or school districts are responsible for the costs of remediation, although Minnesota, New York, and the District of Columbia will provide funds to help with the costs of remediation as well  Seven of the eight state requirements have a provision for communicating the results of lead sampling and testing in schools  For example, Minnesota requires all test results be made public and New York requires that results be communicated to students’ families  Maryland and New Jersey require that results above the action level be reported to the responsible state agency, such as the Department of the Environment or the Department of Education, and that sample results that find elevated levels of lead be communicated to students’ families  Illinois requires that all results be made available to families and that individual letters to families also be sent if lead levels over 5 ppb are found  In contrast, Virginia does not include a provision to communicate testing results in its testing requirement for schools  According to stakeholders and state officials we interviewed, states have several other common issues to consider in implementing a state testing and remediation program  First, states need to ensure that their efforts, which can be significant given the thousands of schools that operate in each state, can be completed with limited resources and by a legislated deadline  Second, coordination between relevant state agencies, which will vary by state, may be challenging  Because of the nature of testing for lead in school drinking water, multiple government agencies may be involved, necessitating a balance of responsibilities and information- sharing between these state agencies  Finally, state officials told us that imposing requirements without providing funding to implement them may be a challenge for schools in complying with testing and remediation requirements  Apart from the states with requirements to test for lead in school drinking water discussed in this report, at least 13 additional states had also provided funding or in-kind support to school districts to assist with voluntary lead testing and remediation, according to EPA regional offices  Those states are Arizona, Colorado, Idaho, Indiana, Maine, Massachusetts, Michigan, New Mexico, Ohio, Oregon, Rhode Island, Vermont, and Washington  In Massachusetts, for example, officials told us the state used $2 8 million from the state Clean Water Trust to fund a voluntary program for sampling and testing for all participating public schools in 2016 and 2017  Massachusetts contracted with a state university to assist schools with testing for lead in drinking water  When the program completed its first round of testing in February 2017, 818 schools throughout the state had participated, and the state has begun a second round of sampling with remaining funds from the Clean Water Trust  In Oregon, officials told us the state legislature provided funding for matching grants of up to $8 million to larger school districts for facilities improvements, and made $5 million of emergency funds available to reimburse school districts for laboratory fees associated with drinking water testing as part of the state’s efforts to address student safety  States can also provide technical assistance to support school districts in their efforts to test for and remediate lead in drinking water  The five states we visited provided a range of technical assistance to school districts  For example, to implement the voluntary assistance program in Massachusetts, the contracted university told us they hired 15 additional staff and assisted schools in designing sampling plans, taking samples, and sending them for testing  University officials told us they oversaw the sampling of all drinking water sources in each participating school and sent the sample to state certified laboratories for analysis  State officials encouraged schools to shut off all fixtures in which water tested at or above the action level of 15 ppb and provided guidance on actions to take, such as removing and replacing fixtures, using signage to indicate fixtures not to be used for drinking water, and implementing a flushing program  The state developed an online reporting tool so that all test results could be publicly posted  State officials also supported schools in communicating lead testing results to parents and the community  Other states we visited provided technical assistance to school districts through webinars, guidance documents, in-person presentations, and responding to inquiries  In Oregon, the state Department of Education and the state Health Authority collaborated in 2016 to provide guidance to schools on addressing lead in drinking water  The Governor issued a directive requesting all school districts test for lead in their buildings and the Health Authority requested that districts send them the results  In Texas, officials at the Commission for Environmental Quality have made presentations to schools on water sampling protocols and provided templates for school districts to communicate results  Officials told us that an increased number of school districts have contacted them in the past year seeking guidance, and, in response, they directed districts to EPA’s 3Ts guidance and a list of accredited laboratories  In Illinois, state officials partnered with the state chapter of the American Water Works Association to provide a guidance document for drinking water sampling and testing to assist schools in complying with new testing requirements  In Georgia, officials at the Department of Natural Resources told us they promote the 3Ts guidance on their website and have offered themselves as a resource on school testing at presentations with local water associations  EPA provides several voluntary resources, such as guidance, training, and technical assistance, to states and school districts regarding testing for and remediation of lead in school drinking water, but some school districts we surveyed and officials we interviewed said more information would be helpful  The Lead Contamination Control Act of 1988 (LCCA) required EPA to publish a guidance document and testing protocol to assist schools in their testing and remediation efforts  EPA’s Office of Ground Water and Drinking Water issued its 3Ts guidance which provides information on training school officials, testing drinking water in schools, and telling the school and broader community about these efforts  Of the school districts that reported in our survey using the 3Ts guidance to inform their lead testing efforts, an estimated 68 percent found the guidance extremely or very helpful for conducting tests  The Office of Ground Water and Drinking Water also developed an additional online resource—known as the 3Ts guidance toolkit—to further assist states and school districts with their lead in drinking water prevention programs by providing fact sheets and brochures for community members, among other things  Some states have used the 3Ts guidance as a resource for their state programs, according to EPA officials  For example, a New York regulation directs schools to use the 3Ts guidance as a technical reference when implementing their state- required lead testing and remediation programs  The Office of Ground Water and Drinking Water provides training to support states and school districts with their lead testing and remediation programs  In June 2017, EPA started a quarterly webinar series to highlight school district efforts to test for lead  These webinars include presentations from school officials and key partners that conducted lead testing and remediation  For example, on June 21, 2017, officials from Denver Public Schools and Denver Water presented on their efforts to test for lead in the public school system  EPA’s approach to providing guidance and technical assistance to states and school districts is determined by each of the 10 EPA regional offices  Some EPA regional offices provide the 3Ts guidance to school districts upon request and others conduct outreach to share the guidance, typically through their healthy schools coordinator when discussing other topics, such as indoor air quality and managing chemicals  EPA regional offices also provide technical assistance by request, typically through phone consultations with school districts that have questions regarding the 3Ts guidance, according to EPA headquarters officials  Officials also indicated that the agency has received more requests for technical assistance from schools over the past few years regarding lead in drinking water  Officials in EPA Regions 1 in Boston and 2 in New York City told us they provided technical assistance to school districts by conducting lead testing and analysis in school facilities and Region 9 in San Francisco provided technical assistance by reviewing school district testing protocols  For example, EPA Region 2 officials said between 2002 and 2016 they worked with one to two school districts per year to assist with their lead testing efforts  As part of this effort, the regional office provided funding for sampling and analysis  Officials said they prioritized school districts based on population size and whether the community had elevated blood lead levels  Other EPA regional office approaches included identifying resources and guidance for relevant state agencies and facilitating information sharing by connecting districts that have tested for lead with districts that are interested in doing so  However, most EPA regional offices do not provide technical assistance in the form of testing, analysis, or remediation to school districts, and some do little or no outreach to communicate the importance of testing for and remediating lead in school drinking water  According to federal standards for internal control, management should externally communicate the necessary quality information to achieve the entity’s objectives  Each EPA regional office’s approach to providing resources to states and school districts varies based on differing regional priorities and available resources, according to EPA headquarters officials  Additionally, officials said that this decentralized model of providing support and technical assistance related to lead testing and remediation in schools is appropriate because of the number of schools across the United States  However, based on our survey we found school district familiarity with the 3Ts guidance varied by geographic area (see fig  8)  An estimated 54 percent of school districts in the Northeast reported familiarity with the 3Ts guidance, compared with 17 percent of districts in the South  Furthermore, the Northeast was the only geographic area with more school districts reporting that they were familiar with the 3Ts guidance than not  This awareness corresponds with the efforts made by the state of Massachusetts and EPA’s regional offices in the Northeast to distribute the 3Ts guidance and conduct lead testing and remediation in school districts  By promoting further efforts to communicate the importance of lead testing to schools to help ensure that their lead testing programs are in line with good practices included in the 3Ts guidance, EPA regional offices that have not focused on this issue could leverage the recent efforts of other regional offices to provide technical assistance and guidance, and other forms of support  EPA’s 3Ts guidance emphasizes the importance of taking action to remediate elevated lead in school drinking water, but the agency’s guidance on a recommended action level for states and school districts is not current and contains elements that could be misleading  Although the guidance recommends that school districts prioritize taking action if lead levels from water fountains and other outlets used for consumption exceed 20 ppb (based on a 250 milliliter water sample), EPA officials told us when the guidance was originally developed in response to the 1988 LCCA requirement, the agency did not have information available to recommend an action level specifically designed for schools  Furthermore, EPA officials told us that the action level in the 3Ts guidance is not a health-based standard  However, there are statements in the guidance that appear to suggest otherwise  For example, the guidance states that EPA strongly recommends that all water outlets in all schools that provide water for drinking or cooking meet a “standard” of 20 ppb lead or less and that school officials who follow the steps included in the document, including using a 20 ppb action level, will be “assured” that school facilities do not have elevated lead in the drinking water  The use of the terms “standard” and “assured” are potentially misleading and could suggest that the 20 ppb action level is protective of health  Further, state and school district officials may be familiar with the 15 ppb action level (based on a 1 liter water sample) for public water systems aimed at identifying system-wide problems under the LCR, which may also create confusion around the 20 ppb action level included in the 3Ts guidance  According to our survey, an estimated 67 percent of school districts reported using an action level less than the 20 ppb recommended in the 3Ts guidance  We found that nearly half of school districts used action levels between 15 ppb and 19 ppb  Although these action levels— the 20 ppb from the 3Ts guidance and the 15 ppb from the LCR—are intended for different purposes, the difference creates confusion for some state and school district officials  Also, according to our survey, an estimated 56 percent of school districts reported they would find it helpful to have clearer guidance on what level of lead to use as the action level for deciding to take steps to remediate lead in drinking water  In addition, officials we interviewed in four of the five states we visited said there is a need for clearer guidance on the action level  EPA officials agreed that the difference between the two action levels creates confusion for states and school districts  In addition to wanting clearer guidance on choosing lead action levels, about half of the school districts we surveyed said they would also like additional information to help inform their lead testing and remediation programs  Specifically, school districts reported that they want information on a recommended schedule for lead testing, how to remediate elevated lead levels, and information associated with testing and remediation costs (see fig  9)  For example, an estimated 54 percent of school districts responded that they would like additional information on a testing schedule, as did officials in 10 of the 17 school districts and one of the five states we interviewed  EPA’s 3Ts guidance does not include information to help school districts determine a schedule for retesting their schools  Officials in one school district told us they need information for determining retesting schedules for lead in their school drinking water, and that—without guidance—they chose to retest every 5 years, acknowledging that this decision was made without a clear rationale  Further, an estimated 62 percent of school districts reported wanting additional information on remedial actions to take to address elevated lead  For example, officials from the Massachusetts Department of Environmental Protection told us that they would like additional guidance on evaluating remedial actions to address elevated lead in the fixtures or the plumbing system  Officials with EPA’s Office of Ground Water and Drinking Water hold quarterly meetings with regional officials to obtain input on potential improvements to the 3Ts guidance, but have not made any revisions  EPA has not substantially updated the 3Ts guidance since October 2006 and does not have firm plans or time frames for providing additional information, including on the action level and other key topics such as a recommended schedule for testing  EPA officials said that they may update the 3Ts guidance before the LCR is updated, but did not provide a specific time frame for doing so  EPA has efforts underway to reconsider the action level for the LCR, which may include a change in the action level from one that is based on technical feasibility, to one that also considers lead exposure in vulnerable populations such as infants and young children, which EPA refers to as a health-based benchmark  EPA anticipates issuing comprehensive revisions to the LCR by February 2020  While the 3Ts guidance is not contingent on the LCR, EPA officials told us they would consider updates to the 3Ts guidance, including the 20 ppb action level, as they consider revisions to the LCR  By updating the 3Ts guidance to include an action level for school districts that incorporates available scientific modeling regarding vulnerable population exposures, EPA could have greater assurance that school districts are able to limit children’s exposure to lead  EPA has emphasized the importance of addressing elevated lead levels in school drinking water through its 3Ts guidance, but has not communicated necessary information about action levels and other key topics consistent with the external communication standard under federal standards for