Indian Irrigation Projects: Numerous Issues Need to Be Addressed to Improve Project Management and Financial Sustainability
Published: 2006-02-24T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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.

section_title: Letter
paragraphs: 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. In addition, problems  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.”  Furthermore, the regulations state that “close cooperation between the  Indian tribal councils, the project waters users and the Officer-In-Charge   is necessary and will be to the advantage of the entire  project.” 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  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.
subsections: section_title: Background
paragraphs: 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.  Over the years, the Congress continued to pass additional legislation  authorizing and funding irrigation facilities on Indian lands.
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.  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).
BIA’s management of the 16 irrigation projects is decentralized, with  regional and local BIA offices responsible for day-to-day operations and  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.
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.
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  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.
Federal regulations and internal BIA guidance require that BIA collaborate  with water users, both Indian and non-Indian, in managing the irrigation  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. 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 …  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. In response, BIA instituted a new financial management  system called the National Irrigation Information Management System,  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.
section_title: BIA Estimates the Cost of Deferred Maintenance at about $850 Million, but the Estimate Is Being Refined
paragraphs: 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.
subsections: section_title: In 2004, BIA Initially Estimated Completing the Deferred Maintenance Would Cost Over $1 Billion
paragraphs: 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.
BIA generally defines deferred maintenance as upkeep that is postponed  until some future time. 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.
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  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.
section_title: In 2005, BIA Revised the Estimate Downward to about $850 Million, but It Is Still a Work in Progress
paragraphs: 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. 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  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.
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  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 one- third 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.
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  Irrigation Project in July 2005, 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.
section_title: Shortcomings in BIA’s Management of Some Irrigation Projects Undermine Effective Decisionmaking
paragraphs: 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.)
subsections: section_title: In Many Cases, BIA Officials with Oversight Authority Lack Expertise, While Those with Expertise Lack Authority
paragraphs: 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  infrastructure, do not necessarily get the technical oversight or scrutiny  needed.
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  identification of potential risks to the agency in that structure.  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.
section_title: BIA Has Not Consistently Provided Information and Opportunities for Stakeholders to Participate in Setting Project Priorities
paragraphs: 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.
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.
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 non- responsive. 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.
section_title: Long-Term Direction of BIA’s Irrigation Program Depends on Resolution of a Number of Larger Issues
paragraphs: 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.
subsections: section_title: The Extent to Which Projects Are Capable of Sustaining Themselves Is Unknown
paragraphs: 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, “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.”
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  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. 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.
section_title: There Is No Plan for How to Fund the Deferred Maintenance
paragraphs: 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.  To date, BIA has primarily focused on developing and refining an accurate  estimate of the cost to fix the deferred maintenance items. While  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.
section_title: It Might Be More Appropriate for Other Entities to Manage Some or All of the Projects
paragraphs: 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.
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  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.
section_title: Conclusions
paragraphs: 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  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 long- term 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.
section_title: Recommendations for Executive Action
paragraphs: 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  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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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.
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.
section_title: Objectives, Scope, and Methodology
paragraphs: 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 project- specific 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  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.
section_title: Profiles of the Nine Irrigation Projects GAO Visited
paragraphs: 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.
subsections: section_title: Blackfeet Irrigation Project
paragraphs: 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.
subsections: section_title: Key Operations and Maintenance Concerns Expressed During Our Site Visit
paragraphs: Fees are insufficient to cover the costs of project operations and  maintenance.
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.
section_title: Key Management Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Colorado River Irrigation Project
paragraphs: 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  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.
subsections: section_title: Key Operations and Maintenance Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Key Management Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Key Operations and Maintenance Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Key Management Concerns Expressed During Our Site Visit
paragraphs: 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.
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.
section_title: Fort Belknap Irrigation Project
paragraphs: 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.
subsections: section_title: Key Operations and Maintenance Concerns Expressed During Our Site Visit
paragraphs: 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.
Deferred maintenance exacerbates problems of poor farming land and  low crop values.
section_title: Key Management Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Pine River Irrigation Project
paragraphs: The Pine River Irrigation Project is the only one of BIA’s 16 revenue- generating 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.
subsections: section_title: Key Operations and Maintenance Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Key Management Concerns Expressed During Our Site Visit
paragraphs: 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.
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.
section_title: San Carlos Indian Works Irrigation Project (Pima)
paragraphs: 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.
subsections: section_title: Key Operations and Maintenance Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Key Management Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: San Carlos Joint Works Irrigation Project (Coolidge)
paragraphs: 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.
subsections: section_title: Key Operations and Maintenance Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Key Management Concerns Expressed During Our Site Visit
paragraphs: 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.
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.
section_title: Wapato Irrigation Project
paragraphs: 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.
subsections: section_title: Key Operations and Maintenance Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Key Management Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Wind River Irrigation Project
paragraphs: The Wind River Irrigation Project was authorized for construction in 1905,  but construction was never completed. It is one of BIA’s 16 revenue- generating irrigation projects with 38,300 acres being assessed operations  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.
subsections: section_title: Key Operations and Maintenance Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: Key Management Concerns Expressed During Our Site Visit
paragraphs: 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.
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.