a

GAO

United States Government Accountability Office

Report to the Chairman, Subcommittee 

on Interior and Related Agencies, 

Committee on Appropriations, U.S. 

Senate

February 2006 INDIAN IRRIGATION 

PROJECTS

Numerous Issues 

Need to Be Addressed 

to Improve Project 

Management and 

Financial 

Sustainability

GAO-06-314
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

February 2006

INDIAN IRRIGATION PROJECTS 

Numerous Issues Need to Be Addressed 

to Improve Project Management and 

Financial Sustainability 

Highlights of GAO-06-314, a report to the 

Chairman, Subcommittee on Interior and 

Related Agencies, Committee on

Appropriations, U.S. Senate 

The Department of the Interior’s 

Bureau of Indian Affairs (BIA) 

manages 16 irrigation projects on

Indian reservations in the western 

United States. These projects, 

which were generally constructed 

in the late 1800s and early 1900s,

include water storage facilities and 

delivery structures for agricultural

purposes. Serious concerns have 

arisen about their maintenance and

management. 

GAO was asked to examine (1) 

BIA’s estimated deferred 

maintenance cost for its 16 

irrigation projects, (2) what 

shortcomings, if any, exist in BIA’s 

current management of its 

irrigation projects, and (3) any

issues that need to be addressed to 

determine the long-term direction

of BIA’s irrigation program.

What GAO Recommends

GAO recommends that BIA (1) 

provide the necessary level of 

technical support to project 

managers, (2) require project

managers to meet at least twice 

annually with water users, and (3) 

conduct studies to determine the

financial sustainability of the

projects. 

Although we requested comments 

from the Department of the Interior

on our findings and

recommendations, none were

provided in time to be included as 

part of this report. 

BIA estimated the cost for deferred maintenance at its 16 irrigation projects 

at about $850 million for 2005, although the agency is in the midst of refining 

this estimate. BIA acknowledges that this estimate is a work in progress, in 

part, because some projects incorrectly counted new construction items as 

deferred maintenance. To further refine its estimate, BIA plans to hire

engineering and irrigation experts to conduct thorough condition 

assessments of all 16 irrigation projects to correctly identify deferred 

maintenance needs and costs. 

BIA’s management of some of its irrigation projects has serious 

shortcomings that undermine effective decisionmaking about project 

operations and maintenance. First, under BIA’s organizational structure, 

officials with the authority to oversee irrigation project managers generally 

lack the technical expertise needed to do so effectively, while the staff that 

have the expertise lack the necessary authority. Second, despite federal 

regulations that require BIA to consult with project stakeholders in setting 

project priorities, BIA has not consistently provided project stakeholders 

with the necessary information or opportunities to participate in project 

decisionmaking. 

The long-term direction of BIA’s irrigation program depends on the 

resolution of several larger issues. Of most importance, BIA does not know 

to what extent its irrigation projects are capable of financially sustaining 

themselves, which hinders its ability to address long-standing concerns 

regarding inadequate funding. Information on financial sustainability, along 

with accurate deferred maintenance information, are two critical pieces of 

information that are needed to have a debate on the long-term direction of 

BIA’s irrigation program. Once this information is available, the Congress 

and interested parties will be able to address how the deferred maintenance 

will be funded and whether entities other than BIA could more appropriately 

manage some or all of the projects. 

Deferred Maintenance at the Crow Irrigation Project (March 2005) 

Source: GAO.

Abandoned Car in Canal Crumbling Concrete Structure

www.gao.gov/cgi-bin/getrpt?GAO-06-314.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robin M. 

Nazzaro at (202)512-3841 or 

nazzaror@gao.gov. 
Page i GAO-06-314 Indian Irrigation Projects

Contents

Letter 1

Results in Brief 3

Background 6

BIA Estimates the Cost of Deferred Maintenance at about $850 

Million, but the Estimate Is Being Refined 13

Shortcomings in BIA’s Management of Some Irrigation Projects 

Undermine Effective Decisionmaking 20

Long-Term Direction of BIA’s Irrigation Program Depends on 

Resolution of a Number of Larger Issues 25

Conclusions 30

Recommendations for Executive Action 31

Agency Comments and Our Evaluation 32

Appendixes

Appendix I: Objectives, Scope, and Methodology 34

Appendix II: Profiles of the Nine Irrigation Projects GAO Visited 36

Blackfeet Irrigation Project 36

Colorado River Irrigation Project 37

Crow Irrigation Project 39

Fort Belknap Irrigation Project 41

Pine River Irrigation Project 42

San Carlos Indian Works Irrigation Project (Pima) 44

San Carlos Joint Works Irrigation Project (Coolidge) 45

Wapato Irrigation Project 47

Wind River Irrigation Project 48

Appendix III: GAO Contact and Staff Acknowledgments 51

Tables Table 1: Tribe(s) Served and Year Authorized for BIA’s 16 Irrigation 

Projects 9

Table 2: Land Ownership for BIA’s 16 Irrigation Projects 11

Figures Figure 1: Location of BIA’s 16 Irrigation Projects by Region 8

Figure 2: Example of an Irrigation Project Operated by BIA 10

Figure 3: Examples of Deferred Maintenance on BIA’s Irrigation 

Projects (c. 2005) 15

Figure 4: Fiscal Year 2005 Cost Estimate of Deferred Maintenance 

by Irrigation Project 17
Contents

Page ii GAO-06-314 Indian Irrigation Projects

Figure 5: Fiscal Year 2005 Cost Estimate of Deferred Maintenance 

by Type 19

Figure 6: Misalignment of Expertise and Authority for a Typical 

BIA Irrigation Project 21

Figure 7: Opportunities for Water Users to Meet with BIA Varies by 

Project 24

Figure 8: Pictures of the Blackfeet Irrigation Project (July 2005) 36

Figure 9: Pictures of the Colorado River Irrigation Project (June 

2005) 38

Figure 10: Pictures of the Crow Irrigation Project (March 2005) 39

Figure 11: Pictures of the Fort Belknap Irrigation Project (July 

2005) 41

Figure 12: Pictures of the Pine River Irrigation Project (August

2005) 43

Figure 13: Pictures of the San Carlos Indian Works Irrigation Project 

(June 2005) 44

Figure 14: Pictures of the San Carlos Joint Works Irrigation Project 

(June 2005) 46

Figure 15: Pictures of the Wapato Irrigation Project (April 2005) 47

Figure 16: Pictures of the Wind River Irrigation Project (July 

2005) 49

Abbreviations

BIA Bureau of Indian Affairs

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Page 1 GAO-06-314 Indian Irrigation Projects

United States Government Accountability Office

Washington, D.C. 20548

A

February 24, 2006 Letr

The Honorable Conrad Burns

Chairman 

Subcommittee on Interior and Related Agencies

Committee on Appropriations

United States Senate

The scarcity of water in the western part of the United States makes 

irrigation critical to the continued success of agricultural activities. There 

are over 100 irrigation works on Indian reservations primarily across the 

western United States. The Department of the Interior’s Bureau of Indian 

Affairs (BIA), which is responsible for providing social and economic 

services to Indians, as well as managing land and natural resources held in 

trust by the United States for Indians, currently refers to these irrigation 

works as either “irrigation projects” or “irrigation systems.” There are 16 

irrigation projects where water users are charged for the operation and 

maintenance of the irrigation works by BIA. The remaining systems, on 

which BIA does not charge an annual operation and maintenance fee, are 

operated and maintained through a collaborative effort which generally 

involves other BIA programs, tribes, and water users. 

The 16 irrigation projects, which were generally initiated in the late 1800s 

and early 1900s by the Department of the Interior, include water storage 

facilities and delivery structures for agricultural purposes. The projects 

were constructed as part of the federal government’s Indian assimilation 

policy to foster agricultural opportunities and provide economic benefits to 

Indian communities. Over time, non-Indians began buying or leasing the 

land served by the projects for agricultural purposes, and project 

stakeholders evolved from Indian water users and the tribes within the 

reservations to include non-Indian water users as well. Many of the water 

users today are non-Indian.

A number of prior reports on BIA’s irrigation projects have documented 

that the annual operations and maintenance fees have historically been set 

too low to cover the full cost of running the projects.1

 In addition, problems 

1

U.S. Department of the Interior, Office of the Inspector General, Indian Irrigation 

Projects, Bureau of Indian Affairs, 96-I-641, (Washington D.C.: March 1996); U.S. 

Department of the Interior, Office of the Inspector General, Operations and Maintenance 

Assessments of Indian Irrigation Projects, Bureau of Indian Affairs, W-IA-BIA-12-86, 

(Washington D.C.: Feb. 1988).
Page 2 GAO-06-314 Indian Irrigation Projects

have been reported with collecting the fees that have been assessed. 

Because of insufficient funding, project maintenance has been consistently 

postponed, resulting in an extensive and costly list of deferred 

maintenance items. The kinds of such deferred maintenance range from 

repairing or replacing dilapidated irrigation structures to clearing weeds 

from irrigation ditches. In addition to the deferred maintenance, water 

users have expressed concern that BIA has been unresponsive in 

addressing the projects’ ongoing operations and maintenance needs. 

The 16 irrigation projects are located in 4 of BIA’s 12 regions—Rocky 

Mountain, Northwest, Southwest, and Western. Management of these 

projects is decentralized, with local or regional BIA offices responsible for 

project management. Fourteen projects are overseen by local BIA agency 

superintendents, and the 2 largest projects are overseen directly by 

regional directors. The agency superintendents that oversee projects report 

to their respective regional director. BIA’s irrigation and engineering 

experts, who provide technical assistance to the projects, are located in 

each region as well as in the BIA central Irrigation, Power, and Safety of 

Dams offices (central irrigation offices) located in Washington, D.C., and 

other BIA locations in the western United States. The regional irrigation 

staff and central irrigation office staff do not have line authority over the 

projects.

Federal regulations specify that in making judgments about the work and 

actions necessary for the proper operation, maintenance and 

administration of the projects, the official in charge “... consults with water 

users and their representatives, and with tribal council representatives, and 

seeks advice on matters of program priorities and operational policies.”2

Furthermore, the regulations state that “close cooperation between the 

Indian tribal councils, the project waters users and the Officer-In-Charge 

[of the project] is necessary and will be to the advantage of the entire 

project.”3

 BIA’s irrigation manual and handbook also contain language 

directing project staff to involve project stakeholders in the management of 

the projects.

In response to ongoing concerns about maintenance and management of 

the irrigation projects, in December 2003 Senator Conrad Burns and 

2

25 C.F.R. § 171.1(c).

3

25 C.F.R. § 171.1(d).
Page 3 GAO-06-314 Indian Irrigation Projects

Congressman Dennis Rehberg, both of Montana, sponsored a town hall 

meeting with local water users and BIA officials to discuss problems at 

BIA’s irrigation projects. In this context, we were asked to examine (1) 

BIA’s estimated deferred maintenance cost for its 16 irrigation projects; (2) 

what shortcomings, if any, exist in BIA’s current management of its 

irrigation projects; and (3) any issues that need to be addressed to 

determine the long-term direction of BIA’s irrigation program. 