internal control  According to EPA, CDC, and others, eliminating sources of lead before exposure can occur is considered the best strategy to protect children from potential adverse health outcomes  EPA officials also told us that clear guidance is important because testing for lead in drinking water requires technical expertise  But without providing interim or updated guidance to help school districts choose an action level for lead remediation EPA will continue to provide schools with confusing information regarding whether to remediate, which may not adequately limit potential lead exposure to students and staff  Furthermore, without important information on key topics, such as a recommended schedule for lead testing, how to remediate elevated lead levels, and information associated with testing and remediation costs school districts are at risk of making misinformed decisions regarding their lead testing and remediation efforts  Education has not played a significant role in supporting state and school districts efforts to test for and remediate lead in school drinking water, and there has been limited collaboration between Education and EPA, according to officials  In 2005, Education, EPA, CDC, and other entities involved with drinking water signed the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities (the memorandum) to encourage and support schools’ efforts to test for lead in drinking water and to support actions to reduce children’s exposure to lead  According to the memorandum, Education’s role is to identify the appropriate school organizations with which to work and facilitate dissemination of materials and tools to schools in collaboration with EPA  In addition, EPA’s role is to update relevant guidance documents for school districts—resulting in the production of the 3Ts guidance in 2006—raising awareness, and collaborating with other federal agencies and associations, among other things  Education officials told us that the agency does not have any ongoing efforts related to implementing the memorandum  However, Education and EPA officials were not aware of the memorandum being terminated by either agency and told us the memorandum remains in effect  Although Education does not have any ongoing efforts related to implementing the memorandum, the agency’s websites, including the Readiness and Emergency Management for Schools Technical Assistance Center (REMS TA Center) website, and the Green Strides portal, provide links to EPA guidance and webinars on lead testing and remediation  The REMS TA Center website, which is largely focused on emergency management planning, includes a link to EPA’s 3Ts guidance and other resources on lead exposure and children, but does not provide information regarding the importance of testing for lead in school drinking water  Education’s Green Strides portal includes a link to a number of EPA’s webinars on lead in school drinking water, but does not include all of the quarterly webinars started in June 2017 to highlight school district efforts to test for lead  An Education official told us that these EPA webinars are identified by Education without coordinating with EPA officials  Further, when searching on Education’s website for lead in school drinking water, the 3Ts guidance does not show up  Education officials acknowledged that information regarding lead testing and remediation is difficult to find on Education’s website and they could take steps to make federal guidance on lead in school drinking water more accessible  The federal government has developed guidelines to help federal agencies improve their experience with customers through websites  One such resource is Guidelines for Improving Digital Services developed by the federal Digital Services Advisory Group  It states that federal agencies should take steps to make guidance easy to find and accessible  Making guidance easy to find and accessible such as by clarifying which links contain guidance; highlighting new or important guidance; improving their websites’ search function; and categorizing guidance on Education’s websites could help raise school district awareness of the guidance, which is currently low in most areas of the country  Many school districts are not familiar with EPA guidance related to lead testing and remediation  Specifically, an estimated 60 percent of school districts reported in our survey that they were not familiar with the EPA’s 3Ts guidance  Most school district officials from our site visits told us they did not have contact with EPA prior to or during their lead testing and some said they would not have thought to go to EPA for guidance  Likewise, EPA officials reported they had received feedback from school district officials indicating that they do not know where to go for information about testing for and remediating lead in drinking water  Rather, school district officials may look to their state educational agency or Education for guidance on lead testing and remediation, as they might do when looking for guidance on other topics  Education and EPA do not regularly collaborate to support state and school districts’ efforts related to lead in school drinking water, according to EPA and Education officials  Education officials said the agency does not have a role in ensuring safe drinking water in schools, and that the mitigation of environmental health concerns in school facilities is a state and local function  Therefore, the agency does not collaborate with EPA to disseminate the 3Ts guidance beyond posting links to related guidance on their websites and newsletters  EPA officials told us they do not know which office they should collaborate with at Education  EPA regional officials also said they do not collaborate with Education to disseminate the guidance to states and school districts  However, in the 2005 memorandum, EPA and Education agreed to work together to encourage school districts to test drinking water for lead; disseminate results to parents, students, staff, and other interested stakeholders; and take appropriate actions to correct elevated lead levels  There are many school districts that have not tested for lead in school drinking water, and some conducted testing without the assistance of federal guidance—although the large majority (68 percent) of school districts who use the guidance reported finding it helpful  Officials in 11 of 17 school districts we interviewed that had conducted lead testing told us they were familiar with the 3Ts guidance and 9 of those districts said they found it helpful for designing their lead testing programs  Increased encouragement and dissemination of EPA resources about lead in school drinking water by Education and EPA could help school districts test for and remediate lead in drinking water using good practices and reduce the potential risk of exposure for students and staff  Children are particularly at risk of experiencing the adverse effects of lead exposure from a variety of sources, including drinking water  While there is no federal law requiring lead testing for drinking water in most schools, some states and school districts have decided to test for lead in the drinking water to help protect students  However, there are a number of school districts that have not tested for lead and some that do not know if they have tested for lead in their drinking water, according to our nationwide survey  Even in states and school districts that have opted to test, officials may choose different action levels to identify elevated lead and may choose different testing protocols that do not test all fixtures in all schools  EPA has developed helpful guidance—3Ts—and webinars for states and school districts to support efforts to test and remediate lead in school drinking water  However, some EPA regional offices have not communicated the importance of testing for and remediating lead to states and school districts  By promoting further efforts to communicate the importance of lead testing to school districts to help ensure that their lead testing programs are in line with good practices, including the 3Ts guidance, regional offices that have not focused on this issue could build on the recent efforts of other regional offices to provide technical assistance and guidance and other forms of support  State and school district officials can use EPA’s 3Ts guidance to help ensure that their drinking water testing and remediation efforts are in line with good practices and said that it has been helpful for establishing their programs  However, statements in the guidance—which has not been updated in over a decade—that suggest the action level described will ensure that school facilities do not have elevated lead in their drinking water are misleading  In addition, state and school district officials told us that additional guidance—including information on a recommended schedule for retesting as well as on costs associated with testing and remediation—could help school districts make more informed decisions regarding their testing and remediation efforts  Without providing interim or updated guidance, EPA is providing schools with confusing and out of date information, which can increase the risk of school districts making uninformed decisions  EPA officials said they would consider updates to the 3Ts action level while the revisions to the LCR are being completed  However, the longer school districts are without the additional information they need to conduct their efforts in line with good practices and continue to rely on confusing and misleading information, the more challenges they will face in trying to limit children’s exposure to lead  After EPA revises the LCR, the agency would have greater assurance that school districts are limiting children’s exposure to lead by considering whether to develop, as part of its guidance, a health-based level for schools that incorporates available scientific modeling regarding vulnerable population exposures  Finally, although Education provides information to states and school districts on lead testing and remediation through the agency’s websites, that information is difficult to find  Further, Education’s website does not include all of EPA’s quarterly webinars to highlight school district efforts to test for lead  By making guidance accessible, Education could improve school district awareness of EPA resources about lead in school drinking water  In addition, EPA and Education should improve their collaboration to encourage and support lead testing and remediation efforts by states and school districts  EPA has the expertise to develop guidance and provide technical assistance to states and school districts, while Education, based on its mission to promote student achievement, should collaborate with EPA to disseminate guidance and raise awareness of lead in drinking water as an issue that could impact student success  Although over one-third of districts that tested found elevated levels of lead, many districts have still not been tested  Unless EPA and Education encourage additional school districts to test for lead, many students and school staff may be at risk of lead exposure  We are making a total of seven recommendations, including five to EPA and two to Education: The Assistant Administrator for Water of EPA’s Office of Water should promote further efforts to communicate the importance of testing for lead in school drinking water to address what has been a varied approach by regional offices  For example, the Assistant Administrator could direct those offices with limited involvement to build on the recent efforts of several regional offices to provide technical assistance and guidance, and other forms of support  (Recommendation 1) The Assistant Administrator for Water of EPA’s Office of Water should provide interim or updated guidance to help schools choose an action level for lead remediation and more clearly explain that the action level currently described in the 3Ts guidance is not a health-based standard  (Recommendation 2) The Assistant Administrator for Water of EPA’s Office of Water should, following the agency’s revisions to the LCR, consider whether to develop a health-based level, to include in its guidance for school districts, that incorporates available scientific modeling regarding vulnerable population exposures and is consistent with the LCR  (Recommendation 3) The Assistant Administrator for Water of EPA’s Office of Water should provide information to states and school districts concerning schedules for testing school drinking water for lead, actions to take if lead is found in the drinking water, and costs of testing and remediation  (Recommendation 4) The Assistant Secretary for Elementary and Secondary Education should improve the usability of Education’s websites to ensure that the states and school districts can more easily find and access federal guidance to address lead in school drinking water, by taking actions such as clarifying which links contain guidance; highlighting new or important guidance; improving their websites’ search function; and categorizing guidance  (Recommendation 5) The Assistant Administrator for Water of EPA’s Office of Water and the Director of the Office of Children’s Health Protection should collaborate with Education to encourage testing for lead in school drinking water  This effort could include further dissemination of EPA guidance related to lead testing and remediation in schools or sending letters to states to encourage testing in all school districts that have not yet done so  (Recommendation 6) The Assistant Secretary for Elementary and Secondary Education should collaborate with EPA to encourage testing for lead in school drinking water  This effort could include disseminating EPA guidance related to lead testing and remediation in schools or sending letters to states to encourage testing in all school districts that have not yet done so  (Recommendation 7) We provided a draft of this report to EPA, Education, and CDC for review and comment  EPA and Education provided written comments that are reproduced in appendixes VII and VIII respectively  EPA also provided technical comments, which we incorporated as appropriate  CDC did not provide comments  We also provided relevant excerpts to selected states and incorporated their technical comments as appropriate  In its written comments, EPA stated that it agreed with our recommendations and noted a number of actions it plans to take to implement them  For example, EPA said its Office of Ground Water and Drinking Water is holding regular meetings with regional offices and other EPA offices to obtain input on improving the 3Ts guidance  Potential revisions include updates to implementation practices, the sampling protocol, and the action level, including clarifying descriptions of different action levels and standards  Also, EPA said that while it has not yet determined the role of a health-based benchmark for lead in drinking water in the revised LCR, it sees value in providing states, drinking water systems, and the public with a greater understanding of the potential health implications for vulnerable populations of specific levels of lead in drinking water  EPA said it would continue to reach out to states and schools to provide information, technical assistance, and training and will continue to make the 3Ts guidance available  EPA also said it would work with Education to ensure that school districts and other stakeholders are aware of additional resources EPA is developing  In its written comments, Education stated that it agreed with our recommendations and noted a number of actions it plans to take to implement them  In response to our recommendation to improve Education’s websites, Education said it would identify and include an information portal dedicated to enhancing the usability of federal resources related to testing for and addressing lead in school drinking water  Also, Education said it is interested in increasing coordination across all levels of government and it shares the view expressed in our report that improved federal coordination, including with EPA, will better enhance collaboration to encourage testing for lead in school drinking water  Education said it would develop a plan for disseminating relevant resources to its key stakeholder groups and explore how best to coordinate with states to disseminate EPA’s guidance on lead testing and remediation to school districts  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 interested congressional committees, the Administrator of the Environmental Protection Agency, the Secretary of Education, the Director of the Centers for Disease Control and Prevention, 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 have any questions about this report, please contact us at (617) 788-0580 or nowickij@gao gov or (202) 512-3841 or gomezj@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 key contributions to this report are listed in appendix IX  In this report, we examined three objectives: (1) the extent to which school districts are testing for, finding, and remediating lead in school drinking water; (2) the extent to which states require or support testing for and remediating lead in school drinking water by school districts; and (3) the extent to which federal agencies are supporting state and school district efforts to test for and remediate lead  To address these objectives, we conducted a web-based survey of school districts, interviews with selected state and school district officials, a review of applicable requirements in selected states, a review of relevant federal laws and regulations, and interviews with federal agency officials and representatives of stakeholder organizations  We conducted this performance audit from October 2016 through July 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  To examine the extent to which school districts are testing for and remediating lead in school drinking water, we designed and administered a generalizable survey of a stratified random sample of U S  local educational agencies (LEA), which we refer to as school districts throughout the report  The survey included questions about school district efforts to test for lead in school drinking water, such as the number of schools in which tests were conducted, the costs of testing, and whether parents or others were notified about the testing efforts  We also asked questions about remediation efforts, such as whether lead was discovered in school drinking water, the specific remediation efforts that were implemented, and whether parents or others were notified about the remediation efforts  Further, we asked about officials’ familiarity with the Environmental Protection Agency’s (EPA) guidance entitled 3Ts for Reducing Lead in Drinking Water in Schools, (3Ts guidance) whether the guidance was used, and the extent to which it was helpful in conducting tests, remediating lead, and communicating with parents and others  We directed the survey to school district superintendents or other cognizant officials, such as facilities directors  See appendix II which includes the survey questions and estimates  We defined our target population to be all school districts in the 50 U S  states and the District of Columbia that are not under the jurisdiction of the Department of Defense or Bureau of Indian Education  We used the LEA Universe database from Department of Education’s (Education) Common Core of Data (CCD) for the 2014-2015 school year to our sampling frame  For the purpose of our survey, our sample was limited to school districts that: were located in the District of Columbia or the 50 states; had a LEA type code of 1, 2, 4, 5, 7, and 8; had one or more schools and one or more students; and were not closed according to the 2014-2015 School Year  The resulting sample frame included 16,452 school districts and we selected a stratified random sample of 549 school districts  We stratified the sampling frame into 13 mutually exclusive strata based on urban classification and poverty classification  We further stratified the school districts classified as being in a city by charter status  We selected the largest 100 school districts with certainty  We determined the minimum sample size needed to achieve precision levels of plus or minus 12 percentage points or fewer, at the 95 percent confidence level  We then increased the sample size within each stratum for an expected response rate of 70 percent  We defined the three urban classifications based on the National Center for Education Statistics (NCES) urban-centric locale code  To build a general measure of the poverty level for each school district we used the proportion of students eligible for free or reduced-price lunch (FRPL) as indicated in the CCD data and classified these into the following three groups: High-poverty – More than 75 percent of students in the school district were eligible for FRPL; Mid-poverty – Between 25 1 and 75 0 percent of students in the school district were eligible for FRPL; and Low-poverty – 25 percent or fewer students in the school district were eligible for FRPL  We assessed the reliability of the CCD data by reviewing existing documentation about the data and performing electronic testing on required data elements and determined they were sufficiently reliable for the purpose of our report  We administered the survey from July to October 2017 (the survey asked school districts to report information based on the 12 months prior to their completing the survey ) To obtain the maximum number of responses to our survey, we sent reminder emails to nonrespondents and contacted nonrespondents over the telephone  We identified that four of the 549 sampled school districts were closed and one was a “cyber-school” with no building, so these were removed from the sample  Of the remaining 544 eligible sampled school districts, we received valid responses from 373, resulting in an unweighted response rate of 68 percent  We conducted an analysis of our survey results to identify potential sources of nonresponse bias using a multivariate logistic regression model  We examined the response propensity of the sampled school districts by several demographic characteristics  These characteristics included poverty, urbanicity, and charter status  We did not find any other population characteristics significantly affected survey response propensity except those used in stratification (charter schools and the largest 100 school districts)  Based on the response bias analysis and the 68 percent response rate across stratum, we determined that estimates based on adjusted weights reflecting the response rate are generalizable to the population of eligible school districts and are sufficiently reliable for the purposes of this report  We took steps to minimize non-sampling errors, including pretesting draft instruments and using a web-based administration system  As we began to develop the survey, we met with officials from seven school districts to explore the feasibility of responding to the survey questions  We then pretested the draft instrument from April to June 2017 with officials in eight school districts—including one charter school district—in cities and suburbs in different states  In the pretests, we asked about the clarity of the questions and the flow and layout of the survey  The EPA also reviewed and provided us comments on a draft version of the survey  Based on feedback from the pretests and EPA’s review, we made revisions to the survey instrument  To further minimize non-sampling errors, we used a web-based survey, which allowed respondents to enter their responses directly into an electronic instrument  Using this method automatically created a record for each respondent and eliminated the errors associated with a manual data entry process  We express the precision of our particular sample’s results as a 95 percent confidence interval (for example, plus or minus 10 percentage points)  This is the interval that would contain the actual population value for 95 percent of the samples we could have drawn  As a result, we are 95 percent confident that each of the confidence intervals in this report will include the true values in the study population  To analyze differences in the percentages of school districts that reported they tested for lead in school drinking water and those that discovered lead, we compared weighted survey estimates generated for school districts in different levels of the following subgroups: Poverty: low poverty, mid poverty, and high poverty; Racial composition: majority-minority and majority white; Region: Northeast, South, Midwest, and West; Population density: urban, suburban, and rural/town; Urban charter school: in urban areas, charter district and non-charter Largest 100: largest 100 districts (based on student enrollment) and all other districts  For each subgroup, we produced percentage estimates and standard errors for each level and used these results to confirm the significance of the differences between weighted survey estimates  To examine school districts’ testing and remediation efforts and state support of those efforts, we conducted site visits in five states—Georgia, Illinois, Massachusetts, Oregon, and Texas—from February to October 2017  We selected these states because they varied in the extent to which they required testing of school drinking water for lead and they are located in geographic areas covered by different EPA regional offices  Within these states, we selected 17 school districts that had tested for lead in school drinking water and to achieve variation in the size and population density (urban, suburban, and rural) of the district as well as including one charter school district  Site visits generally consisted of interviews with officials in state agencies and school districts and officials in the local EPA regional office: State interviews: We interviewed officials in state environment, education, and health agencies, depending on whether they had information related to school district testing for lead in school drinking water in their state  The topics we discussed were the agencies’ roles and responsibilities related to testing for and remediation of lead in school drinking water, any related state requirements, policies, and guidance, communication and public notification about testing and remediation efforts and, as appropriate, coordination among multiple state agencies  We also discussed similar topics related to lead-based paint  In Massachusetts, we interviewed representatives with the University of Massachusetts, because of their role in implementing the state’s program to support school district efforts to test for lead in school drinking water  School Districts: Within the five site visit states, we interviewed officials in 14 school districts in person and in three school districts by phone (because we were not able to meet with them in person)  We also selected one charter school that functions as its own school district which had conducted tests for lead in school drinking water  Similar to our school district survey, the interview topics we discussed with district officials included testing for and remediation of lead in school drinking water, use of guidance (such as the 3Ts guidance) and efforts to communicate or coordinate with any federal, state, or local agencies, including any other school districts  Within 13 of the school districts, we visited at least one school in which the district had tested for lead in drinking water and, as needed, took remedial action in order to gain an in-depth understanding of their testing and remediation efforts  EPA Regional Offices: We interviewed officials in all 10 EPA Regional offices  We met in-person with officials in the regional offices 1, 4, 5, and 6 and conducted phone interviews with officials in regional offices 2, 3, 7, 8, 9, and 10  We generally discussed EPA officials’ roles and responsibilities related to testing for lead in school drinking water and paint and efforts in states and school districts in their region  Information we gathered from these interviews, while not generalizable, represents the conditions present in the states and school districts at the time of our interviews and may be illustrative of efforts in other states and school districts  As part of our effort to examine school districts’ testing and remediation efforts and state support of those efforts, we reviewed related state requirements  To determine whether states had related requirements, we asked all EPA regional offices if states in their region had requirements related to testing for lead in school drinking water  EPA provided examples of eight states (California, Illinois, Maryland, Minnesota, New Jersey, New York, Virginia, and the District of Columbia that had such requirements  We reviewed relevant laws, regulations, and policy documents for these states  We then confirmed the details of the related requirements with the appropriate state officials via structured questionnaires  Also, we used available documentation to corroborate and verify the testing requirements of the states that EPA identified  GAO did not conduct an independent search of state laws  To examine the extent to which federal agencies have collaborated in supporting state and school district efforts to test for and remediate lead, we reviewed relevant federal laws, including the Water Infrastructure Improvements for the Nation Act of 2016, Reduction of Lead in Drinking Water Act of 2011, the Safe Drinking Water Act of 1974, as amended, and the Lead Contamination Control Act of 1988; regulations, such as the Lead and Copper Rule; and guidance, such as the 3Ts guidance  We also reviewed documentation including the Memorandum of Understanding on Reducing Lead Levels in Drinking Water in Schools and Child Care Facilities signed in 2005 by EPA, Education and the Centers for Disease Control and Prevention (CDC); Federal Partners in School Health Charter; EPA training webinar information; and other relevant guidance including the 3Ts guidance tool kit  We interviewed officials from EPA’s Office of Ground Water and Drinking Water and Office of Children’s Health Protection and officials in all 10 of EPA regional offices regarding their approach to providing support to states and school district on lead testing and remediation  We interviewed officials from Education’s Office of Safe and Healthy Students and officials from the CDC  During these interviews, we interviewed officials about the Memorandum of Understanding and about the Federal Partners in School Health initiative, both of which represent collaborative efforts that address lead in school drinking water, among other topics  We evaluated federal efforts to collaborate and support lead testing and remediation in schools against federal standards for internal control, which call for agencies to communicate quality information to external parties, among other things  We also evaluated federal efforts against the Memorandum of Understanding, in which EPA, Education, and CDC agreed to encourage testing drinking water for lead and communicate with key stakeholders, among other things  To inform all of our research objectives, we interviewed representatives with the National Conference of State Legislatures, National Center for Healthy Housing, National Alliance of Public Charter Schools, the DC Public Charter School Board, and the 21st Century School Fund  We also attended a workshop entitled “Eliminating Lead Risks in Schools and Child Care Facilities” in December 2017  The questions we asked in our survey of local educational agencies (referred to in this report as school districts) are shown below  Our survey was comprised of closed- and open-ended questions  In this appendix, we include all survey questions and aggregate results of responses to the closed-ended questions; we do not provide information on responses provided to the open-ended questions  Estimates noted with superscript “a” are based on 20 or fewer responses and were not included in our findings  For a more detailed discussion of our survey methodology, see appendix I  1  Do any schools in your local educational agency (LEA) obtain drinking water from a public water system such as a city or municipal water plant? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) No (Skip to 20) Don’t know (Skip to 20) Section B: Testing for Lead in School Drinking Water 2  Is there a requirement that the drinking water in your LEA’s schools be tested for lead? (Please answer “Yes” regardless of whether that requirement comes from your state, municipality, local educational agency or any other governmental entity ) (Check one ) 95 percent confidence interval – lower bound (percentage) 3  Regardless of whether your LEA is required to test for lead in school drinking water, have tests been conducted for lead in the drinking water in at least one of your schools in the past 12 months? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If yes to 3: 3A  What is the number of schools in which tests were conducted in the past 12 months? Estimated Number (Mean) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 3B  About how many samples were taken from sources of drinking water such as water fountains and sinks in each school? (Check one ) 95 percent confidence interval – lower bound (percentage) 3C  Did any of the following develop the sampling plan, draw the samples of water, and analyze the samples? (Check all that apply ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 3D  What size samples were taken? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 3D: What sample size was used? 3E: To the best of your knowledge, did the personnel drawing or analyzing samples follow a testing protocol that offers guidance on developing the sampling plan, drawing samples of water, or analyzing samples? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) No (Skip to 3F) Don’t know (Skip to 3F) If ‘yes’ to 3E: a  To the best of your knowledge, were any of the following entities involved in developing the protocol? (Check one per row ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) Contractor / water testing company EPA or another federal government agency A local government agency (aside from your LEA) If ‘other’ to 3Eh: What other entities were involved in developing the protocol? 