To address the objectives of this report, we collected documentation on 

BIA’s 16 irrigation projects from officials in BIA’s central irrigation office, 

and we visited and collected information from each of BIA’s four regional 

offices that oversee the 16 irrigation projects. We also visited 9 of the 16 

projects, where we collected project-specific information from BIA 

officials and project stakeholders. We also met with and collected 

documentation from the Department of the Interior’s Bureau of 

Reclamation, the primary agency responsible for irrigation management, 

for comparative purposes. Specifically, to examine estimated deferred 

maintenance costs, we reviewed BIA’s lists of deferred maintenance items 

and cost estimates, and the methodology BIA used to develop these lists 

and estimates. We concluded that these data were sufficiently reliable for 

the purposes of this report based on a review of relevant controls, 

reliability tests, and interviews with agency officials about the collection 

and management of the data. We did not develop our own estimate of 

deferred maintenance. To determine what, if any, management 

shortcomings exist, we reviewed relevant federal regulations and agency 

guidance, and analyzed BIA-wide and project-specific management 

protocols and systems for the 9 projects we visited. Finally, to determine 

any issues needing to be addressed to determine the long-term direction of 

the projects, we reviewed prior studies on BIA’s irrigation program and we 

discussed the long-term direction of the program with BIA irrigation 

officials and project stakeholders. A more detailed description of our 

objectives, scope and methodology can be found in appendix I. We 

performed our work between March 2005 and February 2006 in accordance 

with generally accepted government auditing standards.

Results in Brief BIA has estimated the cost for deferred maintenance at its 16 irrigation 

projects at about $850 million for 2005, although the agency is in the midst 

of refining this estimate. BIA defines deferred maintenance as upkeep, such 

as removing weeds from irrigation ditches or repairing irrigation 

structures, that is postponed until some future time. As part of its ongoing 

strategy to develop a cost figure for the projects’ total deferred 
Page 4 GAO-06-314 Indian Irrigation Projects

maintenance, BIA had initially estimated this cost at approximately $1.2 

billion in fiscal year 2004. This estimate was based, in part, on preliminary 

condition assessments of structures and equipment at each of the 16 

irrigation projects using a scale of good, fair, poor, critical, and abandoned. 

The assessment of the structures consisted of visual inspections generally 

conducted by nonengineers. BIA acknowledged that the 2004 estimate 

would need revision largely for three reasons: the individuals who 

conducted the assessments did not have irrigation or engineering 

expertise, not all projects used the same methodology to develop their 

deferred maintenance estimates, and some projects incorrectly counted 

new construction items as deferred maintenance. To improve its estimate 

in 2005, BIA implemented a facilities management system designed to help 

projects track and continuously update deferred maintenance information. 

BIA technical experts from the central irrigation office conducted training 

for BIA irrigation projects on how to use this system, as well as how to 

correctly define deferred maintenance. Projects used this system to revise 

their list of deferred maintenance items and associated cost estimates in 

fiscal year 2005, resulting in a lower total deferred maintenance estimate of 

about $850 million. However, some projects continued to classify items as 

deferred maintenance when they were actually new construction, and 

some provided BIA with incomplete information. To further refine the cost 

estimate, BIA plans to hire experts in engineering and irrigation to conduct 

thorough condition assessments of all 16 irrigation projects every 5 years to 

identify deferred maintenance needs and costs. The first such assessment 

was completed in July 2005, with all 16 assessments expected to be 

completed by 2010.

BIA’s management of some of its irrigation projects has serious 

shortcomings that undermine effective decisionmaking about project 

operations and maintenance. First, under BIA’s organizational structure, in 

many cases, officials with the authority to oversee project managers’ 

decisionmaking lack the technical expertise needed to do so effectively, 

while the staff who do have the expertise lack the necessary authority. The 

BIA regional directors, agency superintendents and deputy 

superintendents that oversee the projects do not generally have 

engineering or irrigation expertise and they rely heavily on the project 

managers to run the projects. However, this process breaks down when the 

project managers themselves do not have the expertise required for the 

position—that is, in cases in which BIA has had difficulty filling project 

manager vacancies and has, as a result, hired less qualified people. For 

example, at the Crow project in 2002, a project manager with insufficient 

expertise decided to repair a minor leak in a key water delivery structure 
Page 5 GAO-06-314 Indian Irrigation Projects

by dismantling it and replacing it with a different type of structure. The new 

structure was subsequently deemed inadequate by BIA’s irrigation experts, 

and the required reconstruction delayed water delivery by about a month. 

Furthermore, the BIA staff with such expertise—regional irrigation 

engineers and central irrigation office staff—have no authority over the 16 

projects. A second serious management shortcoming involves the extent to 

which some projects involve stakeholders in decisionmaking. Despite 

federal regulations that require BIA to consult with project stakeholders in 

setting project priorities, BIA has not consistently provided the information 

or opportunities necessary for stakeholders—both Indian and non-Indian 

water users—to participate in decisionmaking about project operations 

and maintenance. For example, the Wapato Irrigation Project shares little 

information on its spending with stakeholders, and the Pine River Irrigation 

Project does not meet with its non-tribal stakeholders, limiting 

stakeholders’ ability to have an impact on project decisions and BIA’s 

ability to benefit from this input. 

The long-term direction of BIA’s irrigation program depends on the 

resolution of several larger issues. Of most importance, BIA does not know 

to what extent its irrigation projects are capable of financially sustaining 

themselves, which hinders its ability to address long-standing concerns 

regarding inadequate funding. The projects were constructed without 

consideration for whether they could generate adequate income to be selfsupporting, yet since the 1960s many have been considered generally selfsupporting through fees paid by water users. The future of BIA’s irrigation 

program also depends on the resolution of how the deferred maintenance 

will be funded. BIA currently has no plan for how it will obtain funding to 

fix the deferred maintenance items. Regardless of the precise cost estimate 

for total deferred maintenance, funding deferred maintenance costs in the 

hundreds of millions of dollars will be a significant challenge in times of 

tight budgets and competing priorities. In the interim, the Congress has 

appropriated approximately $7.5 million for some of BIA’s irrigation 

projects for fiscal year 2006. Finally, it might be more appropriate for other 

entities, including other federal agencies, tribes, and water users, to 

manage some or all of the projects. Given that BIA must balance irrigation 

management with its many other missions in support of Indian 

communities, such as providing education and law enforcement, it may be 

beneficial to consider whether others for whom irrigation is more of a 

priority or an area of expertise could better manage some of the projects. 

Successful management of the projects by other groups, however, would 

depend on the characteristics of each project and its stakeholders. For 

example, turning over projects to tribes may be better suited to projects 
Page 6 GAO-06-314 Indian Irrigation Projects

where most of the water users are Indian, whereas turning over projects to 

water users would be better suited to projects where water users share 

similar interests and have a desire to organize into an irrigation district or 

association. 

To improve the ongoing day-to-day management of the projects in the 

short-term, we are recommending that the Secretary of the Interior direct 

the Assistant Secretary for Indian Affairs to provide the necessary level of 

technical support for project managers who have less than the desired level 

of engineering qualifications and to adequately involve project 

stakeholders in the management of the projects. To address the long-term 

financial sustainability of the projects, we are recommending that the 

Secretary direct the Assistant Secretary for Indian Affairs to conduct 

studies to determine the extent to which projects are capable of sustaining 

themselves. Information on financial sustainability, along with accurate 

deferred maintenance information, are two critical pieces of information 

that are needed to have a debate on the long-term direction of BIA’s 

irrigation program. Once this information is available, the Congress and 

interested parties will be able to address how the deferred maintenance 

will be funded and whether entities other than BIA could more 

appropriately manage some or all of the projects. Since how to fund the 

deferred maintenance and who should manage the projects are future 

policy issues for the Congress to decide in collaboration with all interested 

parties, we are not making any specific recommendations to address them. 

Although we requested comments from the Department of the Interior on 

our findings and recommendations, none were provided in time to be 

included as part of this report.

Background BIA’s irrigation program was initiated in the late 1800s, as part of the 

federal government’s Indian assimilation policy, and it was originally 

designed to provide economic development opportunities for Indians 

through agriculture. The Act of July 4, 1884, provided the Secretary of the 

Interior $50,000 for the general development of irrigation on Indian lands.4

Over the years, the Congress continued to pass additional legislation 

authorizing and funding irrigation facilities on Indian lands.

4

Act of July 4, 1884, 23 Stat. 76, 94 (1884).
Page 7 GAO-06-314 Indian Irrigation Projects

BIA’s irrigation program includes over 100 “irrigation systems” and 

“irrigation projects” that irrigate approximately 1 million acres primarily 

across the West. BIA’s irrigation systems are non revenue-generating 

facilities that are primarily used for subsistence gardening and they are 

operated and maintained through a collaborative effort which generally 

involves other BIA programs, tribes, and water users. In contrast, BIA’s 16 

irrigation projects charge their water users an annual operations and 

maintenance fee to fund the cost of operating and maintaining the project.5

Most of BIA’s irrigation projects are considered self-supporting through 

these operations and maintenance fees. The 16 irrigation projects are 

located on Indian reservations across the agency’s Rocky Mountain, 

Northwest, Southwest, and Western regions (see fig. 1).

5

See 70 Fed. Reg. 57889 (Oct. 4, 2005) for the 2005 operations and maintenance fees for the 

projects as well as the proposed fees for 2006.
Page 8 GAO-06-314 Indian Irrigation Projects

Figure 1: Location of BIA’s 16 Irrigation Projects by Region

BIA’s management of the 16 irrigation projects is decentralized, with 

regional and local BIA offices responsible for day-to-day operations and 

Crow

Pacific Ocean

Blackfeet

Fort Belknap Fort Peck

Wapato

Wind River

Colorado River

Pine River

Fort

Yuma

Walker River Uintah

Duck Valley

Fort Hall

Flathead

Irrigation projects

Sources: BIA; GAO.

Southwest region

Rocky Mountain region

Northwest region

Western region

San Carlos Indian Works

San Carlos Joint Works
Page 9 GAO-06-314 Indian Irrigation Projects

maintenance. Table 1 provides the tribe or tribes served by each of the 16 

irrigation projects along with the year each project was originally 

authorized. 

Table 1: Tribe(s) Served and Year Authorized for BIA’s 16 Irrigation Projects

 Source: GAO.

a

No specific authorization date.

b

The Fort Yuma Irrigation Project is operated and maintained by the Bureau of Reclamation. The 

operations and maintenance fees collected by BIA for the project are turned over to the Bureau of 

Reclamation.

The irrigation facilities constructed by BIA included a range of structures 

for storing and delivering water for agricultural purposes. Figure 2 

highlights an example of the key structural features found on BIA’s 

irrigation projects. 

Irrigation project Tribe(s) served Year authorized

Blackfeet Blackfeet Tribe of the Blackfeet Indian Reservation of Montana 1907

Colorado River Colorado River Indian Tribes of the Colorado River Indian 

Reservation, Arizona and California

1867

Crow Crow Tribe of Montana 1890

Duck Valley Shoshone-Paiute Tribes of the Duck Valley Reservation, Nevada a

Flathead Confederated Salish & Kootenai Tribes of the Flathead Reservation, 

Montana

1904

Fort Belknap Fort Belknap Indian Community of the Fort Belknap Reservation of 

Montana

1895

Fort Hall Shoshone-Bannock Tribes of the Fort Hall Reservation of Idaho 1894

Fort Peck Assiniboine and Sioux Tribes of the Fort Peck Indian Reservation, 

Montana

1908

Fort Yumab Quechan Tribe of the Fort Yuma Indian Reservation, California & 

Arizona

1904

Pine River Southern Ute Indian Tribe of the Southern Ute Reservation, Colorado a

San Carlos Indian Works Gila River Indian Community of the Gila River Indian Reservation, 

Arizona

1924

San Carlos Joint Works Gila River Indian Community of the Gila River Indian Reservation, 

Arizona

1924

Uintah Ute Indian Tribe of the Uintah & Ouray Reservation, Utah 1906

Walker River Walker River Paiute Tribe of the Walker River Reservation, Nevada a

Wapato Confederated Tribes and Bands of the Yakama Nation, Washington 1904

Wind River Arapahoe Tribe of the Wind River Reservation, Wyoming and the 

Shoshone Tribe of the Wind River Reservation, Wyoming 

1905
Page 10 GAO-06-314 Indian Irrigation Projects

Figure 2: Example of an Irrigation Project Operated by BIA

The beneficiaries of BIA’s projects have evolved over time and at present 

are quite diverse. Over the years, non-Indians have bought or leased a 

significant portion of the land served by BIA’s irrigation program. As a 

result, current water users on BIA’s projects include the tribes, individual 

Flow

Flow

Storage

reservoir

Main canal

headworks

Flow

measurement

Flume

Canal lining

Check

structure

Wasteway

Wasteway

Inverted

siphon

Diversion

River dam

Return

via

ground

water

End via spill

wasteway

Farm

headgate

Secondary

canal

headgate

Regulatory

storage

Unlined

ditch

Flow

Flow

Flow

Flow

Check structure

Ground

water

well pumps

River

headgate

Flow meter

Drains

River pumping plant

Diverted water

Natural water ways

Water in fields surface return

Subsurface return

Surface return

Source: Bureau of Reclamation, GAO.
Page 11 GAO-06-314 Indian Irrigation Projects

Indian landowners, non-Indian landowners, and non-Indian lessees of 

Indian lands. The extent of non-Indian landownership and leasing ranges 

significantly across BIA’s irrigation projects (see table 2). For example, 100 

percent of the land served by the Colorado River Irrigation Project is Indian 

owned, while only about 10 percent of the land served by the Flathead 

Irrigation Project is Indian owned.

Table 2: Land Ownership for BIA’s 16 Irrigation Projects

Source: GAO analysis of BIA data.

a

The Fort Yuma Irrigation Project is operated and maintained by the Bureau of Reclamation. The 

operations and maintenance fees collected by BIA for the project are turned over to the Bureau of 

Reclamation.

b

The acreage for the San Carlos Indian Works is also included in the acreage for the San Carlos Joint 

Works. In calculating the total acreage, the acreage for the San Carlos Indian Works is only counted 

once.

Federal regulations and internal BIA guidance require that BIA collaborate 

with water users, both Indian and non-Indian, in managing the irrigation 

Irrigation project Total assessed acreage

Percentage of Indian 

owned land

Percentage of non-Indian 

owned land

Colorado River 79,350 100 0

Duck Valley 12,923 100 0

Fort Yumaa 7,524 100 0

San Carlos Indian Works 50,000b 99 1

Fort Belknap 9,900 92 8

Walker River 2,100 90 10

Pine River 11,855 85 15

Fort Hall 72,201 80 20

Wind River 38,300 67 33

Blackfeet 38,300 60 40

Wapato 96,443 60 40

Crow 38,900 56 44

Fort Peck 18,800 53 47

Uintah 62,200 52 48

San Carlos Joint Works 100,000b 50 50

Flathead 128,105 10 90

Total 716,901b 57 43
Page 12 GAO-06-314 Indian Irrigation Projects

projects. For example, federal regulations state that close cooperation 

between BIA and water users is necessary and that the BIA official in 

charge of each project is responsible for consulting with all water users in 

setting program priorities.6

 In addition, BIA’s manual requires that BIA 

“provide opportunities for water user participation in matters relating to 

irrigation project operations” and that BIA’s officer-in-charge “meet 

regularly with water users to discuss proposed [operation and 

maintenance] assessment rates ... [and] general operations and 

maintenance.” Although BIA guidance does not define “regularly,” BIA’s 

Irrigation Handbook explicitly recommends that project staff meet at least 

twice annually to discuss work performed over the course of the year and 

allow for water user feedback and suggestions for the coming year. 

Furthermore, BIA’s Irrigation Handbook states that, at a minimum, BIA 

should discuss annual project budgets and work plans with water users. 

Since their inception, BIA’s 16 irrigation projects have been plagued by 

maintenance concerns. Construction of the projects was never fully 

completed, resulting in structural deficiencies that have continually 

hindered project operations and efficiency. In addition, water users and 

BIA have reported that operations and maintenance fees provide 

insufficient funding for project operations. Due to insufficient funding, 

project maintenance has been consistently postponed, resulting in an 

extensive and costly list of deferred maintenance items. Such deferred 

maintenance ranges from repairing or replacing dilapidated irrigation 

structures to clearing weeds from irrigation ditches. 

In addition, concerns regarding BIA’s management of the projects have 

been raised for years, particularly in regard to its financial management 

practices. For example, problems concerning BIA’s billing practices for its 

operations and maintenance fees have been raised by many, prompting 

independent review on more than one occasion. We and the Department of 

the Interior’s Inspector General have both identified serious problems with 

the land use records BIA has used to develop its annual operations and 

maintenance bills.7

 In response, BIA instituted a new financial management 

system called the National Irrigation Information Management System, 

6

25 C.F.R. § 171.1 (c), (d).

7

GAO, Indian Programs: BIA’s Management of the Wapato Irrigation Project, GAO/RCED97-124 (Washington D.C.: May 28, 1997); U.S. Department of the Interior, Office of the 

Inspector General, Indian Irrigation Projects, Bureau of Indian Affairs, 96-I-641, 

(Washington D.C.: March 1996).
Page 13 GAO-06-314 Indian Irrigation Projects

which has begun to address some of the billing errors. However, concerns 

still exist regarding the accuracy of the data in the billing system. The 

accuracy of some of the information in the irrigation billing system is 

dependant on the irrigation program receiving accurate and timely 

information from other BIA programs, such as land ownership and leasing 

information from BIA’s Real Estate Services program.

In 2001, the Yakama tribe and individual tribal members filed appeals 

challenging the Wapato Irrigation Project’s operation and maintenance fees 

for the pre-2000 and year 2000 bills. Furthermore, the Wapato Irrigation 

Project agreed to not send any bills to the tribe or its members since 2001. 

Although a settlement is under discussion, in the interim the Wapato 

Irrigation Project has not been able to collect about $2 million, annually, of 

its expected revenue. 

BIA Estimates the Cost 

of Deferred 

Maintenance at about 

$850 Million, but the 

Estimate Is Being 

Refined

According to BIA’s latest estimate, it will cost about $850 million to 

complete the deferred maintenance on all of its 16 irrigation projects; but 

this estimate is still being refined. BIA initially estimated its deferred 

maintenance costs at over $1 billion in fiscal year 2004, but acknowledged 

that this estimate was preliminary and would need to be revised largely 

because it incorrectly included new construction items and was developed 

by non-engineers. BIA revised this estimate downward in fiscal year 2005 

based on the implementation of a new facilities management system. 

However, BIA plans to further refine this estimate since some projects 

continued to incorrectly count new construction items as deferred 

maintenance.

In 2004, BIA Initially 

Estimated Completing the 

Deferred Maintenance 

Would Cost Over $1 Billion

As part of its ongoing effort to identify the needs and costs of deferred 

maintenance on its 16 irrigation projects, BIA estimated in fiscal year 2004 

that it would cost approximately $1.2 billion to complete all deferred 

maintenance. This initial estimate was based, in part, on preliminary 

condition assessments of irrigation structures and equipment for each of 

BIA’s 16 irrigation projects. These preliminary condition assessments 

generally consisted of visual inspections to classify each project’s structure 

and equipment using a scale of good, fair, poor, critical and abandoned 

based on the apparent level of disrepair. BIA staff then estimated how 

much it would cost to repair each item based on its condition classification.
Page 14 GAO-06-314 Indian Irrigation Projects

BIA generally defines deferred maintenance as upkeep that is postponed 

until some future time.8

 Deferred maintenance varies from project to 

project and ranges from cleaning weeds and trees which divert water from 

irrigation ditches, to repairing leaky or crumbling check gates designed to 

regulate water flow, to resloping eroded canal banks to optimize water 

flow. Figure 3 shows examples of deferred maintenance on some of the 

irrigation projects we visited (clockwise from the upper left, figure 3 shows 

(1) a defunct check gate and overgrown irrigation ditch at the Fort Belknap 

Irrigation Project, (2) a cattle-crossing eroding a canal bank and impairing 

water flow at the Wind River Irrigation Project, (3) a crumbling irrigation 

structure at the Crow Irrigation Project, and (4) a check gate leaking water 

at the Colorado River Irrigation Project). For detailed information on key 

maintenance issues for each of the nine projects we visited, see appendix 

II.

8

BIA defines deferred maintenance as “maintenance that was not performed when it should 

have been or when it was scheduled and which, therefore, was put off or delayed for a 

future period (adapted from [Federal Accounting Standards Advisory Board Bulletin] No. 6). 

This includes facility deficiencies where there is non-compliance to codes (e.g., life safety, 

[Americans with Disabilities Act, Occupational Safety and Health Administration], 

environmental, etc.) and other regulatory or Executive Order compliance requirements.”
Page 15 GAO-06-314 Indian Irrigation Projects

Figure 3: Examples of Deferred Maintenance on BIA’s Irrigation Projects (c. 2005)

BIA officials acknowledged that their fiscal year 2004 deferred 

maintenance estimate was only a starting point and that it needed to be 

revised for three key reasons: (1) the individuals who conducted the 

assessments were not knowledgeable about irrigation projects or 

infrastructure; (2) not all projects used the same methodology to develop 

their deferred maintenance cost estimates; and (3) some projects 

incorrectly counted new construction items as deferred maintenance. 

• BIA’s preliminary condition assessments were conducted by computer 

specialists, rather than by people with the expertise in irrigation or 

engineering needed to accurately assess project infrastructure. BIA 

contracted with geographic information system experts primarily to 

catalogue the structures on each project. These geographic information 

system experts also observed the condition of the structures they 

catalogued and classified the condition of each structure, based on the 

level of apparent disrepair, as part of the overall effort to inventory and 

map key structures on each project. Consequently, some items identified 

as being in “poor” condition may in fact be structurally sound but simply 

Source: GAO.
Page 16 GAO-06-314 Indian Irrigation Projects

appear cosmetically dilapidated, whereas other structures classified as 

being in “good” condition may in fact be structurally dilapidated but 

appear cosmetically sound. For example, according to BIA staff at the 

Colorado River Irrigation Project, the recent repainting of certain check 

gates disguised severe rust and structural deterioration of key metal 

parts. 

• BIA staff used inconsistent methodologies to develop the cost estimates 

for deferred maintenance. According to BIA staff, the deferred 

maintenance cost estimates were developed by different people, 

sometimes using different or unknown methodologies for assigning cost 

values to deferred maintenance items. For example, some projects 

developed their own cost estimates and sent them to BIA’s central office 

for inclusion in its overall figures, while BIA regional staff developed 

cost estimates for other projects based, in part, on information from 

BIA’s preliminary condition assessments. 