3F  If tests were conducted in some schools in your LEA in the past 12 months—but were not conducted in every school—how was it determined which schools would be tested? (Check one per row ) Not applicable: tests were conducted in every school (Skip to 3G) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 3Fe: In what other ways did your LEA use to determine which schools would be tested? 3G  How much do you estimate your LEA has spent on testing for lead in school drinking water in the past 12 months? (Please answer this question for lead testing only; the survey asks about expenditures to address concerns identified through testing later  Also, please include materials, labor, and any other expenditures related to lead testing in your estimate ) Estimated Number (Median) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 3H  Did your LEA use any of the following sources of funding for the testing in the past 12 months? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 3H: What other sources of funding did your LEA use? 3I  In the past 12 months, did your LEA notify the following groups that it was planning to test for lead in school drinking water before conducting the tests? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) General public (e g , media) If ‘other’ to 3I: What other groups did your LEA notify that it was planning to test for lead in school drinking water before conducting the tests? 3J  In the past 12 months, did your LEA report the testing results to the following groups after completing the tests? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) General public (e g , media) If ‘other’ to 3J: To what other groups did your LEA report the testing results? 3K  If ‘no’ to 3: Were any of the following a reason your LEA did not conduct any tests in any schools in the last 12 months? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 3K: For what other reasons did your LEA not conduct any tests in any schools in the last 12 months? 4  Does your LEA have a schedule for recurring tests to determine the amount of lead in the drinking water in your schools within any of the following time frames? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) Section C: Remediation of Lead in School Drinking Water 5  Has your LEA discovered any level of lead in the drinking water of any of your schools (as a result of testing) in the last 12 months? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 5A  What lead concentration (measured in “parts per billion” or “ppb”) did your LEA use to initiate remedial action? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 5A: What lead concentration did your LEA use to initiate remedial action? 5B  In the last 12 months, how many schools had at least one test result–including as few as one sample in one school–greater than the lead level your LEA used to initiate action? (Please answer regardless of whether these results were discovered in the first of multiple rounds of testing ) 5C To address lead discovered in school drinking water, has your LEA taken any of the following actions in any of your schools in the past 12 months? 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 5D  If ‘no’ to every item in 5C: What are the reasons why your LEA has not taken actions in any of your schools in the past 12 months? 5E  If ‘yes’ to any item in 5C: How much do you estimate your LEA has spent on taking actions in the past 12 months? (Please include materials, labor, and any other expenditures related to lead remediation in your estimate ) Estimated Number (Median) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 5F  Did your LEA use any of the following sources of funding to take actions in the past 12 months? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other’ to 5F: What other sources of funding did your LEA use to take actions in the past 12 months? 5G  Did your LEA notify the following groups about its actions in the past 12 months? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) General public (e g , media) If ‘other’ to 5G: What other groups has your LEA notified about its remedial actions in the past 12 months? 6  Does your LEA have a schedule to flush the water system as a result of concerns about lead in drinking water in at least one of your schools within any of the following time frames? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) 7  Does your LEA have plans to take actions to eliminate or reduce lead in school drinking water (for example, replace drinking water fountains, replace pipes) in at least one of your schools? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘according to a schedule’ to 7: how would you describe the schedule that your LEA has developed? Section D: Guidance Regarding Lead Testing and Remediation 8  Prior to receiving this survey, were you familiar with guidance issued by the U S  Environmental Protection Agency entitled “3Ts for Reducing Lead in Drinking Water in Schools”? (Please answer “Yes” if you had read or used the”3Ts” prior to receiving this survey ) (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘yes’ to 8: did your LEA (or a contractor working on behalf of your LEA) follow or refer to “3Ts” during your efforts to test for or remediate lead in school drinking water? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘yes’ to 8A: How helpful was 3Ts for conducting tests for lead in your schools’ drinking water? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘yes’ to 8A: How helpful was 3Ts for remediating lead in your schools’ drinking water? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘yes’ to 8A: How helpful was 3Ts for communicating with parents and other stakeholders about lead in your schools’ drinking water? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) What else, if anything, would make 3Ts more helpful? 9  Did your LEA (or a contractor working on behalf of your LEA) use any other guidance (for example, best practices, manuals, protocols, webinars) in your LEA’s efforts to test for lead in your schools’ drinking water, take remedial actions, or for notification purposes? (Check one ) 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) What other guidance was used? 10  Would your LEA find any of the following helpful? (Check one per row)  95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) Clearer guidance on a level of lead in school drinking water at which we should take action Additional guidance on determining a schedule for 41 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) regularly testing for lead in school drinking water Additional guidance on actions to take if lead is found in school drinking water Information on the costs of testing for lead in school drinking water Information on the costs of remediating lead in school drinking water 18 95 percent confidence interval – lower bound (percentage) 95 percent confidence interval – upper bound (percentage) If ‘other guidance or information’ to 10: What other guidance or information would be helpful? Section E: Inspecting Schools for Lead Based Paint Section F: Remediation of Lead Based Paint in Schools Section G: Other Questions 16  How many schools are owned or operated by your LEA? Estimated Number (Mean) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 17  How many schools in your LEA were built before 1986? (If a building has additions, we mean the original structure/the original part of the building ) Estimated Number (Mean) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 18  How many schools in your LEA were built before 1978? (If a building has additions, we mean the original structure/the original part of the building ) Estimated Number (Mean) 95 percent confidence interval – lower bound (number) 95 percent confidence interval – upper bound (number) (Respondent reported number) 19  Is there anything else you would like to share with us regarding lead testing, inspection, or remediation efforts in your school or LEA (drinking water or paint)? 20  What is the name, title, e-mail address, and telephone number of the person responsible for completing this survey? Section H: Completion 21  Please check one of the options below  Clicking on “Completed” indicates that your answers are official and final  Your answers will not be used unless you have done this  (Check one ) 95 percent confidence interval – lower bound (percentage) Charter schools comprise a small but growing group of public schools  In contrast to most traditional public schools, many charter schools are responsible for financing their own buildings and other facilities  As a result, charters schools vary in terms of whether they own their own building or pay rent, and whether they operate in buildings originally designed as a school or in buildings which have been redesigned for educational purposes  Sometimes charter schools may also share space in their building with others, such as non-profit organizations  In addition to differences in facility access and finance, charter school governance also varies  In some states, charter schools function as their own school district, while in other states, charter schools have the option to choose between being a distinct school district or part of a larger school district  To determine the extent to which charter school districts were testing for lead in school drinking water and finding and remediating lead, our survey included charter school districts in two ways: our sampling design included three strata specifically for charter school districts in urban areas; in addition, charter school districts were retained in the sampling population, such that they could be randomly selected in our other strata  While we generally received too few responses from charter school districts to report their data separately, we are able to estimate that about 36 percent of charter school districts tested for lead in school drinking water  To learn more about experiences of charter schools, we visited one charter school district and interviewed representatives of the DC Public Charter School Board (DC PCSB)  The charter school district we visited consisted of one charter school in a building it leased  The school had 10 sources of consumable water, all of which were tested in 2016 and were found to have lead below the district’s selected action level of 15 parts per billion  Before testing, district officials met with the building owner who agreed to cover the cost of any remediation  Officials with the DC PCSB told us that it paid to have tests conducted in every charter school in the District of Columbia  According to DC PCSB officials, between March and June 2016, 95 charter schools were tested, and lead above their action level of 15 parts per billion was discovered in 20 schools  Officials estimated their testing costs to be about $100,000, which was subsequently reimbursed by the District of Columbia’s Office of State Superintendent of Education  They also said that charter schools were responsible for taking steps to remediate the lead and recommended schools flush their water systems and use filters  Communication of results Not specified 5 ppb in a 250 ml sample (from filtered fixture) The Environmental Protection Agency (EPA) provides information on its website for the public on lead in drinking water  EPA’s website includes, among other documents, a December 2005 brochure for the public and school districts entitled “3Ts for Reducing Lead in Drinking Water in Schools” (see fig 10)  In addition to the individuals named above, Diane Raynes (Assistant Director), Scott Spicer (Assistant Director), Jason Palmer (Analyst-in- Charge), Amanda K  Goolden, Rich Johnson, Grant Mallie, Jean McSween, Dae Park, James Rebbe, Sarah M  Sheehan, and Alexandra Squitieri made significant contributions to this report  Also contributing to this report were Susan Aschoff, David Blanding, Mimi Nguyen, Tahra Nichols, Dan C  Royer, Kiki Theodoropoulos, and Kim Yamane  Lead Paint in Housing: HUD Should Strengthen Grant Processes, Compliance Monitoring, and Performance Assessment  GAO-18-394  Washington, D C : June 19, 2018  Drinking Water: Additional Data and Statistical Analysis May Enhance EPA’s Oversight of the Lead and Copper Rule  GAO-17-424  Washington, D C : September 1, 2017  Environmental Health: EPA Has Made Substantial Progress but Could Improve Processes for Considering Children’s Health  GAO-13-254  Washington, D C : August 12, 2013  Lead in Tap Water: CDC Public Health Communications Need Improvement  GAO-11-279  Washington, D C : March 14, 2011  Environmental Health: High-level Strategy and Leadership Needed to Continue Progress toward Protecting Children from Environmental Threats  GAO-10-205  Washington, D C : January 28, 2010  Drinking Water: EPA Should Strengthen Ongoing Efforts to Ensure That Consumers Are Protected from Lead Contamination  GAO-06-148  Washington, D C : January 4, 2006 


Report 2: Since 2001, the United States has made a commitment to building Afghanistan’s security and governance in order to prevent the country from once again becoming a sanctuary for terrorists  To achieve its security objectives, the United States currently has two missions in Afghanistan: a counterterrorism mission that it leads and the NATO-led Resolute Support train, advise, and assist mission, which it participates in with other coalition nations  The objective of Resolute Support, according to DOD reporting, is to establish self-sustaining Afghan security ministries and forces that work together to maintain security in Afghanistan  The United States is conducting these missions within a challenging security environment that has deteriorated since the January 2015 transition to Afghan-led security  The United Nations reported nearly 24,000 security incidents in Afghanistan in 2017—the most ever recorded—and, despite a slight decrease in the overall number of security incidents in early 2018, the United Nations noted significant security challenges, including a spike in high-casualty attacks in urban areas and coordinated attacks by the insurgency on ANDSF checkpoints  DOD provides both personnel and funding to support its efforts in Afghanistan  DOD documents indicate that the United States contributes more troops to Resolute Support than any other coalition nation  As of May 2018, the United States was contributing 54 percent of Resolute Support military personnel, according to DOD reporting  Of the approximately 14,000 U S  military personnel in Afghanistan as of June 2018, about 8,500 were assigned to Resolute Support to train, advise, and assist the ANDSF, according to DOD reporting  For fiscal year 2018, Congress appropriated about $4 67 billion for the Afghanistan Security Forces Fund—the primary mechanism of U S  financial support for manning, training, and equipping the ANDSF  Other international donors provided about $800 million, and the Afghan government committed to providing about $500 million, according to DOD reporting  Under Resolute Support and the International Security Assistance Force mission that preceded it, CSTC-A is the DOD organization responsible for (1) overseeing efforts to equip and train the ANA and ANP; (2) validating requirements, including equipment requirements; (3) validating existing supply levels; (4) submitting requests to DOD components to contract for procurement of materiel for the ANDSF; and (5) ensuring that the Afghan government appropriately uses and accounts for U S  funds provided as direct contributions from the Afghanistan Security Forces Fund  OSD-P is responsible for developing policy on and conducting oversight of the bilateral security relationship with Afghanistan focused on efforts to develop the Afghan security ministries and their forces  In August 2017, we reported that the United States had spent almost $18 billion on equipment and transportation for the ANDSF from fiscal years 2005 through April 2017, representing the second-largest expenditure category from the Afghanistan Security Forces Fund  In that report, we identified six types of key equipment the United States funded for the ANDSF in fiscal years 2003 through 2016, including approximately: 600,000 weapons, such as rifles, machine guns, grenade launchers, shotguns, and pistols; 163,000 tactical and nontactical radios, such as handheld radios and 76,000 vehicles, such as Humvees, trucks, recovery vehicles, and mine resistant ambush protected vehicles; 30,000 equipment items for detecting and disposing of explosives, such as bomb disposal robots and mine detectors; 16,000 equipment items for intelligence, surveillance, and reconnaissance, such as unmanned surveillance drones and night vision devices; and 208 aircraft, such as helicopters, light attack aircraft, and cargo airplanes  The Ministry of Defense oversees the ANA, and the Ministry of the Interior oversees the ANP  According to DOD reporting, the authorized force level for the ANDSF, excluding civilians, as of June 2018 was 352,000: 227,374 for the Ministry of Defense and 124,626 for the Ministry of Interior  The ANA includes the ANA corps, Afghan Air Force, Special Mission Wing, ANA Special Operations Command, and Ktah Khas (counterterrorism forces)  The ANP includes the Afghan