• Some projects incorrectly included new construction items as deferred 

maintenance. According to BIA, work that would expand a project or 

its facilities should not be categorized as deferred maintenance. 

Therefore, expanding an existing water delivery system or constructing 

a new building is not deferred maintenance. However, some projects 

incorrectly counted new construction items as deferred maintenance. 

For example, the Fort Hall Irrigation Project included increasing the 

capacity of its main canal for about $15.3 million, the Duck Valley 

Irrigation Project included building new canals for about $1.3 million, 

and the Flathead Irrigation Project included building a new warehouse 

for about $147,000. 

In 2005, BIA Revised the 

Estimate Downward to 

about $850 Million, but It Is 

Still a Work in Progress

To improve the accuracy of its deferred maintenance estimate in 2005 and 

to help staff develop, track, and continuously update deferred maintenance 

lists and cost estimates, BIA implemented MAXIMO—a facilities 

management system linked to the geographic information system mapping 

inventory developed from its preliminary condition assessments.9

 Using 

data from MAXIMO, BIA revised its total deferred maintenance estimate 

for the irrigation projects downward to about $850 million for fiscal year 

2005. Figure 4 shows the current deferred maintenance cost estimate for 

9

BIA implemented MAXIMO agencywide, not just for its irrigation projects, to help identify 

and track deferred maintenance. 
Page 17 GAO-06-314 Indian Irrigation Projects

each of the 16 projects. In the summer of 2005, BIA technical experts from 

the central irrigation office conducted training for BIA irrigation projects 

on how to use MAXIMO to enter information on maintenance needs, and 

how to correctly define deferred maintenance. Projects used this system to 

revise their list of deferred maintenance items and associated cost 

estimates in fiscal year 2005. While MAXIMO is still being tailored to the 

needs of the irrigation program, its implementation generally standardized 

the process for identifying and calculating deferred maintenance among 

projects. 

Figure 4: Fiscal Year 2005 Cost Estimate of Deferred Maintenance by Irrigation Project

Despite the implementation of MAXIMO, BIA’s fiscal year 2005 estimate of 

deferred maintenance is still inaccurate for the following reasons:

• Some projects continued to incorrectly count certain items as deferred 

maintenance. Despite training, some projects continued to incorrectly 

0 20 40 60 80 100 120 140 160 180 200

Irrigation project

Walker River

San Carlos Joint

Works

Duck Valley

Fort Yuma

Fort Belknap

Pine River

Fort Peck

Blackfeet

Flathead

Fort Hall

Crow

San Carlos Indian

Works

Wind River

Uintah

Colorado River

Wapato

Dollars in millions

Source: GAO analysis of BIA data.
Page 18 GAO-06-314 Indian Irrigation Projects

count certain items, such as new construction items and vehicles, as 

deferred maintenance. For example, the Fort Hall Irrigation Project 

included the installation of permanent diversion structures for about 

$2.1 million, the Wapato Irrigation Project included constructing 

reservoirs for about $640,000, and the San Carlos Indian Works 

Irrigation Project included building a new office for about $286,000. In 

addition, some projects included the cost of repairing vehicles or buying 

new ones in their deferred maintenance estimates, despite BIA’s new 

guidance that such items are not deferred maintenance. According to 

BIA officials, while projects can consider the weed clearing postponed 

due to broken vehicles as deferred maintenance, the delayed repair of 

the vehicle itself is not deferred maintenance. For example, the Wind 

River Irrigation Project included an excavator vehicle for about $500,000 

and the Crow Irrigation Project included dump trucks for about 

$430,000.

• Some projects provided BIA with incomplete information. According 

to BIA officials, some projects did not do thorough assessments of their 

deferred maintenance needs, and some may not be including legitimate 

deferred maintenance items, such as re-sloping canal banks that have 

eroded by crossing cattle or overgrown vegetation. Moreover, both the 

Walker River and the Uintah Irrigation Projects failed to provide 

information detailing their deferred maintenance costs, and several 

projects lumped items together as “other” with little or no explanatory 

information other than “miscellaneous”—accounting for almost onethird of BIA’s total deferred maintenance cost estimate for its irrigation 

projects (see fig. 5). 

• BIA made errors when compiling the total deferred maintenance cost 

estimates. For example, BIA inadvertently double-counted the estimate 

provided by the Colorado River Irrigation Project when compiling the 

overall cost estimate, according to BIA officials. Additionally, BIA 

officials erroneously estimated costs for all structures, such as flumes 

and check gates, based on the full replacement values even when items 

were in good or fair condition and needed only repairs. These structures 

account for over one-third of BIA’s total deferred maintenance estimate 

(see fig. 5).

While the inclusion of incorrect items and calculation errors likely 

overestimate BIA’s total deferred maintenance costs, the incomplete 

information provided by some projects may underestimate total costs.
Page 19 GAO-06-314 Indian Irrigation Projects

Figure 5: Fiscal Year 2005 Cost Estimate of Deferred Maintenance by Type

To further refine its cost estimate and to develop more comprehensive 

deferred maintenance lists, BIA plans to hire experts in engineering and 

irrigation to periodically conduct thorough condition assessments of all 16 

irrigation projects to identify deferred maintenance needs and costs. 

According to BIA officials, these thorough condition assessments are 

expected to more accurately reflect each project’s actual deferred 

maintenance, in part because experts in engineering and irrigation who can 

differentiate between structural and cosmetic problems will conduct them. 

These assessments will also help BIA prioritize the allocation of potential 

funds to complete deferred maintenance items because they will assign a 

prioritization rating to each deferred maintenance item based on the 

estimated repair or replacement cost as well as the overall importance to 

the project. The first such assessment was completed for the Flathead 

36% 23%

32%

5%

Other

Right of way

1%

Equipment and heavy equipment

3%

Building

Structure

Water conveyance system

Source: GAO analysis of BIA data.
Page 20 GAO-06-314 Indian Irrigation Projects

Irrigation Project in July 2005,10 and BIA plans to reassess the condition of 

each project at least once every 5 years, with the first round of such 

condition assessments completed by the end of 2010.

Shortcomings in BIA’s 

Management of Some 

Irrigation Projects 

Undermine Effective 

Decisionmaking

BIA’s management of some of its irrigation projects has serious 

shortcomings that undermine effective decisionmaking about project 

operations and maintenance. Under BIA’s organizational structure, in many 

cases, officials with the authority to oversee project managers’ 

decisionmaking lack the technical expertise needed to do so effectively, 

while the staff who do have the expertise lack the necessary authority. In 

addition, despite federal regulations that require BIA to consult with 

project stakeholders in setting project priorities, BIA has not consistently 

provided the information or opportunities necessary for stakeholders—

both Indian and non-Indian water users—to participate in decisionmaking 

about project operations and maintenance. (See appendix II for detailed 

information on key management concerns at each of the nine projects we 

visited.) 

In Many Cases, BIA Officials 

with Oversight Authority 

Lack Expertise, While Those 

with Expertise Lack 

Authority 

Under BIA’s organizational structure, in many cases, officials with the 

authority to oversee project managers’ decisionmaking lack the expertise 

needed to do so effectively, while the staff who do have the expertise lack 

the necessary authority to oversee project managers’ decisionmaking. BIA 

regional directors, agency superintendents, and agency deputy 

superintendents who oversee the projects do not generally have 

engineering or irrigation expertise, and they rely heavily on the project 

managers to run the projects. (See fig. 6 for an organizational chart 

showing the lines of authority for providing oversight of a typical BIA 

irrigation project.) Of the nine projects we visited, only two had managers 

at the regional or agency levels who are experts in irrigation or engineering. 

At the same time, BIA staff with the irrigation and engineering expertise—

regional irrigation engineers and central irrigation office staff—have no 

authority over the 16 projects under BIA’s current organizational structure. 

Consequently, key technical decisions about project operations and 

maintenance, such as when or how to repair critical water delivery 

10This condition assessment, entitled Final Report: Engineering Evaluation of Existing 

Conditions, Flathead Agency Irrigation Division (FAID) was prepared by HKM 

Engineering for the Confederated Salish and Kootenai Tribes. BIA did not fund this 

condition assessment.
Page 21 GAO-06-314 Indian Irrigation Projects

infrastructure, do not necessarily get the technical oversight or scrutiny 

needed.

Figure 6: Misalignment of Expertise and Authority for a Typical BIA Irrigation Project

This organizational structure and reliance on the project managers breaks 

down when the person managing the project lacks the expertise required 

for the position—that is, in cases in which BIA has had difficulty filling 

project manager vacancies and has, as a result, hired less qualified people 

or has the agency deputy superintendent temporarily serving in the project 

manager position. Of the nine projects we visited, four lacked project 

managers for all or part of the 2005 irrigation season and five project 

managers were experts in engineering or irrigation. 

The GAO Internal Control Management and Evaluation Tool recommends 

that federal agencies analyze the knowledge and skills needed to perform 

jobs appropriately and provides guidance on organizational structure and 

Branch Chief,

Irrigation, Power and Safety of Dams

(Central Irrigation Office)

Regional Director

Deputy Regional Director

Central Irrigation Office Staff

Agency Superintendent

Agency Deputy Superintendent

Irrigation Project Manager

Regional Irrigation Engineer

Irrigation Project Staff

Managing and oversight authority for irrigation

Irrigation and or engineering skills and expertise

Deputy Director,

Field Operations

Deputy Director,

Office of Trust Services

Chief,

Division of Natural Resources

Director,

Bureau of Indian Affairs

Source: GAO.
Page 22 GAO-06-314 Indian Irrigation Projects

identification of potential risks to the agency in that structure.11

Specifically, it recommends that adequate mechanisms exist to address 

risks—such as the risks associated with staff vacancies or hiring less 

qualified staff.

When the project manager is under-qualified and unchecked by managers 

who heavily rely on his or her decisionmaking, the potential for adverse 

impacts on the operations and maintenance of an irrigation project 

increases. For example, at the Crow Irrigation Project in 2002, a project 

manager with insufficient expertise decided to repair a minor leak in a key 

water delivery structure by dismantling it and replacing it with a different 

type of structure. The new structure was subsequently deemed inadequate 

by BIA’s irrigation experts, and the required reconstruction delayed water 

delivery by about a month. In addition, at the Blackfeet Irrigation Project in 

2000, the accidental flooding and subsequent erosion of a farmer’s land was 

inadequately addressed by project and agency management who decided to 

use a short-term solution over the objections of the regional irrigation 

engineer, who lacked the authority to override the project manager and 

agency superintendent’s technical decision, despite their lack of expertise. 

At the time of this report, the regional irrigation engineer continues to 

negotiate the implementation of a long-term and technically sound 

solution.

Furthermore, BIA lacks protocols to ensure that project managers consult 

with, or get input from, BIA’s technical experts before implementing 

technically complex decisions about project operations and maintenance, 

further exacerbating problems and undermining management 

accountability. For example, in the 2002 incident at the Crow Irrigation 

Project discussed above, the project manager was not required to consult 

with, notify, or get approval from either the regional irrigation engineer or 

central irrigation office staff, despite his lack of expertise and the 

complexity of the flume replacement project he undertook. According to 

BIA officials, if the project manager had consulted an engineer, his plan to 

replace the flume with two small culverts would have been rejected before 

work began because it was technically insufficient and would not have 

been completed before the start of the approaching irrigation season.