Uniformed Police, Afghan Anti-Crime Police, Afghan Border Police, Public Security Police, Counter Narcotics Police of Afghanistan, and General Command of Police Special Units  The ANA Special Mission Wing, Ktah Khas, ANA Special Operations Command, and ANP General Command of Police Special Units are collectively referred to as the Afghan Special Security Forces  In this report, we refer to the Afghan Air Force and the Afghan Special Security Forces as specialized forces, and the other components of the ANDSF as conventional forces  According to DOD reporting, the combined authorized force level for the specialized forces as of June 2018 was approximately 34,500, or about 10 percent of the ANDSF’s total authorized force level of 352,000, compared with the conventional forces, which make up about 74 percent of the total authorized force level for the ANDSF  Figure 1 shows the ANDSF’s organization  U S  and coalition advisors from Resolute Support focus on capacity building at the Ministry of Defense, Ministry of Interior, and ANDSF regional headquarters, according to DOD reporting  Ministerial advisors are located at Resolute Support headquarters in Kabul  At the ministerial level, advisors provide assistance to improve institutional capabilities, focusing on several functional areas  Table 1 summarizes the indicators of effectiveness that ministerial advisors are to use to measure ministerial progress in developing functioning systems that can effectively execute each of the functional areas  Regional Resolute Support advisors from seven advising centers located throughout Afghanistan provide support to nearby ANA corps and ANP zone headquarters personnel, according to DOD reporting  Some advisors are embedded with their ANDSF counterparts, providing a continuous coalition presence, while others provide less frequent support, based on proximity to and capability of their ANDSF counterparts  Regional advisors are to track ANDSF capability development by assessing the progress of the ANA corps and ANP zone headquarters based on five capability pillars (see table 2)  DOD and other Resolute Support advisors are to document the results of these assessments each quarter in an ANDSF Assessment Report  According to DOD reporting, in addition to ministerial and regional advising, two tactical-level advisory commands provide continuous support for the ANDSF’s specialized forces: Train, Advise, and Assist Command–Air (TAAC-Air) advises the Afghan Air Force down to the unit level, and NATO Special Operations Component Command–Afghanistan (NSOCC-A) primarily provides tactical-level special operations advising for the Afghan Special Security Forces  TAAC-Air and NSOCC-A assess capabilities at the headquarters level based on the five capability pillars described above in table 2, and these assessments are included in the quarterly ANDSF Assessment Report  Figure 2 shows the levels of advising each Resolute Support advisory command type provides for the ANDSF conventional forces and specialized forces  Since Resolute Support began, the ANDSF have improved some capabilities related to the functional areas and capability pillars described above, but face several capability gaps that leave them reliant on coalition assistance, according to publicly available DOD reporting  DOD defines capability as the ability to execute a given task  A capability gap is the inability to execute a specified course of action, such as an ANDSF functional area or a capability pillar (see tables 1 and 2 above)  According to DOD guidance, a gap may occur because forces lack a materiel or non-materiel capability, lack proficiency or sufficiency in a capability, or need to replace an existing capability solution to prevent a future gap from occurring  According to DOD reporting on the Afghan security ministries, ANA corps, and ANP zones, the ANDSF generally have improved in some capability areas since Resolute Support began, with some components performing better than others  For example, DOD has reported that the Afghan ministries have improved in operational planning, strategic communications, and coordination between the Ministry of Interior and Ministry of Defense at the national level  In general, the ANA is more capable than the ANP, according to DOD reporting  According to DOD officials and SIGAR reporting, this is due, in part, to the ANA having more coalition advisors and monitoring than the ANP  DOD officials also noted that the Ministry of Interior, which oversees the ANP, and Afghanistan’s justice system are both underdeveloped, hindering the effectiveness of the ANP  Corruption, understaffing, and training shortfalls have also contributed to the ANP’s underdevelopment, according to DOD and SIGAR reporting  The Afghan Special Security Forces are the most capable within the ANDSF and can conduct the majority of their operations independently without coalition enablers, according to DOD reporting  DOD and SIGAR reports have attributed the Afghan Special Security Forces’ relative proficiency to factors such as low attrition rates, longer training, and close partnership with coalition forces  The Afghan Air Force is becoming increasingly capable, and can independently plan for and perform some operational tasks, such as armed overwatch and aerial escort missions, according to DOD reporting  However, DOD has reported that the ANDSF generally continue to need support in several key areas  For example, as of December 2017, DOD reported several ministerial capability gaps, including force management; logistics; and analyzing and integrating intelligence, surveillance, and reconnaissance information  DOD also reported that, as of December 2017, the ANA and ANP continued to have capability gaps in several key areas, such as weapons and equipment sustainment and integrating fire from aerial and ground forces  The ANDSF rely on support from contractors and coalition forces to mitigate capability gaps in these key areas  For some capability areas, such as aircraft and vehicle maintenance and logistics, the ANDSF is not expected to be self- sufficient until at least 2023, according to DOD reporting  According to DOD officials and SIGAR reporting, coalition and contractor support helps mitigate ANDSF capability gaps in the immediate term but may make it challenging to assess the ANDSF’s capabilities and gaps independent of such support  For example, vehicle and aircraft maintenance contractors are responsible for sustaining specific operational readiness rates for the equipment they service  While this helps ensure that ANDSF personnel have working equipment to accomplish their mission, thereby closing an immediate capability gap, it may mask the ANDSF’s underlying capabilities and potentially prolong reliance on such support, according to DOD officials and SIGAR reporting  DOD and the ANDSF have begun implementing plans and initiatives that aim to strengthen ANDSF capabilities  These include the following, among others: ANDSF Roadmap  In 2017, the Afghan government began implementing the ANDSF Roadmap—a series of developmental initiatives that seek to strengthen the ANDSF and increase security and governance in Afghanistan, according to DOD reporting  The Roadmap is structured to span 4 years, but DOD has reported that its full implementation will likely take longer than that  According to DOD reporting, the Roadmap aims to improve four key elements: (1) fighting capabilities; (2) leadership development; (3) unity of command and effort; and (4) counter-corruption efforts  Under the Roadmap’s initiative to increase the ANDSF’s fighting capabilities, DOD and the ANDSF have begun implementing plans to increase the size of the specialized forces  Specifically, DOD reports that the ANDSF plans to nearly double the size of the Afghan Special Security Forces by 2020 as an effort to bolster the ANDSF’s offensive reach and effectiveness  The Afghan Special Security Forces are to become the ANDSF’s primary offensive force, the conventional ANA forces are to focus on consolidating gains and holding key terrain and infrastructure, and the conventional ANP forces are to focus on community policing efforts  In addition, to provide additional aerial fire and airlift capabilities, the ANDSF began implementing an aviation modernization plan in 2017  The aim is to increase personnel strength and the size of the Afghan Air Force and Special Mission Wing fleets by 2023  Enhanced vehicle maintenance efforts  To help improve the ANDSF’s vehicle maintenance abilities, DOD awarded a National Maintenance Strategy Ground Vehicle Support contract, which, according to DOD officials, became fully operational in December 2017  The National Maintenance Strategy Ground Vehicle Support contract consolidated five separate vehicle maintenance and training contracts into a single contract and contains provisions for building the capacity of ANDSF and Afghan contractors to incrementally take control of vehicle maintenance over a 5-year period  Additional U S  military personnel  As part of the South Asia strategy, the United States committed 3,500 additional military personnel to increase support to its missions in Afghanistan  According to DOD reporting, most of the additional personnel will support the Resolute Support mission, providing more advising and combat enabler support to the ANDSF  Additionally, in March 2018, the United States began deploying a Security Force Assistance Brigade—a new type of unit made up of U S  Army personnel with expertise in training foreign militaries—to Afghanistan  The Security Force Assistance Brigade will advise conventional and specialized forces at and below the corps and zone levels and will accompany and support ANA conventional forces at the battalion level in ground operations as needed, according to DOD and SIGAR reporting  DOD collects some reliable information about the operation and maintenance abilities of ANDSF specialized forces, in part because advisors are embedded at the tactical level with the specialized forces, according to DOD officials  Specifically, U S  and coalition forces advise specialized forces at the tactical level under Resolute Support because building ANDSF aviation and special operations abilities are considered particularly important, according to DOD reporting  DOD officials told us that since U S  and coalition forces are embedded at the tactical level for specialized forces, they can monitor, assess, and report on tactical abilities, including the ability to operate and maintain equipment  Our analysis of information provided by DOD about the Afghan Air Force’s ability to operate and maintain MD-530 helicopters illustrates that DOD has some detailed information about specialized forces  TAAC-Air advisors help train Afghan pilots and maintainers and collect information on their tactical abilities  For example, TAAC-Air advisors track the percentage of maintenance performed by Afghan Air Force maintainers and aircraft operational readiness rates, according to DOD officials  According to DOD reporting and officials, as of December 2017, the Afghan Air Force could independently conduct MD-530 helicopter operations for short intervals without contractor support but relied on contractors to perform the majority of maintenance and sustainment activities  See appendix II for more information on the Afghan Air Force’s ability to operate and maintain MD-530 helicopters  U S  and coalition forces perform high-level assessments of the ANDSF conventional forces’ capabilities at the corps and zone levels but do not assess their tactical abilities, such as the ability to operate and maintain equipment, according to DOD officials  For example, U S  and coalition forces assess the ANA and ANP conventional forces in quarterly ANDSF Assessment Reports, but these reports are at the corps and zone headquarters levels, and are not meant to provide an evaluation of the entire ANDSF, according to DOD reporting  DOD officials stated that other U S - and coalition-produced reports and assessments, such as DOD’s semiannual Section 1225 reports to Congress, semiannual periodic mission reviews, and annual Afghanistan Plans of Record, provide some information on the ANDSF’s high-level capabilities  However, according to DOD officials, these reports do not routinely assess the conventional forces’ ability to operate and maintain equipment  According to DOD officials, DOD does not assess conventional forces’ tactical abilities because advisors have had little or no direct contact with conventional units below the corps and zone levels, and thus do not collect such information on conventional forces  Specifically, under Resolute Support, U S  and coalition forces have not embedded with the conventional forces below the corps and zone levels except in limited circumstances  Since U S  and coalition forces do not collect firsthand information on the conventional units’ tactical abilities, they rely on those units’ self-reporting for information on ANDSF abilities below the corps and zone levels, which, according to DOD officials, may be unreliable  ANDSF reporting is not verified by U S  officials and can be unreliable in its consistency, comprehensiveness, and credibility, according to DOD officials and SIGAR  For example, the ANDSF produce a monthly tracker on vehicle availability, maintenance backlog, repair times, and personnel productivity, but DOD officials told us that the trackers are of questionable accuracy

ground_truth: No federal law requires testing of drinking water for lead in schools that receive water from public water systems, although these systems are regulated by the EPA. Lead can leach into water from plumbing materials inside a school. The discovery of toxic levels of lead in water in Flint, Michigan, in 2015 has renewed awareness about the danger lead exposure poses to public health, especially for children. GAO was asked to review school practices for lead testing and remediation. This report examines the extent to which (1) school districts are testing for, finding, and remediating lead in drinking water; (2) states are supporting these efforts; and (3) federal agencies are supporting state and school district efforts. GAO administered a web-based survey to a stratified, random sample of 549 school districts, the results of which are generalizable to all school districts. GAO visited or interviewed officials with 17 school districts with experience in lead testing, spread among 5 states, selected for geographic variation. GAO also interviewed federal and state officials and reviewed relevant laws and documents. An estimated 43 percent of school districts, serving 35 million students, tested for lead in school drinking water in 2016 or 2017, according to GAO's nationwide survey of school districts. An estimated 41 percent of school districts, serving 12 million students, had not tested for lead. GAO's survey showed that, among school districts that did test, an estimated 37 percent found elevated lead (lead at levels above their selected threshold for taking remedial action.) (See figure.) All school districts that found elevated lead in drinking water reported taking steps to reduce or eliminate exposure to lead, including replacing water fountains, installing filters or new fixtures, or providing bottled water. According to the Environmental Protection Agency (EPA), at least 8 states have requirements that schools test for lead in drinking water as of 2017, and at least 13 additional states supported school districts' voluntary efforts with funding or in-kind support for testing and remediation. In addition, the five states GAO visited provided examples of technical assistance to support testing in schools. EPA provides guidance and other resources to states and school districts regarding testing and remediating lead in drinking water, and the Department of Education (Education) provides some of this information on its websites. School district officials that used EPA's written guidance said they generally found it helpful. Although EPA guidance emphasizes the importance of addressing elevated lead levels, GAO found that some aspects of the guidance, such as the threshold for taking remedial action, were potentially misleading and unclear, which can put school districts at risk of making uninformed decisions. In addition, many school districts reported a lack of familiarity with EPA's guidance, and their familiarity varied by region of the country. Education and EPA do not regularly collaborate to support state and school district efforts on lead in drinking water, despite agreeing to do so in a 2005 memorandum of understanding. Such collaboration could encourage testing and ensure that more school districts will have the necessary information to limit student and staff exposure to lead. GAO is making seven recommendations, including that EPA update its guidance on how schools should determine lead levels requiring action and for EPA and Education to collaborate to further disseminate guidance and encourage testing for lead. EPA and Education agreed with the recommendations.

prompt_front: You are given two reports by the government agency.



Question: Write a one-page summary of the report 2.