11GAO, Internal Control Standards: Internal Control Management and Evaluation Tool,

GAO-01-1008G (Washington, D.C.: Aug. 2001).
Page 23 GAO-06-314 Indian Irrigation Projects

BIA Has Not Consistently 

Provided Information and 

Opportunities for 

Stakeholders to Participate 

in Setting Project Priorities 

A second serious management shortcoming is the extent to which some 

projects involve water users in decisionmaking. Federal regulations, as 

well as BIA guidance, call for involving project stakeholders—that is, tribal 

representatives as well as both Indian and non-Indian water users—in the 

operations and maintenance of each project. Specifically, federal 

regulations state that BIA is responsible for consulting with all water users 

in setting program priorities; BIA’s manual requires that BIA provide 

regular opportunities for project water users to participate in project 

operations; and BIA’s Irrigation Handbook recommends that BIA meet at 

least twice a year with project water users to discuss project budgets and 

desired work.

Despite such requirements and recommendations, BIA has not consistently 

provided the opportunities or information necessary for water users to 

participate in such decisionmaking about project operations and 

maintenance. The frequency of meetings between BIA and its project water 

users varied considerably on the nine projects we visited, from rarely 

(generally zero meetings per year), to periodically (generally more than one 

meeting per year), to regularly (generally more than three meetings per 

year), as shown in figure 9. For example, both the Blackfeet and Colorado 

River Irrigation Projects hold regular meetings with both tribal and 

individual water users, with meetings held quarterly at the Blackfeet 

Irrigation Project and monthly at the Colorado River Irrigation Project. In 

contrast, BIA officials on the Pine River Irrigation Project do not meet with 

any non-tribal water users, and BIA officials at the Fort Belknap Irrigation 

Project have held few water users meetings in recent years. There was no 

meeting with water users at the Fort Belknap Irrigation Project to kick-off 

the 2005 irrigation season because the project manager position was 

vacant, worsening an already adversarial relationship between water users 

and BIA, according to water users and a local government official. Also, 

BIA officials on the Crow Irrigation Project have no regularly scheduled 

meetings with either the tribe or individual water users and, in fact, failed 

to send a single representative to the meeting it called in 2005 for water 

users to voice their concerns about project management and operations.
Page 24 GAO-06-314 Indian Irrigation Projects

Figure 7: Opportunities for Water Users to Meet with BIA Varies by Project 

a

Individual water users include Indians and/or non-Indians, depending on the project.

In addition to a lack of regular meetings with all project water users, BIA 

has not consistently shared the type of information about project 

operations and finances that water users need to meaningfully participate 

in project decisionmaking. Although BIA officials at the Colorado River 

Irrigation Project share information on their budgets with water users and 

work collaboratively with water users to develop annual work priorities in 

accordance with BIA’s Irrigation Handbook, not all projects we visited 

provide or solicit this type of information. For example, BIA staff at the 

Wapato Irrigation Project does not solicit water users’ input on project 

priorities or share information on the project’s budget, according to water 

users we spoke with, and BIA officials at the Crow Irrigation Project do not 

share this type of critical information. However, some of the projects we 

visited have recently begun to share information on project spending and 

involve project water users in developing project priorities, despite not 

doing so historically. For example, the project management at the 

Blackfeet Irrigation Project began sharing budget information with its 

water users during the 2005 season, and the new project management at 

the Fort Belknap Irrigation Project stated that they plan on involving 

project water users in setting project priorities in the 2006 season. 

Irrigation project

BIA communication with

Tribes Individual

water usersa

Regular meetings

Periodic meetings

Rare meetings

Regular meetings

Periodic meetings

Rare meetings

Blackfeet

Colorado River

Crow

Fort Belknap

Pine River

San Carlos Indian Works

San Carlos Joint Works

Wapato

Wind River

Source: GAO.
Page 25 GAO-06-314 Indian Irrigation Projects

Moreover, although some project managers and their staff are 

approachable and responsive on an individual basis, according to water 

users on some projects we visited, others stated that project management 

on some of BIA’s irrigation projects were generally inaccessible and nonresponsive. For example, BIA officials acknowledged that a former project 

manager at the Blackfeet Irrigation Project told water users to sue BIA to 

get information on project decisionmaking. In addition, some expressed 

concerns that BIA is less responsive to non-Indians because BIA’s mission 

does not specifically include non-Indians. Consequently, some non-Indian 

water users have opted to go directly to their congressional representatives 

to raise their concerns. For example, non-Indian water users at the Wapato 

Irrigation Project have sought congressional intervention on several 

occasions to help compel BIA staff to disclose information about project 

finances, such as information related to proposed operations and 

maintenance fee debts and data on project land not being billed for 

operations and maintenance. In addition, Senator Conrad Burns and 

Congressman Dennis Rehberg of Montana co-sponsored a town hall 

meeting in 2003 to provide local water users an opportunity to voice project 

concerns to BIA officials. Requests by non-Indian water users for project 

management and regional staff to address the lack of water delivery at the 

Crow Irrigation Project during the month of August 2005 went largely 

unanswered by BIA, resulting in congressional intervention. Such lack of 

access and communication about project operations limits the ability of 

water users to have an impact on project decisions as well as the ability of 

BIA to benefit from this input.

Long-Term Direction of 

BIA’s Irrigation 

Program Depends on 

Resolution of a 

Number of Larger 

Issues

The long-term direction of BIA’s irrigation program depends on the 

resolution of several larger issues. Of most importance, BIA does not know 

the extent to which its irrigation projects are capable of financially 

sustaining themselves, which hinders its ability to address long-standing 

concerns regarding inadequate funding. The future of BIA’s irrigation 

program also depends on the resolution of how the deferred maintenance 

will be funded. BIA currently has no plans for how it will obtain funding to 

fix the deferred maintenance items, and obtaining this funding presents a 

significant challenge in times of tight budgets and competing priorities. 

Finally, it might be more appropriate for other entities, including other 

federal agencies, tribes, and water users, to manage some or all of the 

projects. 
Page 26 GAO-06-314 Indian Irrigation Projects

The Extent to Which 

Projects Are Capable of 

Sustaining Themselves Is 

Unknown 

BIA does not know the extent to which Indian irrigation projects are 

capable of sustaining themselves. Reclamation law and associated policy 

require the Department of the Interior’s Bureau of Reclamation to test the 

financial feasibility of proposed projects comparing estimated 

reimbursable project costs with anticipated revenues. The Bureau of 

Reclamation then uses these reimbursable cost estimates to negotiate 

repayment contracts with water users, where appropriate. In contrast, 

Indian irrigation projects were authorized to support Indian populations 

residing on reservations without regard to whether the projects could be 

financially self-sustaining. As a result, neither the Congress nor project 

stakeholders have any assurance that these projects can sustain 

themselves. For example, a comprehensive 1930 study of BIA’s irrigation 

program concluded that the Blackfeet and Fort Peck Irrigation Projects 

should be abandoned. Specifically, the report noted, “[a]fter a very careful 

study of all the available data relating to these projects, including a field 

examination, we are firmly convinced that any further attempts to 

rehabilitate and to operate and maintain these projects ... can result only in 

increasing the loss that must be accepted and sustained by the 

Government. Adequate preliminary investigations and studies to which 

every proposed project should be subjected, in our opinion, would have 

condemned ... these ... projects as unfeasible.”12 [Emphasis added.] 

Despite this lack of information on the overall financial situation for each 

of the projects, in the early 1960s BIA classified more than half of its 16 

projects as fully self-supporting, on the basis of annual operations and 

maintenance fees they collected from water users. These self-supporting 

projects do not receive any ongoing appropriated funds. These projects are 

subject to full cost recovery despite the absence of financial information to 

demonstrate that the water users could sustain this financial burden. The 

Blackfeet and Fort Peck Irrigation Projects were two of the projects 

classified as fully self-supporting. While the specific financial situations for 

the Blackfeet and Fort Peck Irrigation Projects have likely changed since 

the 1920s, BIA does not know if these projects, or any of the other Indian 

irrigation projects, are financially self-supporting.

The heavy reliance on water users to sustain these projects has created 

ongoing tension between the water users and BIA. Some water users have 

12Survey of Conditions of the Indians in the United States: Hearings Before a 

Subcommittee of the Senate Committee on Indian Affairs, 71st Cong., 2d Sess. at 2219-20 

(1930).
Page 27 GAO-06-314 Indian Irrigation Projects

complained to BIA that they cannot afford the operations and maintenance 

fees and they pressure BIA to keep the fees as low as possible. The Bureau 

of Reclamation recently conducted a study of the Pine River Irrigation 

Project and concluded that some of the water users could not conduct a 

profitable farming operation with the 2005 operations and maintenance fee 

of $8.50 per acre. BIA has not responded to the Bureau of Reclamation 

study, and in October 2005 BIA proposed doubling the rate to $17.00 per 

acre for the 2006 irrigation season even though water users claim that they 

cannot afford to pay a higher fee.13 The operations and maintenance fee has 

been set at $8.50 at the Pine River Irrigation Project since 1992 and, 

according to BIA officials, the collections do not provide adequate funds to 

properly operate and maintain the project. As a result, BIA estimates that 

the deferred maintenance at the project has grown to over $20 million. 

Without definitive information on the financial situation of each project, 

BIA cannot determine what portion of project operations and maintenance 

costs can be reasonably borne by the water users and to what extent 

alternative sources of financing, such as congressional appropriations, 

should be pursued. 

There Is No Plan for How to 

Fund the Deferred 

Maintenance 

Despite the estimated $850 million in deferred maintenance and the degree 

to which it impedes ongoing operations and maintenance at BIA’s irrigation 

projects, BIA currently has no plan for funding the list of deferred 

maintenance items. Funding deferred maintenance costs in the hundreds of 

millions of dollars will be a significant challenge in times of tight budgets 

and competing priorities. Nonetheless, officials stated that the agency has 

made little effort to identify options for funding the deferred maintenance. 

BIA acknowledges that income from ongoing operations and maintenance 

fees would likely be inadequate to cover the deferred maintenance, yet the 

agency has done little to identify alternative means of funding. According 

to officials, BIA has not asked the Congress for supplemental funding to 

cover the deferred maintenance. For example, water users report that the 

$7.5 million appropriated for BIA’s irrigation projects for fiscal year 2006 

resulted from lobbying by concerned water users, not from BIA’s efforts.14

To date, BIA has primarily focused on developing and refining an accurate 

estimate of the cost to fix the deferred maintenance items. While 

1370 Fed. Reg. 57889, 57893 (Oct. 4, 2005).

14These funds were specifically appropriated for five irrigation projects—Crow, Fort Peck, 

Fort Belknap, Blackfeet and Wind River—and one irrigation system.
Page 28 GAO-06-314 Indian Irrigation Projects

developing an estimate of the projected cost is important, BIA officials 

believe that the agency also needs to develop a plan for ultimately funding 

the deferred maintenance. 

Developing a plan for funding the deferred maintenance is complicated by 

competing priorities and a crisis-oriented management style that 

complicates preventative maintenance, according to BIA officials. The 

current state of disrepair of most of the irrigation projects results in 

frequent emergency situations concerning project operations and 

maintenance. As a result, BIA irrigation staff spends a significant amount of 

its time addressing emergency maintenance situations, to the detriment of 

other maintenance needs that are essential to sustaining the projects over 

the long term. As a result of this “crisis-style” management, BIA has limited 

time to devote to non-emergency issues such as the list of deferred 

maintenance items. Furthermore, this “crisis-style” management prevents 

BIA from devoting adequate time to preventative maintenance. For 

example, irrigation staff at Wind River Irrigation Project stated that making 

“band-aid” emergency repairs on a regular basis prevents them from 

addressing long-standing deferred maintenance needs, as well as from 

conducting strategic improvements that would help sustain the project 

over the long term. 

It Might Be More 

Appropriate for Other 

Entities to Manage Some or 

All of the Projects

It may be beneficial to consider whether other groups for whom irrigation 

is a priority or an area of expertise could better manage some of the 

irrigation projects, including other federal agencies, Indian tribes, and 

water users. BIA must balance its irrigation management responsibilities 

with its many other missions in support of Indian communities. As the 

federal agency charged with supporting Indian communities in the United 

States, BIA’s responsibility is to administer and manage land and natural 

resources held in trust for Indians by the U.S. government. Administration 

and management of these trust lands and resources involves a wide variety 

of responsibilities, including law enforcement, social services, economic 

development, education and natural resource management. Given the 

multitude of responsibilities that BIA must balance, there are inherent 

limits on the resources and knowledge that BIA is able to devote to any one 

program. As a result of these limitations and competing demands, officials 

report that irrigation management is not a priority for BIA. The fact that 

many water users on the irrigation projects are now non-Indian may further 

encourage BIA to prioritize and devote more resources to other programs 

before irrigation management. 
Page 29 GAO-06-314 Indian Irrigation Projects

Successful management of the irrigation projects by other groups would 

depend on the unique characteristics of each project and its water users. 

Potential groups who may be able to assume management for some 

irrigation projects or portions of some irrigation projects include the 

following:

• The Bureau of Reclamation. As the federal agency charged with 

managing water in the western United States, the Bureau of 

Reclamation has extensive technical experience in managing irrigation 

projects and has served in a technical or advisory capacity to BIA’s 

irrigation staff. Furthermore, efforts have been made in the past to turn 

over some BIA irrigation projects to the Bureau of Reclamation and the 

Fort Yuma Irrigation Project is currently operated by the Bureau of 

Reclamation. In addition, the Bureau of Reclamation utilizes 

management practices for its irrigation projects that maximize 

information sharing and collaboration with water users. For example, in 

contrast to BIA, the Bureau of Reclamation delegates responsibility for 

much of the day-to-day operations and maintenance on its irrigation 

projects to irrigation districts, which are organized groups of water 

users. 

• Indian Tribes. Officials report that some of the tribes have staff with 

extensive knowledge of irrigation and water management, as well as 

technical training. Some tribes stated that they have a vested interest in 

seeing their respective projects succeed, and they would like to assume 

direct responsibility for their reservation’s irrigation project, assuming 

the deferred maintenance items are fixed before the turnover occurs. 

Turning over some of the BIA projects to Indian tribes would be an 

option where tribes have the management and technical capability to 

assume responsibility for an irrigation project. 

• Water Users. Water users have extensive familiarity with the day-to-day 

management of the projects and in some cases already handle many 

day-to-day operations and maintenance activities. For example, the 

Crowheart Water Users Association, a group of water users at the Wind 

River Irrigation Project, have successfully assumed responsibility for 

most of the maintenance needs on their portion of the project. In 

exchange for their efforts, BIA refunds to the Crowheart Water Users 

Association 50 percent of their annual operation and maintenance fees. 

Through this arrangement, the Crowheart Water Users Association 

believes it has been able to more effectively address maintenance needs 

and increase project efficiency. Turning over some of the BIA projects to 
Page 30 GAO-06-314 Indian Irrigation Projects

water users would be an option where water users share similar 

interests and have positive working relationships, as well as the desire 

to organize an irrigation district or association. 

Any successful alternative management option would have to consider the 

sometimes disparate interests and priorities among water users. In some 

cases, a combination of the various alternative management options may 

be beneficial and feasible. This type of arrangement is currently being 

considered for the Flathead Irrigation Project, where BIA is currently in the 

process of turning over the operation and management of the project to a 

collaborative management group that may include the tribe, individual 

Indian water users, and non-Indian water users. However, regardless of the 

alternative management option, water users and tribal officials repeatedly 

stated that they would not be willing or able to take over project operations 

and maintenance unless the deferred maintenance had already been 

addressed or adequate funding was available to address the deferred 

maintenance needs.

Conclusions Since BIA historically has not had adequate funds to operate and maintain 

the projects, the projects are in a serious state of disrepair. BIA is in the 

process of implementing its plan to develop an accurate list and estimate of 

the deferred maintenance needs for each project. However, some of the 

projects also have day-to-day management shortcomings regarding 

technical support and stakeholder involvement that need to be addressed. 

BIA’s decentralized organizational structure combined with the difficulty in 

attracting and retaining highly qualified project managers at remote Indian 

reservations led to some poor decisionmaking at some of the projects. It is 

critically important that project managers, especially those with less than 

desirable qualifications, have the necessary level of technical support to 

prevent poor decisions from being made in the future. 

A lack of adequate stakeholder involvement at some projects has also 

seriously undermined project accountability. Unlike most other BIA 

programs, the operations and maintenance of the irrigation projects are 

funded almost entirely by the project beneficiaries—the water users, many 

of whom are non-Indian. Consequently, BIA is accountable to these water 

users and these water users expect to have an active voice in project 

operations and maintenance. Some projects have not fulfilled their 

obligations to regularly meet with project stakeholders, creating an 

adversarial environment in which BIA and project water users do not trust 

each other. This failure to involve stakeholders in the management of their 
Page 31 GAO-06-314 Indian Irrigation Projects

own projects means that BIA does not benefit from water user expertise 

and has resulted in widespread feelings that BIA is non-responsive and 

evasive, alienating many water users who feel disenfranchised. Moreover, 

this failure has limited the ability of stakeholders to hold BIA accountable 

for its decisions and actions.

In addition to some shortcomings with BIA’s ongoing day-to-day 

management of some of the projects, we also found that information on the 

financial sustainability of the projects is needed to help address the longterm direction of BIA’s irrigation program. BIA’s 16 irrigation projects were 

generally built in the late 1800s and early 1900s to further the federal 

government’s Indian policy of assimilation. The government made the 

decision to build these projects to support and encourage Indians to 

become farmers. This decision was generally not based on a thorough 

analysis designed to ensure that only cost effective projects were built. As a 

result, the financial sustainability of some of the projects has always been 

questionable, ultimately creating tension between BIA and its water users. 

BIA is under constant pressure to raise annual operations and maintenance 

fees to collect adequate funds to maintain the projects, while many water 

users contend that they do not have the ability to pay higher fees. Without a 

clear understanding of the financially sustainability of the projects, BIA 

does not know whether it is practical to raise operation and maintenance 

fees, or whether alternative sources of financing should be pursued. 

Information on financial sustainability, along with accurate deferred 

maintenance information, are both critical pieces of information needed to 

have a debate on the long-term direction of BIA’s irrigation program. Once 

this information is available, the Congress and interested parties will be 

able to address how the deferred maintenance will be funded and whether 

entities other than BIA could more appropriately manage some or all of the 

projects.

Recommendations for 

Executive Action

We recommend that the Secretary of the Interior take the following three 

actions.

To improve the ongoing management of the projects in the short-term, we 

recommend that the Secretary direct the Assistant Secretary for Indian 

Affairs to

• provide the necessary level of technical support for project managers 

who have less than the desired level of engineering qualifications by 

putting these projects under the direct supervision of regional or central 
Page 32 GAO-06-314 Indian Irrigation Projects

irrigation office staff or by implementing more stringent protocols for 

engineer review and approval of actions taken at the projects; and

• require, at a minimum, that irrigation project management meet twice 

annually with all project stakeholders—once at the end of a season and 

once before the next season—to provide information on project 

operations, including budget plans and actual annual expenditures, and 

to obtain feedback and input.

To obtain information on the long-term financial sustainability of each of 

the projects, we recommend that the Secretary direct the Assistant 

Secretary for Indian Affairs to conduct studies to determine both how 

much it would cost to financially sustain each project, and the extent to 

which water users on each project have the ability to pay these costs. This 

information will be useful to congressional decisionmakers and other 

interested parties in debating the long-term direction of BIA’s irrigation 

program.

Agency Comments and 

Our Evaluation

We provided the Department of the Interior with a draft of this report for 

review and comment. However, no comments were provided in time to be 

included as part of this report.

As agreed with your office, 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 of this report to the Secretary 

of the Interior, the Assistant Secretary for Indian Affairs, as well as to 

appropriate Congressional Committees, and other interested Members of 

Congress. We also will make copies available to others upon request. In 

addition, the report will be available at no charge on the GAO Web site at 

http://www.gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report.
Page 33 GAO-06-314 Indian Irrigation Projects

If you or your staff have questions about this report, please contact me at 

(202) 512-3841 or nazzaror@gao.gov. Key contributions to this report are 

listed in appendix III.

Robin M. Nazzaro

Director, Natural Resources

and Environment
Page 34 GAO-06-314 Indian Irrigation Projects

Appendix I

Objectives, Scope, and Methodology AAppenednxidexiIs

We were asked to address several issues concerning the Department of the 

Interior’s Bureau of Indian Affairs’ (BIA) management of its 16 irrigation 

projects. Specifically, we were asked to examine (1) BIA’s estimated 

deferred maintenance cost for its 16 irrigation projects; (2) what 

shortcomings, if any, exist in BIA’s current management of its irrigation 

projects; and (3) any issues that need to be addressed to determine the 

long-term direction of BIA’s irrigation program. 

For all three objectives, we collected documentation on BIA’s 16 irrigation 

projects from officials in each of BIA’s central Irrigation, Power, and Safety 

of Dams offices (central irrigation offices) located in Washington, D.C., and 

other locations in the western United States. We also visited and collected 

information from each of BIA’s four regional offices that oversee the 16 

irrigation projects, including the Rocky Mountain, Northwest, Western, and 

Southwest regions. In addition, we visited 9 of the 16 projects located 

across all 4 regions. Specifically, we visited: (1) the Blackfeet Irrigation 

Project, (2) the Colorado River Irrigation Project, (3) the Crow Irrigation 

Project, (4) the Fort Belknap Irrigation Project, (5) the Pine River Irrigation 

Project, (6) the San Carlos Indian Works Irrigation Project, (7) the San 

Carlos Joint Works Irrigation Project, (8) the Wapato Irrigation Project, and 

(9) the Wind River Irrigation Project. We selected these projects based on a 

combination of factors aimed at maximizing our total coverage (over 50 

percent of the projects), visiting at least one project in each of the regions 

where irrigation projects are located, visiting the project with the highest 

deferred maintenance cost estimate in each region using BIA’s fiscal year 

2004 data, and visiting what BIA considered to be the three best projects 

and the five worst projects. During the site visits, we collected projectspecific information from BIA officials and project stakeholders including 

tribes and water users. We also met with and collected documentation from 

the Department of the Interior’s Bureau of Reclamation, the federal agency 

charged with managing water in the western United States, for comparative 

purposes. 

To examine BIA’s estimated deferred maintenance cost for its 16 irrigation 

projects, we toured each of the 9 projects we visited to see examples of 

deferred maintenance and their impact, and we reviewed BIA’s lists of 

deferred maintenance items and associated cost estimates for both fiscal 

years 2004 and 2005. We also reviewed the methodology BIA used to 

develop these lists and estimates and interviewed BIA staff involved in 

developing these lists and estimates to identify major deficiencies. 