Report 2:  Our analysis of information provided by DOD about the ANDSF’s ability to operate and maintain tactical and nontactical radios illustrates the limited amount of information DOD has on ANDSF conventional forces’ tactical abilities  Specifically, DOD officials could not say how well ANDSF personnel on the front lines operate radios in the field and had only limited information on the ANDSF’s ability to maintain radios  For example, the officials noted that the ANA conventional forces can perform some unit-level radio repairs but that complex ANA radio maintenance and all ANP radio maintenance is conducted by contractors  DOD officials at Resolute Support headquarters told us that they provide ministerial- level advising on how to manage ANDSF radio systems and do not provide tactical advising or inventory control for radios  See appendix III for more information on the ANDSF’s ability to operate and maintain radios  Our analysis of information provided by DOD about the ANDSF’s ability to operate and maintain Mobile Strike Force Vehicles (MSFV) highlights the limited amount of information DOD has on ANDSF conventional forces’ tactical abilities compared with specialized forces  DOD officials were able to provide operation and maintenance information for MSFVs that had transferred to the specialized forces as of January 2018 but were unable to provide operation and maintenance information for any other MSFVs  The ANDSF began transferring one of the ANDSF’s two MSFV brigades from the conventional to specialized forces in August 2017, according to DOD officials  As part of this transfer, NSOCC-A advisors—who provide tactical-level advising for the Afghan Special Security Forces—assumed oversight for the first brigade from Resolute Support headquarters advisors  DOD officials stated that the ANDSF’s ability to operate and maintain MSFVs in this brigade prior to the transfer was unknown, as neither Resolute Support headquarters nor the ANA had assessed this  The operation and maintenance abilities of the second brigade, which is still in the conventional forces, remains unknown  DOD officials at NSOCC-A were able to provide information such as inventory and mission capability rates for the MSFVs that had transferred, but only for the short period of time the vehicles had been under the control of the specialized forces  DOD officials told us that NSOCC-A plans to collect more information on the specialized forces’ ability to operate and maintain MSFVs as they are transferred  See appendix IV for more information on the ANDSF’s ability to operate and maintain MSFVs  In the absence of embedded advisors at the tactical level, DOD has not implemented alternative approaches to collect reliable information about the conventional forces’ ability to operate and maintain equipment  Federal internal control standards state that U S  agencies should obtain and process reliable information to evaluate performance in achieving key objectives and assessing risks  DOD officials acknowledged that some of the plans described above that DOD and the ANDSF have begun implementing to address capability gaps may provide opportunities for DOD to collect more reliable information on the conventional forces’ ability to operate and maintain U S -purchased equipment  For example, the National Maintenance Strategy Ground Vehicle Support contract requires that contractors regularly report the total work orders received, work in progress, and completed maintenance work performed by ANDSF personnel as well as vehicle availability rates, which may be more reliable than the ANDSF’s monthly report on vehicle availability  In addition, the Security Force Assistance Brigade may be able to collect and report on the tactical abilities of units they advise and accompany on missions since they are being deployed at or below the corps and zone levels  However, as of June 2018, DOD officials had not decided which, if any, of these options to pursue  Without reliable information on the equipment operation and maintenance abilities of ANDSF conventional forces, which represent nearly 75 percent of the ANDSF, DOD may be unable to fully evaluate the success of its train, advise, assist, and equip efforts in Afghanistan  The United States invested nearly $84 billion in Afghan security in the 17- year period spanning fiscal years 2002 through 2018, but DOD continues to face challenges to developing a self-sustaining ANDSF  While DOD has reported the ANDSF have improved in several capability areas, they continue to face critical capability gaps, impeding their ability to maintain security and stability in Afghanistan independent of U S  and coalition forces  Moreover, DOD lacks reliable information about the degree to which conventional forces—which make up about three-quarters of the ANDSF—are able to operate and maintain U S -purchased equipment  This limits DOD’s ability to fully evaluate the success of its train, advise, assist, and equip efforts in Afghanistan  The Secretary of Defense should develop and, as appropriate, implement options for collecting reliable information on the ANDSF conventional forces’ ability to operate and maintain U S -purchased equipment  (Recommendation 1) We provided a draft of this report to DOD and State for comment  DOD declined to provide written comments specifically on this public version of the report, but DOD’s comments on the sensitive version of this report are reprinted in appendix V  The sensitive version of this report included two recommendations, which DOD cited in its comments on the draft of the sensitive report  One of those recommendations related to information that DOD deemed to be sensitive and that must be protected from public disclosure  Therefore, we have omitted that recommendation from DOD’s comment letter in appendix V  This omission did not have a material effect on the substance of DOD’s comments  In its comments, DOD concurred with the recommendation we made in this version of the report and stated it will take steps to implement it  DOD also provided technical comments, which we incorporated as appropriate  The Department of State had no comments  We are sending copies of this report to the appropriate congressional committees, the Secretary of Defense, and the Secretary of State  In addition, the report is available at no charge on the GAO website at http://www gao gov  If you or your staff has any questions about this report please contact me at (202) 512-7114 or farbj@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 key contributions to this report are listed in appendix VI  House Report 114-537 associated with the National Defense Authorization Act for Fiscal Year 2017 included a provision for us to review the Afghan National Defense and Security Forces’ (ANDSF) capability and capacity to operate and sustain U S -purchased weapon systems and equipment  This report is a public version of a sensitive report that we issued on September 20, 2018  Our September report included three objectives, including one on the extent to which DOD considers ANDSF input and meets their needs when identifying equipment requirements  DOD deemed the information related to that objective to be sensitive, which must be protected from public disclosure  Consequently, we removed that objective and a related recommendation from this public report  This version includes information on the other two objectives: (1) what has been reported about ANDSF capabilities and capability gaps and (2) the extent to which DOD has information about the ANDSF’s ability to operate and maintain U S -purchased equipment  Although the information provided in this report is more limited, the report uses the same methodology for the two objectives as the sensitive report  To identify what has been reported about ANDSF capabilities and capability gaps, we reviewed North Atlantic Treaty Organization (NATO) and DOD documents and reports, such as DOD’s semiannual Section 1225 reports to Congress, produced after the start of the NATO-led Resolute Support mission on January 1, 2015  To determine what steps DOD and NATO have taken to try to address gaps, we reviewed reports the Center for Naval Analyses produced for DOD, as well as DOD and NATO documents and reports produced after January 1, 2015, and reports from GAO, the Special Inspector General for Afghanistan Reconstruction (SIGAR), and the DOD Inspector General  We also interviewed Center for Naval Analyses representatives and DOD officials in the United States and Afghanistan, including DOD officials at the Combined Security Transition Command–Afghanistan (CSTC-A) and in the Office of the Undersecretary of Defense for Policy (OSD-P) who helped create the DOD reporting we reviewed  To determine the extent to which DOD has information about the ANDSF’s ability to operate and maintain U S -purchased equipment, we reviewed DOD documents and reports and interviewed DOD officials in the United States and Afghanistan, including DOD officials who advise the ANDSF  We also reviewed federal internal control standards to determine what responsibilities agencies have specifically related to information collection  To provide illustrative examples of information DOD has about the ANDSF’s ability to operate and maintain U S - purchased equipment and what that information indicates about the ANDSF’s abilities and challenges, we interviewed and analyzed written responses from DOD officials, including DOD officials who provide procurement and lifecycle management for some ANDSF aircraft and vehicles, about three equipment types—MD-530 helicopters, Mobile Strike Force Vehicles (MSFV), and radios  We selected these three equipment types from a list that we developed, for an August 2017 report, of key ANDSF equipment the United States purchased from fiscal years 2003 through 2016  We made our selections after reviewing DOD documentation and interviewing DOD officials regarding a number of considerations, such as (1) how critical the equipment is to the ANDSF’s ability to achieve its mission; (2) which ANDSF component uses the equipment (i e , Afghan National Police, Afghan National Army, or both); (3) whether DOD intends to continue procuring the equipment for the ANDSF; and (4) whether the equipment had been in use at least 5 years  We collected detailed information about the ANDSF’s ability to operate and maintain MD-530 helicopters, MSFVs, and radios, as well as other key statistics DOD provided about the equipment, such as inventory, average lifespan, average cost, role, and training  This information was based mainly on DOD responses collected from January 2018 to February 2018 as well as DOD documents and reports produced after January 1, 2015  The total amount of MD-530s and radios authorized for procurement was based on DOD data that we collected for our August 2017 report on key ANDSF equipment the United States purchased in fiscal years 2003 through 2016, which we supplemented with additional data DOD provided on U S -purchased equipment from October 1, 2016, through December, 31, 2017  The performance audit upon which this report is based was conducted from August 2016 to September 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  We subsequently worked with DOD from September 2018 to October 2018 to prepare this public version of the original sensitive report for public release  This public version was also prepared in accordance with those standards  Manufacturer: MD Helicopters, Inc  U S  Program Management Office: U S  Army, Non-Standard Rotary Wing Aircraft Project Management Office Program Advising: Train Advise Assist Command–Air (TAAC-Air) The United States originally procured 6 unarmed MD-530s for the AAF for rotary wing training in 2011  In 2014, the United States purchased 12 armed MD-530s and began retrofitting the 5 remaining trainer helicopters with armament for operational missions to address a close air attack gap  MD- 530s were chosen to fill the gap over other aircraft, in part because they could be delivered relatively quickly as the AAF awaited A-29 light attack aircraft that were experiencing procurement delays, according to Department of Defense (DOD) officials  The United States procured additional MD-530s in 2015, 2016, and 2017 because of the aircraft’s positive impact on the battlefield, according to DOD officials (see fig  3)  Key Statistics Variants: All can be armed with  50-cal machine gun pods and/or 2 75 inch rocket pods  Total Authorized for Procurement: 60 as of December 31, 2017 Inventory: 25 as of January 2018 (30 are scheduled for delivery; attrition of 5 due to crashes and enemy fire) Average Lifespan: Absent mishaps, and with good maintenance, there is no defined lifespan limit for MD-530s, according to DOD officials  National Army and Afghan National Police, depending on the mission, in all but one region of Afghanistan, which is supported by other aircraft  MD-530s are typically tasked two at a time for missions, according to DOD officials  An MD-530 crew consists of a pilot and co-pilot, according to DOD  Average cost: $6 3 million per aircraft, including all electronic devices, weapons management systems, and weapons (excluding ordnance), according to DOD officials  o Division of labor is based on the individual crew members' capabilities, with one pilot handling navigation and communication while the other identifies targets and operates the weapon systems  Army pilot advisors at Kandahar Air Field, according to DOD officials  o MD-530 pilot training takes about 3 years (see fig  4)  1  The GAO report number cited in DOD’s letter refers to a draft of the sensitive version of this report, which we issued on September 20, 2018  Prior to issuing that version, we changed its report number to GAO-18- 662SU to reflect its sensitive nature  That version of this report included two recommendations  The second recommendation has been omitted from DOD’s letter in this public version because it was related to information that DOD deemed to be sensitive  In addition to the contact named above, Joyee Dasgupta (Assistant Director), Kara Marshall, Katherine Forsyth, and Bridgette Savino made key contributions to this report  The team also benefitted from the expert advice and assistance of David Dayton, Neil Doherty, Justin Fisher, Ashley Alley, Cary Russell, Marie Mak, James Reynolds, Sally Williamson, Ji Byun, and J  Kristopher Keener 
Report 2:  Expected program tasks include updating asset records and improving and consolidating asset inventories in WMATA’s asset system of record (called Maximo)  WMATA’s efforts to develop more complete asset inventory and condition assessments are not complete  Among other things, WMATA documentation on the Enterprise Asset Management Program cited “inattention, poor standardization, and organizational silos” as factors that have resulted in WMATA having multiple sets of asset records in various states of accuracy and usefulness  The Enterprise Asset Management Program, according to WMATA, is an effort to help address this situation and improve asset data quality, including inventory and condition assessments  Although WMATA is developing a new Enterprise Asset Management Program, it has yet to develop a plan for obtaining a complete inventory or physical condition assessments of its assets  The Project Management Institute’s Guide to the Project Management Body of Knowledge, PMBOK® Guide describes the elements of good project management and their importance in achieving organizational goals  Among these elements are: Having a project charter that formally authorizes a project, that commits resources to the activity, and that provides a direct link to organizational strategic objectives; Preparing a project plan to define the basis of the project’s work and how the work will be performed; and Establishing a monitoring and control process to track, review, and report overall progress in meeting the plan’s objectives  WMATA has prepared draft documents that describe how it will implement the Enterprise Asset Management Program and that contain some elements of good project management  For example, in January 2018 WMATA circulated a proposed charter that once approved would authorize the Enterprise Asset Management program, identify needed resources, and link to WMATA’s strategic goals  As of October 2018, this proposed charter had not yet been finalized  Draft program documents also indicate there would be a monitoring and control process that would establish regular reporting to internal stakeholders to assess program accomplishments and progress implementing the program  While WMATA has developed a proposed charter and a monitoring and control process for its Enterprise Asset Management Program, it has not established a plan for collecting asset inventory and condition assessment information  The draft program charter includes general tasks for updating asset records and improving and consolidating asset inventory data in Maximo  However, a plan would provide more specific details for how the work would be completed, such as the information to be collected on different assets, how and when this information would be consolidated into Maximo, milestones for completing the work, or how the effort would be funded  Without a plan to obtain asset inventory and condition assessment information WMATA will continue to lack critical information needed for good capital planning and sound investment decision-making  WMATA has reported significant progress toward its goals of reducing track defects and fire incidents, but still faces several challenges with implementing its track preventive maintenance program  WMATA defines an incident as any unplanned event that disrupts rail revenue service  According to WMATA officials, within the track preventive maintenance program WMATA seeks to reduce incidents specifically caused by electrical wayside fires and track defects each by 50 percent from fiscal year 2017 to fiscal year 2019  WMATA reported that in fiscal year 2018 it had met its goal for track defect incidents but not for electrical wayside fires  According to officials, track defect incidents—which include incidents caused by defective fasteners, switches, and “ballast”—were reduced by 50 percent from a total of 778 in fiscal year 2017 to 387 in fiscal year 2018  Electrical-wayside-fire incidents—including incidents caused by cable and insulator fires—went down 20 percent from a total of 55 in fiscal year 2017 to 44 in fiscal year 2018 (see fig 5)  Although WMATA has reduced both track defect incidents and electrical fires, the track preventive maintenance program is not intended to address the full range of all defects and track fires that may occur on the system  WMATA officials told us that the track preventive maintenance program specifically seeks to reduce electrical-wayside-fire incidents, which are a specific sub-set of overall track fires, and does not include non-electrical fires or smoke incidents, such as the ones caused by railcars or debris  WMATA captures and publicly reports the non-electrical fires as part of its quarterly Metro Performance Report, but according to WMATA officials, these fires are not specifically addressed through the track preventive maintenance program  While electrical fires decreased in fiscal year 2018, non-electrical fires did not change, as WMATA reported 23 non-electrical fires for both fiscal years 2017 and 2018  Additionally the track preventive maintenance program addresses a certain sub-set of track defect