Although we analyzed the cost estimates provided by BIA, we did not 

develop our own estimate of deferred maintenance. To assess the reliability 
Appendix I

Objectives, Scope, and Methodology

Page 35 GAO-06-314 Indian Irrigation Projects

of data we received from BIA on deferred maintenance, we interviewed 

officials most knowledgeable about the collection and management of 

these data. We reviewed the relevant controls and found them adequate. We 

also conducted tests of the reliability of the computerized data. On the 

basis of these interviews, tests, and reviews, we concluded that BIA’s 

estimates of deferred maintenance were sufficiently reliable for the 

purposes of this report. 

To examine what shortcomings, if any, exist in BIA’s current management 

of its irrigation projects, we reviewed relevant federal regulations and 

agency guidance, and analyzed BIA-wide and project-specific management 

protocols and systems for the nine projects we visited. We also reviewed 

general guidance on internal control standards, including risk assessment, 

monitoring, and information and communication. We interviewed BIA 

officials from the central irrigation office in Washington, D.C., Colorado, 

Oregon, Arizona and Montana. We also interviewed BIA regional officials as 

well as agency and project officials associated with each of the 9 projects 

we visited for information on key shortcomings in BIA’s management of its 

irrigation projects. Finally, we interviewed a variety of project 

stakeholders—including tribal representatives, individual Indian water 

users, and non-Indian water users—at each of the 9 projects we visited for 

information on key shortcomings in BIA’s management.

Finally, to examine any issues that need to be addressed to determine the 

long-term direction of BIA’s irrigation program, we reviewed previous 

studies highlighting key issues impacting the future of BIA’s irrigation 

program. This included reviewing previous studies conducted by GAO, the 

Department of the Interior’s Office of Inspector General, and the Bureau of 

Reclamation, as well as other studies conducted at the request of the 

Congress. We also reviewed relevant federal regulations and agency 

guidance, as well as historical information relevant to BIA’s management of 

the irrigation program, including budget information and agency memos. 

Finally, we interviewed BIA officials from the central irrigation office, 

regional offices, and the 9 projects we visited for information on the key 

challenges impacting the long-term direction of the program. We also 

interviewed project stakeholders—including tribal representatives and 

water users—at the 9 projects we visited for information on the key issues 

impacting the future direction of BIA’s irrigation program. 

We performed our work between March 2005 and February 2006 in 

accordance with generally accepted government auditing standards.
Page 36 GAO-06-314 Indian Irrigation Projects

Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited ApendxiI

This appendix contains brief profiles of the nine irrigation projects we 

visited. Each project profile begins with a short overview of basic facts 

about the project, followed by a set of bullet points describing the key 

operations and maintenance concerns and the key management concerns 

expressed to us by BIA officials, tribal officials, or water users during our 

site visits.

Blackfeet Irrigation 

Project 

The Blackfeet Irrigation Project was authorized for construction in 1907, 

but construction was never completed. It consists of 38,300 acres being 

assessed operations and maintenance fees (and 113,100 acres authorized 

for irrigation). The project is located in Browning, Montana on the 

Blackfeet Indian Reservation of Montana, home of the Blackfeet Tribe. 

About 60 percent of the project’s land is owned by either the tribe or 

individual tribal members, and about 40 percent is owned by non-Indians. 

BIA currently estimates the project’s total deferred maintenance costs to be 

$29,130,222. See figure 8 below for pictures of the Blackfeet Irrigation 

Project.

Figure 8: Pictures of the Blackfeet Irrigation Project (July 2005)

Key Operations and 

Maintenance Concerns 

Expressed During Our Site 

Visit

• Fees are insufficient to cover the costs of project operations and 

maintenance. 

Source: GAO.

Deteriorating Canal Lining Leaking Check Gate
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 37 GAO-06-314 Indian Irrigation Projects

• Weeds and overgrown vegetation are problematic and impair water 

flow.

• Deferring maintenance has led to bigger and more costly maintenance 

problems.

• Deferring maintenance decreases water efficiency and access to water.

• The project as built cannot meet the increased demand for water.

Key Management Concerns 

Expressed During Our Site 

Visit

• Communication between BIA and the water users could be improved, 

such as enhancing transparency, increasing involvement, and meeting 

separately with the tribe.

• Lack of training and expertise undermines BIA’s management of the 

project.

• Inadequate oversight within BIA exacerbates problems associated with 

lack of training and expertise.

• Project staff should report to managers with expertise in irrigation 

and/or engineering.

• BIA protocols are too vague, such as when project staff should consult 

with regional or central irrigation office engineers.

• BIA needs to be able to measure water in order to better manage water 

deliveries and identify critical problems.

• Irrigation is a low priority for BIA.

Colorado River 

Irrigation Project

The Colorado River Irrigation Project was the first BIA irrigation project 

built, authorized for construction in 1867, but construction was never 

completed. It is now considered the best of BIA’s 16 revenue-generating 

irrigation projects due, in part, to its innovative leadership and customer 

service attitude. The project has adopted a user fee system that measures 

and assesses water users based on their actual usage as well as charging 

water users additional fees for using more water than their individual 

allotment. The project is located in Parker, Arizona on the Colorado River 
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 38 GAO-06-314 Indian Irrigation Projects

Indian Reservation, home of the Colorado River Indian Tribes. The project, 

which has a 10-month-long irrigation season, consists of 79,350 assessed 

acres (and 107,588 acres authorized for irrigation), and is composed 

entirely of Indian land—land owned by the tribe or its members. BIA 

currently estimates the project’s total deferred maintenance costs to be 

$134,758,664. See figure 9 for pictures of the Colorado River Irrigation 

Project.

Figure 9: Pictures of the Colorado River Irrigation Project (June 2005)

Key Operations and 

Maintenance Concerns 

Expressed During Our Site 

Visit

• Development leases may no longer be allowed, potentially resulting in 

irrigable land going un-irrigated and costing the tribe and project 

potential revenues. 

• Replacement of deteriorating irrigation structures needed.

• Canal needs new lining due to years of deterioration and, in some cases, 

poor construction.

• Clearing moss and pondweed is needed lest the flow of water be 

impaired. 

• New irrigation structures needed to regulate water flow where ditches 

converge.

Source: GAO.

Concrete-lined Irrigation Canal Leaking Check Gate
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 39 GAO-06-314 Indian Irrigation Projects

Key Management Concerns 

Expressed During Our Site 

Visit

• Understaffing and high turnover of project system operators adversely 

impact water deliveries in that there are too few system operators to 

deliver water in a timely manner. 

• BIA procurement and contracting is time-consuming and costly. 

• Annual project budget may understate actual funding because it does 

not include possible additional fees.

• Operations and maintenance fees can only be used to address 

operations and maintenance on the existing project, rather than expand 

the project.

Crow Irrigation Project The Crow Irrigation Project was authorized for construction in 1890, but 

construction was never completed. It is one of the oldest of BIA’s 16 

revenue-generating irrigation projects with 38,900 acres being assessed 

operations and maintenance fees (and 46,460 acres authorized for 

irrigation). The project is located in Crow Agency, Montana on the Crow 

Reservation, home of the Crow Tribe of Montana. About 56 percent of the 

project land is owned by either the tribe or individual tribal members, and 

about 44 percent is owned by individual non-Indians. BIA currently 

estimates the project’s total deferred maintenance costs to be $54,550,496. 

See figure 10 for pictures of the Crow Irrigation Project.

Figure 10: Pictures of the Crow Irrigation Project (March 2005)

Source: GAO.

Abandoned Car in Deteriorated Canal Crumbling Irrigation Structure
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 40 GAO-06-314 Indian Irrigation Projects

Key Operations and 

Maintenance Concerns 

Expressed During Our Site 

Visit

• Fees are insufficient to cover the project’s operations as well as 

maintenance costs.

• Weeds, overgrown vegetation, tree roots and garbage impair water flow 

in the canals and ditches.

• Crumbling or dilapidated irrigation structures impair water delivery.

• The repair of Rotten Grass Flume needs further work.

• Canal erosion causes sink holes and impairs water flow.

• Deferred maintenance of certain structures leads to safety concerns, 

such as when BIA staff must go into the canal to raise or lower broken 

check gates.

Key Management Concerns 

Expressed During Our Site 

Visit

• The project’s recently reassigned project manager was under-qualified, 

resulting in some decisions that hurt the project and undermine water 

delivery, such as the Rotten Grass Flume incident.

• BIA has inadequate oversight of the project manager and his decisions.

• BIA relies on “crisis-style” management rather than a long-term plan to 

manager project. 

• Allegations that a former project manager inappropriately used fees and 

was not accountable for financial decisions.1

• Communication breakdown between BIA and its water users.

• The project may be better managed if BIA turned over the project’s 

management to water users or tribe.

• Irrigation is a low priority for BIA.

1

GAO referred these allegations to the Department of the Interior’s Office of the Inspector 

General in August 2005. 
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 41 GAO-06-314 Indian Irrigation Projects

Fort Belknap Irrigation 

Project

The Fort Belknap Irrigation Project was authorized for construction in 

1895, but construction was never completed. It is one of the smallest of 

BIA’s 16 revenue-generating irrigation projects with 9,900 acres being 

assessed operations and maintenance fees (and 13,320 acres authorized for 

irrigation). The project is located in Harlem, Montana on the Fort Belknap 

Reservation, home of the Fort Belknap Indian Community of the Fort 

Belknap Reservation of Montana. About 92 percent of the land is owned by 

either the tribe or individual tribal members, and about 8 percent is owned 

by individual non-Indians. BIA currently estimates the project’s total 

deferred maintenance costs to be $17,535,494. See figure 11 for pictures of 

the Fort Belknap Irrigation Project.

Figure 11: Pictures of the Fort Belknap Irrigation Project (July 2005)

Key Operations and 

Maintenance Concerns 

Expressed During Our Site 

Visit

• Fees and appropriations are insufficient to cover the project 

maintenance needs.

• Weeds and overgrowth of vegetation impair water flow.

• Canal erosion caused by cattle-crossings impairs water flow.

• Deteriorated and leaking irrigation structures impair water delivery.

• Additional equipment is needed to conduct maintenance on project.

Source: GAO.

Graffiti on Irrigation Structure Overgrown Vegetation Around Dilapidated 

Irrigation Check Structure
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 42 GAO-06-314 Indian Irrigation Projects

• Deferred maintenance exacerbates problems of poor farming land and 

low crop values.

Key Management Concerns 

Expressed During Our Site 

Visit

• Poor communication and tense relations between BIA and water users.

• Staff turnover and difficulty finding qualified staff are problematic.

• Some project staff lack adequate expertise and training to manage 

project.

• Lack of transparency and water management plan limits BIA 

accountability.

• Some water users want BIA to begin water delivery earlier in season.

Pine River Irrigation 

Project

The Pine River Irrigation Project is the only one of BIA’s 16 revenuegenerating irrigation projects located in the Southwest region, with 11,855 

acres being assessed operations and maintenance fees. Construction on the 

project was never completed. The project is located in Ignacio, Colorado 

on the Southern Ute Reservation, home to the Southern Ute Indian Tribe of 

the Southern Ute Reservation, Colorado. About 85 percent of the land is 

owned by either the tribe or individual tribal members, and about 15 

percent is owned by individual non-Indians. BIA currently estimates the 

project’s total deferred maintenance costs to be $20,133,950. See figure 12 

for pictures of the Pine River Irrigation Project.
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 43 GAO-06-314 Indian Irrigation Projects

Figure 12: Pictures of the Pine River Irrigation Project (August 2005) 

Key Operations and 

Maintenance Concerns 

Expressed During Our Site 

Visit

• Collections from operations and maintenance fees do not provide 

adequate funds to properly operate and maintain the project. 

• The project’s operations and maintenance fees have not been raised 

since 1992. BIA has proposed doubling the fees from $8.50 per acre to 

$17.00 per acre for the 2006 irrigation season.

• The project’s cash reserves were depleted in 2004.

• The project has a number of old water delivery contracts, referred to as 

“carriage contracts,” from the 1930s that are at low fixed rates. Under 

some of the contracts the water users only pay $1.00 per acre to the 

project.

Key Management Concerns 

Expressed During Our Site 

Visit

• The practice of subsidizing the project through other BIA programs, 

such as Natural Resources, Roads Construction, Roads Maintenance 

and Realty, was scheduled to end at the end of fiscal year 2005. 

Alternative sources of funds must be found for the project manager and 

clerk positions.

• “Crisis-style” management only, no preventive maintenance.

Source: GAO.

Irrigation Ditch in Need of Reshaping Overgrown Vegetation in Irrigation Ditch
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 44 GAO-06-314 Indian Irrigation Projects

• Project staff does not formally meet with or provide information to 

individual water users.

• A Bureau of Reclamation study in 1999 found that some of the water 

users could not afford to pay fees of $8.50 to the project and operate a 

profitable farming operation. BIA has not responded to the study.

• The former project manager stated that the BIA irrigation projects 

should be turned over to the Bureau of Reclamation.

San Carlos Indian 

Works Irrigation 

Project (Pima)

The San Carlos Indian Works Irrigation Project was authorized for 

construction in 1924, but construction was never completed. It is one of the 

newest of BIA’s 16 revenue-generating irrigation projects with 50,000 acres 

being assessed operations and maintenance fees (and 50,546 acres 

authorized for irrigation). The project, also referred to as Pima, is located 

in Sacaton, Arizona on the Gila River Indian Reservation, home of the Gila 

River Indian Community. It is served both by its own infrastructure and by 

that of the San Carlos Joint Works Irrigation Project. The project land is 

generally owned by the tribe or tribal members, with about 99 percent of 

the land owned by either the tribe or individual tribal members, and about 1 

percent owned by individual non-Indians. BIA currently estimates Pima’s 

total deferred maintenance costs to be $62,865,503. See figure 13 for 

pictures of the San Carlos Indian Works Irrigation Project.

Figure 13: Pictures of the San Carlos Indian Works Irrigation Project (June 2005)

Source: GAO.

Concrete-lined Irrigation Canal Canal with Vegetation Growth
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 45 GAO-06-314 Indian Irrigation Projects

Key Operations and 

Maintenance Concerns 

Expressed During Our Site 

Visit

• Inefficiency in water delivery results in fewer water users being able to 

receive water, leading to idle acreage in some cases. 

• Clearing tumbleweeds and other vegetation that can clog culverts are a 

recurring problem and represents a large part of the project’s spending 

on operations and maintenance.

• Erosion is a continuing problem, in part, because the canal is used for 

both water deliveries as well as drainage.

• BIA staff has a “wish list” of items that would bring the project into top 

condition, extending beyond the basic deferred maintenance. 

• Project infrastructure may not have the capacity to deliver water to all 

potential water users.

Key Management Concerns 

Expressed During Our Site 

Visit

• 2007 turnover to water users is still underway. 

• Insufficient reserve funds means that project staff may not have enough 

money to conduct needed maintenance towards the end of the year. 

• Vacancies are a constant problem at the project, leaving too few staff to 

conduct project maintenance.

• BIA is too slow to respond to water users’ requests for repairs.

San Carlos Joint Works 

Irrigation Project 

(Coolidge)

The San Carlos Joint Works Irrigation Project was authorized for 

construction in 1924, but construction was never completed. It provides 

water to non-Indian irrigators as well as the San Carlos Indian Works 

Irrigation Project. It consists of 100,000 acres being assessed operations 

and maintenance fees (and 100,546 acres authorized for irrigation), with 50 

percent of the land owned by non-Indian irrigators and 50 percent owned 

by Indian irrigators (in the form of the San Carlos Indian Works Irrigation 

Project). The project is located in Coolidge, Arizona. BIA currently 

estimates Coolidge’s total deferred maintenance costs to be $5,775,427. See 

figure 14 for pictures of the San Carlos Joint Works Irrigation Project.
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 46 GAO-06-314 Indian Irrigation Projects

Figure 14: Pictures of the San Carlos Joint Works Irrigation Project (June 2005)

Key Operations and 

Maintenance Concerns 

Expressed During Our Site 

Visit

• Lack of certainty in BIA’s ability to deliver requested water to all water 

users has led some to purchase additional water from outside of the 

project.

• Silt removal from irrigation canals and ditches is a recurring problem, 

leading BIA to purposefully over-excavate the main canal each year in 

an attempt to catch excess silt that can clog culverts and prevent water 

delivery impairments. 

• Repair of China Wash Flume is an expensive undertaking, but the 

flume’s failure could jeopardize water deliveries for much of the project.

• Removal of weeds to prevent clogged culverts is a recurring problem for 

the project.

Key Management Concerns 

Expressed During Our Site 

Visit

• 2007 turnover to water users is under way but not finalized.

• Lawsuit against BIA’s increase in operations and maintenance fees 

resulted in some water delivery delays while the lawsuit is pending. 

• Contracting delays within BIA have resulted in postponed project 

maintenance.

Source: GAO.

Deteriorating China Wash Flume Concrete that Fell from Flume Weeds in Irrigation Canal 
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 47 GAO-06-314 Indian Irrigation Projects

• Turnover of BIA staff and lack of water user inclusion in project 

decisionmaking impedes effective communication. 

• BIA lacks accountability to water users in terms of how it spends 

operations and maintenance fees.

Wapato Irrigation 

Project

The Wapato Irrigation Project is one of the oldest and largest of BIA’s 16 

revenue-generating irrigation projects with 96,443 acres being assessed 

operations and maintenance fees (and 145,000 acres authorized for 

irrigation). It was authorized for construction in 1904, but construction was 

never completed. The project is located in Yakima, Washington on the 

Yakama Reservation, home of the Confederated Tribes and Bands of the 

Yakama Nation. About 60 percent of the project land is owned by either the 

tribe or individual tribal members, and about 40 percent is owned by 

individual non-Indians. BIA currently estimates the project’s total deferred 

maintenance costs to be $183,128,886. See figure 15 for pictures of the 

Wapato Irrigation Project.

Figure 15: Pictures of the Wapato Irrigation Project (April 2005)

Source: GAO.

Weed Clearing Machine Irrigation Canal with Crumbling Concrete Lining
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 48 GAO-06-314 Indian Irrigation Projects

Key Operations and 

Maintenance Concerns 

Expressed During Our Site 

Visit

• Deterioration of project prevents some water users from receiving 

water.

• Lack of regular project maintenance has led many water users to make 

repairs on their own in order to irrigate crops.

• Water users claim that project staff performs inadequate or faulty 

repairs, resulting in wasted operations and maintenance payments or 

the need for water users to fix the sloppy repairs.

• Fees are insufficient because (a) rates have been set too low, and (b) the 

tribe’s appeal of BIA’s operations and maintenance bills since 2001 has 

decreased income by at least $2 million annually because the agency 

will not collect on these bills or issue subsequent bills until the matters 

raised in the appeal are resolved.

• Fees are insufficient to cover both maintenance and administrative 

costs, such as salaries and benefits, leading to suggestions that BIA 

cover such costs.

Key Management Concerns 

Expressed During Our Site 

Visit

• Understaffing due to inadequate funds and difficulty in finding qualified 

staff has resulted in too few staff to operate and maintain project.

• BIA relies on “crisis-style” management to manage project, resulting in a 

lack of planning and preventive maintenance. 

• Water users lack voice in project decisionmaking, resulting in concerns 

about limited accountability of project staff to its water users.

• Alleged errors with operations and maintenance billing—such as BIA 

billing dead landowners and BIA overbilling living landowners—led the 

tribe and its members to appeal BIA’s billing of operations and 

maintenance fees. Resolution of these appeals is still pending within the 

agency. BIA will not collect on these bills or issue subsequent bills until 

the matters raised in the appeal are resolved.

Wind River Irrigation 

Project

The Wind River Irrigation Project was authorized for construction in 1905, 

but construction was never completed. It is one of BIA’s 16 revenuegenerating irrigation projects with 38,300 acres being assessed operations 
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 49 GAO-06-314 Indian Irrigation Projects

and maintenance fees (and 51,000 acres authorized for irrigation). The 

project is located in Fort Washakie, Wyoming on the Wind River 

Reservation, home of the Arapaho Tribe of the Wind River Reservation and 

the Shoshone Tribe of the Wind River Reservation. About 67 percent of the 

project land is owned by either the tribe or individual tribal members, and 

about 33 percent is owned by individual non-Indians. BIA currently 

estimates the project’s total deferred maintenance costs to be $84,956,546. 

See figure 16 for pictures of the Wind River Irrigation Project.

Figure 16: Pictures of the Wind River Irrigation Project (July 2005)

Key Operations and 

Maintenance Concerns 

Expressed During Our Site 

Visit

• Weeds and tree roots impair water flow and lead to seepage.

• Cattle-crossings erode canal banks and impair water flow.

• Deteriorating irrigation infrastructure impairs water delivery. 

• Additional water storage and improved efficiency needed to meet 

demand for water.

• Deferring maintenance undermines long-term sustainability of project.

• BIA financial management may limit ability of project staff to conduct 

needed maintenance in short maintenance season.

Source: GAO.

Beaver Holes and Overgrown Vegetation in Canal Cattle-Crossing Eroding Irrigation Canal
Appendix II

Profiles of the Nine Irrigation Projects GAO 

Visited

Page 50 GAO-06-314 Indian Irrigation Projects

Key Management Concerns 

Expressed During Our Site 

Visit

• BIA relies on “crisis-style” management and “band-aid” solutions rather 

than a long-term plan to manage project.

• Poor communication between BIA and water users.

• Water users are not involved enough in project decisionmaking.

• Supervision of project staff is insufficient and BIA is not accountable to 

water users.

• Turnover of BIA staff is problematic.

• Some water users want to manage all or part of the project.
Page 51 GAO-06-314 Indian Irrigation Projects

Appendix III

GAO Contact and Staff Acknowledgments ApendxiI

GAO Contact Robin M. Nazzaro, (202) 512-3841, nazzaror@gao.gov

Staff 

Acknowledgments

In addition to those individuals named above, Jeffery D. Malcolm, Assistant 

Director, Tama R. Weinberg, Rebecca A. Sandulli, and David A. Noguera 

made key contributions to this report. Also contributing to the report were 

Richard P. Johnson, Nancy L. Crothers, Stanley J. Kostyla, Kim M. Raheb, 

and Jena Y. Sinkfield. 

(360549)
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