incidents such as those caused by loose fasteners and defective switches  According to WMATA, these track defect incidents can be addressed through its track geometry, torqueing, and switch maintenance initiatives  WMATA addresses other types of track defects, such as rail breaks and third-rail defects, through its capital program  However, according to WMATA, track defects attributable to the capital program are still included as part of the overall goal to reduce all track defect incidents by 50 percent by fiscal year 2019  WMATA established goals for completing each of the six track preventive maintenance initiatives within a certain time period and reported that in fiscal year 2018 it was on-track to meet or exceed those goals for four of the initiatives  For example, in implementing its “cable meggering” initiative, WMATA established a goal to inspect and replace electric cables across its entire rail system within 4 years  According to WMATA, it met its target for fiscal year 2018 by completing 25 percent of the entire system in that year  In addition to cable meggering, WMATA also met its annual targets for the switch maintenance, track bed cleaning, and stray current-testing initiatives  As for the two initiatives behind schedule, the torqueing initiative was 70 percent complete and the tamping initiative stood at 90 percent for the 2018 target (see table 2)  Officials told us they have developed various ways to improve efficiency with these initiatives  For instance, WMATA improved the productivity of its switch maintenance initiative by separating the work to inspect the switches from the follow-up repair work to grind and weld them  These activities had previously been conducted by the same team  However, WMATA faces challenges in implementing the track preventive maintenance program moving forward  WMATA officials described track preventive maintenance as a necessary operation that must be continuously performed and balanced in conjunction with regular train operations that provide service to their customers  According to WMATA officials, executing this new program requires regular refinements to ensure it continues to progress toward its desired outcomes  Among the implementation challenges identified by WMATA officials were the following: Securing Sufficient Track Time  WMATA officials told us that getting adequate time to perform track maintenance is difficult because it requires reducing the number of hours in which WMATA provides service to customers  Consequently, increased maintenance hours can result in lost revenue  Officials from the peer transit agencies we interviewed stated that the tension between conducting maintenance and providing service is common in the transit industry  According to WMATA officials, prior to SafeTrack, windows for performing track maintenance were not sufficient to complete all necessary work, partially because of this need to balance maintenance hours and service hours  To address this issue, WMATA increased its weekly overnight work hours from 33 hours to 39 hours during SafeTrack  After SafeTrack was complete, WMATA extended weekly overnight work hours again to a total of 41 hours  However, maintaining these extended overnight work hours past fiscal year 2019 requires approval from WMATA’s board of directors  As a result, the long-term viability of WMATA’s track preventive maintenance program is partially dependent on the board’s decision to balance the competing demands for service hours and maintenance time  Work Time Productivity  To maintain extended track-maintenance hours into succeeding years, it will be important for WMATA to demonstrate the new program’s productivity  According to WMATA officials, making the most productive use of the extended working hours is a challenge, but it will be necessary to justify the extended maintenance windows  WMATA officials told us that only a portion of overnight work hours yields productive maintenance time  For example, once a line ceases operations, it takes an additional hour for all trains to reach their final destination, and another hour after that to safely turn off all power running to the track and then establish a work zone  Once maintenance work is completed, additional time must be allotted for restoring power and allowing trains to move back into position  Because of these requirements, a five-hour work window may only yield two hours of productive work time (called “wrench time”)  For this reason, WMATA began tracking its wrench time at the beginning of fiscal year 2018  As of June 2018, WMATA reported that average wrench time had increased from about 2 0 hours per day in July 2017 to 2 37 hours  Resource Constraints  According to WMATA officials, having sufficient people with the necessary skills and experience to perform track maintenance work is a significant challenge  For instance, expanded maintenance windows have increased WMATA’s workforce requirements  As a result, WMATA has used contractors to assist with its stray-current testing and track bed cleaning initiatives  In another example, WMATA’s torqueing initiative is particularly resource intensive as the entire rail system contains 135 miles of “direct fixation” track, where the torqueing work is being done, and over 504,000 fasteners to check and tighten as necessary  According to WMATA officials, bolts and fasteners are torqued during their initial installment and then again 90 days afterward as part of the initial capital expenditure  After that, any subsequent torqueing is executed as part of the new track preventive maintenance program  WMATA stated that the torqueing initiative seeks to torque all 135 miles of direct fixation track annually  WMATA officials said the torqueing initiative is a mix of contractor and in-house staff, with contractors supplementing WMATA forces as needed  WMATA’s track preventive maintenance program has followed certain leading program management practices such as establishing key performance metrics and monitoring progress toward them  Leading practices recommend that organizations establish performance baselines for their programs and communicate performance metrics to key stakeholders  For instance, as previously noted, WMATA established a measureable program goal to reduce track-defect and electrical-wayside- fire incidents by 50 percent within 2 years, and WMATA also established time periods to complete its system-wide preventive maintenance initiatives  In addition, WMATA’s Rail Services Department—which manages the track preventive maintenance program—among other things, holds a monthly “RailSTAT” meeting in which the teams leading the preventive maintenance initiatives report their progress toward these goals to WMATA’s management  However, WMATA’s program does not fully align with other applicable internal-control standards or leading program-management practices  Specifically, COSO internal control standards and leading practices identified by the Project Management Institute’s The Standard for Program Management stresses the importance of identifying and assessing program risks and developing a program management plan  COSO recommends that organizations identify risks to the achievement of its objectives and analyze risks as a basis for determining how the risks should be managed  Furthermore, the risk identification is to be comprehensive  The Standard for Program Management also recommends that when identifying risks, the assessments be both qualitative and quantitative in nature  Regarding program management plans: The Standard for Program Management recommends that organizations develop program management plans that align with organizational goals and objectives  This includes aligning the program management plan with the organization’s overall strategic plan  Elements of the plan are to provide a roadmap that identifies such things as milestones and decision points to guide program activities  In developing the track preventive maintenance program, WMATA did not fully identify or quantitatively assess risks associated with the program  WMATA officials told us that in developing the track preventive maintenance program they used their professional judgment to identify track-defect and fire incidents as the most significant risks that they needed to address through the program  However, WMATA’s risk identification was not comprehensive in nature, as it only considered two technical aspects of track maintenance: electrical fires and track defects  As previously mentioned, non-electrical fires—which were not included in the scope of the program or risk assessment—did not change from fiscal year 2017 through 2018 and represent approximately 30 percent of all fires on the system over those years  Although WMATA officials told us in designing the program they reviewed track-related incident data from 2016, they did not quantitatively analyze the impact of these incidents on service or safety  In addition, WMATA did not consider broader strategic risks to its program, such as the availability of a program’s funding and stakeholders’ support for the continuation of the program  Specifically, while WMATA has identified several challenges with implementing the program—such as securing sufficient track time, demonstrating work time productivity, and overcoming resource constraints—none of these factors, or potential mitigations, were documented in a risk assessment in developing the program  WMATA has also not prepared a program management plan for the track preventive maintenance program  Although WMATA has identified program goals, officials told us that WMATA has not formally documented the overall structure of the program or how it would be implemented  Instead, the officials said the presentations they provide to WMATA’s board of directors, along with their ongoing staff and executive team meetings, regarding the track preventive maintenance program cover the relevant information needed for running the program  While providing such information to the WMATA board of directors provides some accountability for the program, these presentations do not represent a formal program management plan that links with WMATA’s strategic plan or that identifies milestones and decision points necessary to guide the program  As we previously reported, WMATA did not develop a project management plan before starting its SafeTrack work, and due to this omission and other issues, we found that WMATA lacked assurance that the approach taken with SafeTrack was the most effective way to identify and address safety issues  Furthermore, as this is the first time WMATA has implemented a track preventive maintenance program, a program management plan could help formally establish the program, provide strategic guidance for this new program by providing accountability for both internal and external stakeholders, and ensure that program goals are met  A program management plan could also provide practical benefits, such as helping ensure that WMATA’s extended overnight work hours are efficiently implemented and that sufficient resources are devoted to the program  Without the strategic direction provided by a comprehensive risk assessment and a formal program management plan, WMATA lacks a documented vision for how the track preventive maintenance program should be structured and implemented in order to meet the agency’s strategic goals and improve track safety  Specifically, without a risk assessment that uses quantitative and qualitative data to assess risks— such as data for all fires on the system and qualitative risks such as securing sufficient time for maintenance—WMATA lacks assurance that the program is comprehensively designed to address risks affecting the safety of the rail system or other risks that could hinder the program’s success  Moreover, a program management plan that draws on information from a comprehensive risk assessment would provide WMATA officials with the assurance that they are prepared to respond to current and future challenges that could threaten the long-term viability of the program  Finally, although WMATA developed the track preventive maintenance program to prevent the need for another emergency repair project like SafeTrack, without a formal program management plan, the WMATA employees charged with managing and implementing the program lack an important document to guide their decision-making to meet that objective and the agency’s overall strategic objectives  Developing a program management plan would outline the specific requirements to successfully implement the program, including necessary track time, expected productivity of program initiatives, and required resources  Furthermore, it would provide WMATA’s board of directors with confidence that the program has a clear roadmap with milestones and decision points as the board considers maintaining the extended overnight work hours necessary to implement the program  WMATA’s rail and bus systems provide nearly a million passenger trips each day, and those passengers rely on WMATA for safe and reliable public transportation in the nation’s capital and the surrounding areas  The federal, state, and local jurisdictions that fund WMATA expect WMATA to wisely use taxpayer funds to ensure the system is safe and reliable  WMATA can better meet these expectations by establishing documented policies and procedures that outline how the new capital planning process will work and the basis of investment decisions  In addition, developing measures to assess the performance of individual projects and the capital planning process would provide greater assurance to WMATA’s funding partners that its investment decisions result in a measurable improvement in operating performance, reliability, or other metrics  Furthermore, WMATA’s recent efforts to establish an Enterprise Asset Management Program, once finalized, could help WMATA develop a more complete inventory of its assets and collect critical information on their condition—both of which are consistent with sound capital planning  However, without a plan that provides specific details for obtaining this information, WMATA will continue to lack the critical asset information necessary to make lasting improvements in its capital planning process and make sound capital-investment decisions  Similarly, track preventive maintenance plays a critical role as WMATA works to reduce the track defects and fires that have endangered safety and service reliability  WMATA could better demonstrate the direction of the track preventive maintenance program and how it can improve track safety by more comprehensively assessing the technical and broader risks facing the program and by developing a formal plan that provides greater assurance WMATA is prepared to address challenges that could threaten the long-term viability of the program  Both actions would help WMATA better focus the program on critical maintenance needs and demonstrate its value to WMATA’s board of directors and other stakeholders as WMATA endeavors to provide safe, reliable, and quality service to its riders  We are making the following five recommendations to WMATA  The General Manager of WMATA should establish documented policies and procedures for the new capital planning process  These policies and procedures should include methodologies for ranking and selecting capital projects for funding in WMATA’s fiscal year 2020 capital budget and fiscal years 2020-2025 Capital Improvement Program and for future planning cycles  (Recommendation 1) The General Manager of WMATA should develop performance measures to be used for assessing capital investments and the capital planning process to determine if the investments and planning process have achieved their planned goals and objectives  (Recommendation 2) The General Manager of WMATA should develop a plan for obtaining complete information regarding WMATA’s asset inventory and physical condition assessments, including assets related to track and structures  (Recommendation 3) The General Manager of WMATA should conduct a comprehensive risk assessment of the track preventive maintenance program that includes both a quantitative and qualitative assessment of relevant program risks  In addition to considering technical program risks, WMATA should also consider broader program risks, such as the availability of funding for the program and stakeholders’ support  (Recommendation 4) The General Manager of WMATA should prepare a formal program management plan for the track preventive maintenance program that aligns with WMATA’s strategic plan, addresses how the program is linked to overall strategic goals and objectives, and includes program milestones and decision points  (Recommendation 5) We provided a draft of this report to WMATA and the Department of Transportation for review and comment  WMATA provided written comments, which are reprinted in appendix II, and technical comments, which we incorporated as appropriate in the report  The Department of Transportation provided technical comments, which we incorporated as appropriate  WMATA concurred in part, or with the intent of four of the recommendations, and disagreed with a fifth  Specifically, regarding the first recommendation, which is that WMATA establish documented policies and procedures for the new capital planning process, and that the policies and procedures include methodologies for ranking and selecting capital projects for the fiscal year 2020 capital budget and fiscal year 2020—2025 capital-improvement program  WMATA stated that it agreed with the recommendation, in part  WMATA said it will continue its efforts to finalize and document policies and procedures for the capital planning process for fiscal year 2021 and beyond  WMATA noted that it already has in place numerous planning tools, such as the 2016 Capital Needs Inventory assessment, which helped inform the fiscal year 2020 capital planning process  According to WMATA, it is currently reviewing policies, procedures, training materials, and other documents for the fiscal year 2020 planning process, and those documents will be updated and formalized through final documentation in fiscal year 2021  WMATA noted that it anticipates that many of the elements we recommend regarding the capital planning process will be part of the process documented in fiscal year 2021  For example, WMATA expects that additional automation, decision-making, governance, and reporting capabilities, will be part of the process that will be documented for fiscal year 2021  However, while WMATA has tools available to inform the capital planning process, it has not prepared documented policies and procedures for this process in fiscal year 2020  As we reported, without documented policies and procedures, including those for ranking and selecting projects for the fiscal year 2020 capital budget, WMATA’s stakeholders do not have reasonable assurance that capital investment decisions are made using a sound and transparent process  Taking action now to establish methodologies for ranking and selecting projects for the fiscal year 2020 capital budget would provide WMATA with an opportunity to improve upon those methodologies for the fiscal year 2021 capital planning process to better ensure investments are directed to WMATA’s highest priority needs  As such, we continue to believe this recommendation is valid and that WMATA should fully implement it  Regarding the second recommendation that WMATA develop performance measures for assessing capital investments and the capital planning process, WMATA stated that it agreed with the intent of the recommendation  WMATA also stated that it has developed such measures through compliance with federal requirements, including the FTA’s performance-based planning requirements and the requirement under MAP-21 that tier I transit providers, such as WMATA, establish state-of-good-repair targets that are linked to the capital program  WMATA noted these targets are set forth in its Transit Asset Management Plan  Although WMATA’s October 2018 Transit Asset Management plan includes some broad performance measures and targets for the state-of-good-repair for its various asset classes, as we reported, WMATA has not developed performance measures to assess individual capital projects or the capital planning process itself, as suggested by leading practices in the Executive Guide  As discussed in the report, such measures are important to determine if capital investments have achieved their expected benefits and if they have achieved organizational goals  Leading practices also indicate that by using a mixture of measures managers can assess performance based on a comprehensive view of the needs and objectives of an organization  These needs and objectives can go beyond just the state-of-good-repair to include such things as measures for assessing projects that would improve service reliability, expand capacity, or achieve financial objectives  We continue to believe that fully implementing this recommendation would help ensure that capital investments meet their intended outcomes and that the capital planning process helps WMATA achieve its strategic goals and objectives  Regarding the third recommendation that WMATA develop a plan for obtaining complete information about asset inventories and condition assessments, WMATA stated that it agreed with the intent of the recommendation and that its 2018 Transit Asset Management Plan outlines plans for continuing its asset inventory update  WMATA also said that it is working to ensure it has a complete asset inventory that addresses legacy information and that includes accurate, up-to-date condition assessments  As we reported, the Enterprise Asset Management Program—the program that WMATA told us it plans to use to continue development of asset inventories and condition assessments—includes some elements of good project management, but it also lacks an established plan for collecting asset inventory and condition assessment information  Without a plan to obtain asset inventory and condition assessment information WMATA will continue to lack critical information needed for good capital planning and sound investment decision-making  Thus, we continue to believe that this recommendation is valid and that WMATA should fully implement it  Regarding the fourth recommendation that WMATA conduct a comprehensive risk assessment of the track preventive maintenance program that includes both quantitative and qualitative assessment of relevant program risks, WMATA stated that it agreed with the intent of the recommendation and is putting in place a new process that will address it  Specifically, WMATA stated it is in the process of developing a new Reliability Centered Maintenance process that will include a comprehensive risk assessment of track infrastructure that includes consideration of broader risks such as costs, funding, and track access  According to WMATA, the new process is an engineering framework that will define the maintenance regimen, including preventive maintenance, and improve safety, reliability, and cost-effectiveness  During our review, WMATA officials did not discuss the Reliability Centered Maintenance process in detail or provide documentation that allowed us to evaluate how this process might interface with the current track preventive maintenance program  As a result, we were not able to evaluate how it might address identification and assessment of risks associated with track preventive maintenance  As we reported, going forward track preventive maintenance will play a critical role as WMATA works to reduce track defects and fires  We will review WMATA’s actions to conduct a comprehensive risk assessment as part of our routine recommendation follow-up process  Regarding the fifth recommendation that WMATA prepare a formal program management plan for the track preventive maintenance program, WMATA stated that it disagreed with the recommendation  WMATA noted that specific technical details of the track preventive maintenance program are evolving as it better understands the most effective maintenance regime through implementation of the Reliability Centered Maintenance process  WMATA stated that it believes the framework of Reliability Centered Maintenance is better suited to the ongoing mission of physical asset management than traditional project and program management tools  According to WMATA, the purpose of Reliability Centered Maintenance is to ensure that all efforts are focused on the safety, reliability, and cost-effectiveness of assets through their lifecycle, which is more relevant and applicable to WMATA’s strategic plan than any individual preventive maintenance program  As stated above, WMATA did not provide details about Reliability Centered Maintenance during our review so we are not able to evaluate this process in relation to the track preventive maintenance program  We will review WMATA’s actions related to implementation of the Reliability Centered Maintenance process as part of our routine recommendation follow-up process  We continue to believe this recommendation is valid and that WMATA should fully implement it  We will send copies of this report to appropriate congressional committees, the Secretary of Transportation, the Administrator of the Federal Transit Administration, and the General Manager of WMATA  In addition, we will make copies available to others upon request, and the report will be available at no charge on the GAO website at http://www gao gov  If you or your staff have any questions about this report, please contact me at (202) 512-2834 or goldsteinm@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 key contributions to this report are listed in appendix III  This report examines: (1) How WMATA expended its capital funding from fiscal years 2011 through 2017; (2) How WMATA’s new capital planning process addresses weaknesses it identified in the previous process; and (3) WMATA’s progress toward its track preventive maintenance goals and how the program aligns with leading program management practices  For each of our objectives we reviewed pertinent federal statutes and regulations as well as WMATA and FTA policies and documents  We also selected a non-generalizable sample of five similar U S  transit agencies based on similarity to WMATA in transit route mileage, system use, capital spending, system age, and rail fleet age  We also factored geographical diversity into our selection process  We then interviewed the officials from these selected transit agencies using a standard set of questions to learn how they utilize their capital funds, conduct capital planning, and oversee maintenance; and then we compared their processes to WMATA  Transit route mileage, system use, capital spending, and rail fleet age were measured using data from FTA’s National Transit Database  We measured system age according to data available within the American Public Transportation Association’s 2017 Public Transportation Fact Book, and geographical diversity was determined through data available from the U S  Census Bureau  The transit agencies we selected were: (1) Bay Area Rapid Transit, Oakland, California; (2) Chicago Transit Authority, Chicago, Illinois; (3) Massachusetts Bay Transportation Authority, Boston, Massachusetts; (4) Metropolitan Atlanta Rapid Transit Authority, Atlanta, Georgia; and (5) Southeastern Pennsylvania Transportation Authority, Philadelphia, Pennsylvania  To assess WMATA’s capital spending from 2011 through 2017, we interviewed knowledgeable officials from WMATA and FTA and also reviewed WMATA annual budgets, fourth-quarter and year-end financial reports, budget reconciliation reports, comprehensive annual financial reports, and FTA grant awards  We selected fiscal year 2011 because it was the first year in which WMATA received federal funding authorized by the Passenger Rail Investment and Improvement Act of 2008 (PRIIA), and we selected fiscal year 2017 because it was the most recent year that capital expenditure data were available at the time of our review  By analyzing this information we determined that the following sources provided the most comprehensive and reliable available data on each of the following topics for our report (see table 3): We collected the aforementioned data, analyzed them to identify errors or other anomalies, and interviewed officials to determine how the data are compiled and checked for accuracy  We determined that these data had some limitations, as an external audit report of WMATA financial information for fiscal year 2016 noted a material weakness with WMATA’s process for accounting acquisition costs of capital assets  Specifically, there were inconsistencies between WMATA’s general ledger and sub- ledger, which are used to record acquisition costs, depreciation, and other financial information related to capital assets  As a result, additional steps were required to reconcile the differences between the two sources and could have resulted in a material error  However, after interviewing WMATA officials about the weakness and assessing the available financial information, we determined that the data we used were sufficiently reliable for our purpose of showing general trends of capital expenditures  Our analysis sought to depict how WMATA allocates and expends funds according to major asset categories within its capital-improvement plan  However, these asset categories only remained consistent from 2011 through 2015, and were revised during 2016 and 2017  However, we determined that each asset category consisted of Capital Improvement Projects that were each assigned a number  These projects and their corresponding numbers remained in existence from fiscal year 2011 through 2017, even though the asset categories were updated in fiscal year 2016  Tracking by Capital Improvement Project number provided a means to report consistently through that time period  Therefore, we used the asset categories from fiscal years 2011 through 2015 as our base reporting categories  These categories consisted of: (1) Vehicles/Vehicle Parts, (2) Rail System Infrastructure Rehabilitation, (3) Maintenance Facilities, (4) Systems and Technology, (5) Track and Structures, (6) Passenger Facilities, (7) Maintenance Equipment, (8) Other Facilities, and (9) Project Management and Support  We consolidated WMATA’s nine asset categories into five asset categories in order to represent broader categories of investment: Rail and Bus Vehicle Fleet (Vehicle/Vehicle Parts), Fixed Rail Infrastructure (Rail System Infrastructure and Track and Structures), Maintenance Facilities and Equipment (Maintenance Facilities and Maintenance Equipment), Passenger and Other Facilities (Passenger Facilities and Other Facilities), and Business Systems and Project Management Support (Systems and Technology and Project Management and Support)  We then reviewed WMATA’s fiscal year 2016 Fourth Quarter Report, fiscal year 2017 Fourth Quarter Report, and fiscal year 2017 Budget Reconciliation Report to match each project number from those two years to their corresponding category from fiscal year 2011 through 2015  To assess WMATA’s new capital planning process and how it addresses weaknesses WMATA identified in the previous process, we interviewed WMATA officials about their capital planning process and reviewed WMATA documentation related to the capital planning process  This included Capital Needs Inventories, WMATA’s policy for preparation of the 2010 and 2016 Capital Needs Inventories, annual capital budgets—to include capital improvement programs, and guidance documents issued by WMATA related to submitting projects for inclusion in the annual capital budget  We also reviewed the fiscal year 2018 business plan for WMATA’s Capital Planning and Program Management Department  We also interviewed officials from the Metropolitan Washington Council of Governments, the American Public Transportation Association, and FTA to discuss WMATA’s capital planning and budgeting processes  Furthermore, we compared WMATA’s capital planning practices to leading practices identified in GAO’s Executive Guide  The Executive Guide was used since it identifies leading practices for capital decision- making that are applicable to a wide variety of organizations, both public and private  For example, the Executive Guide developed leading capital planning practices by (1) identifying government and private sector organizations recognized for outstanding capital decision-making practices and (2) identifying and describing the leading capital decision- making practices implemented by these organizations  To identify leading practices for capital planning, we also reviewed Transit Cooperative Research Program Report 157  This report developed a framework for transit agencies to use when prioritizing the rehabilitation and replacement of capital assets and discusses leading practices in how to do this  We also identified project management principles from the Project Management Institute, Inc  Finally, we discussed capital planning with the peer transit agencies and prepared a summary of various aspects of capital planning in these agencies  To examine progress toward goals in WMATA’s track preventive maintenance program and how the program compares with leading program management practices, we reviewed WMATA documentation about the program, interviewed WMATA officials, and analyzed track- defect data and electrical-wayside-fire data provided by WMATA for fiscal years 2016 through 2018—which were the only years detailed track defect and electrical fire incident data were available  In order to determine whether the data provided were sufficiently reliable, we checked the data for errors, conducted interviews with knowledgeable officials to learn their procedures for collecting and analyzing the data, and performed independent tests that included verifying WMATA’s final tally of track defect and fire incidents and verifying there were no extended periods of time where data was missing  We also provided a set of data reliability questions to determine whether procedures were sufficient  After performing these steps we determined that the data were sufficiently reliable for the purposes of our report  In our interviews with WMATA, officials also described what goals they had created for the track preventive maintenance program, their progress in meeting those goals, and provided documentation to demonstrate their progress, which we reviewed  We also interviewed officials from the American Public Transportation Association and the American Railway Engineering and Maintenance-of-Way Association about best maintenance practices in the transit industry  We then compared WMATA’s track preventive maintenance program to leading program management practices identified by the Project Management Institute, Inc ’s The Standard for Program Management and internal control standards published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)  The Project Management Institute’s, standards are utilized worldwide and provide guidance on how to manage various aspects of projects, programs, and portfolios  In particular, The Standard for Program Management provides guidance that is generally recognized to support good program-management practices for most programs, most of the time  We conducted our work from November 2017 to January 2019 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  In addition to the contact named above, Matt Barranca (Assistant Director), Richard Jorgenson (Analyst in Charge), Melissa Bodeau, Lacey Coppage, Cory Gerlach, Erin Guinn-Villareal, Kirsten Lauber, Joshua Ormond, and Patrick Tierney made significant contributions to this report 

ground_truth: Developing independently capable ANDSF is a key component of U.S. and coalition efforts to create sustainable security and stability in Afghanistan under the North Atlantic Treaty Organization (NATO)-led Resolute Support mission. The United States is the largest contributor of funding and personnel to Resolute Support, providing and maintaining ANDSF equipment, along with training, advising, and assistance to help the ANDSF effectively use and sustain the equipment in the future. House Report 114-537 included a provision for GAO to review the ANDSF's capability and capacity to operate and sustain U.S.-purchased weapon systems and equipment. This report addresses (1) what has been reported about ANDSF capabilities and capability gaps and (2) the extent to which DOD has information about the ANDSF's ability to operate and maintain U.S.-purchased equipment. To conduct this work, GAO analyzed DOD and NATO reports and documents, examined three critical equipment types, and interviewed DOD officials in the United States and Afghanistan. This is a public version of a sensitive report issued in September 2018. Information that DOD deemed sensitive has been omitted. Since the Resolute Support mission began in 2015, the Afghan National Defense and Security Forces (ANDSF) have improved some fundamental capabilities, such as high-level operational planning, but continue to rely on U.S. and coalition support to fill several key capability gaps, according to Department of Defense (DOD) reporting. DOD has initiatives to address some ANDSF capability gaps, such as a country-wide vehicle maintenance and training effort, but DOD reports it does not expect the ANDSF to develop and sustain independent capabilities in some areas, such as logistics, for several years. While DOD has firsthand information on the abilities of the Afghan Air Force and Special Security Forces to operate and maintain U.S.-purchased equipment, it has little reliable information on the equipment proficiency of conventional ANDSF units. U.S. and coalition advisors are embedded at the tactical level for the Air Force and Special Security Forces, enabling DOD to directly assess those forces' abilities. However, the advisors have little direct contact with conventional ANDSF units on the front lines. As a result, DOD relies on those units' self-assessments of tactical abilities, which, according to DOD officials, can be unreliable. GAO's analysis of three critical equipment types illustrated the varying degrees of DOD's information (see figure above). For example, DOD provided detailed information about the Air Force's ability to operate and maintain MD-530 helicopters and the Special Security Forces' ability to operate and maintain Mobile Strike Force Vehicles; however, DOD had limited information about how conventional forces operate and maintain radios and Mobile Strike Force Vehicles. DOD's lack of reliable information on conventional forces' equipment operations and maintenance abilities adds to the uncertainty and risk in assessing the progress of DOD efforts in Afghanistan. GAO recommends that DOD develop options for collecting reliable information on conventional ANDSF units' ability to operate and maintain U.S.-purchased equipment. DOD concurred with this recommendation.