The BlackFalls Water Project:

Policy Findings and Recommendations

Rita Sebastian, MA: SID

The Capacity Building Initiative; HellerSchool for Social Policy; BrandeisUniversity

857-204-5653

Contributing Consultants: Ronald Tohannie; Bill Sebastian

September 30, 2009

Preface

This paper presents findings and policy recommendations resulting from the Black Falls Water Project. The project was a collaboration that began in July, 2008, between the US EPA and a coalition of families in the BlackFalls region of the Navajo Nation. The coalition was organized and supported by Forgotten People CDC (FP CDC), a community organization based in Tuba City, AZ, with guidance from an academic partner, which was the Capacity Building Initiative at the HellerSchool for Social Policy, BrandeisUniversity. The project was primarily funded from a grant from the EPA Environmental Justice Small Grants Program.

The project addressed the issues faced by families that do not have access to piped water. In particular, it examined how sanitation and safe drinking water can be provided sustainably to families who will never have access to piped water due to their remote location. Prior federal and tribal programs were mostly focused on extending the network of pipelines, so that a need existed for an effective plan to address this population. Many of the water sources previously used by the families were contaminated by uranium, so that the project also addressed health issues related to this exposure.

In the process of managing the project, the authors of this paper gained insight as to how the needs of this unique population may be effectively addressed. This data may be useful to a variety of stakeholders involved in programs to provide safe drinking water and sanitation services to off-grid families as well as the mitigation of uranium contamination on the Navajo Nation. In particular, serving this population is a key part of meeting the US commitment to reduce the number of American Indian and Native Alaskan households without access to sanitation and safe drinking water by 50% by 2015. Hopefully, some of these findings and policy recommendations will be of use to legislators as well as federal and tribal agencies that are creating the programs to meet these goals.

Contents

1. Summary of Findings and Recommendations:

1.1 Community outreach:

1.2 Water delivery:

1.3 Sanitation:

1.4 Temporary water storage system:

1.5 Health care:

2. Overview of the Black Falls Water Project

2.1 Participants in the Project

2.2 Problems faced by the water haulers

2.3 Efforts to Improve Access to Water

2.4 Access to Water as an Environmental Justice Issue

3. Community Outreach

3.1 Explanation of Findings:

3.1.1 Isolation of Population

3.1.2 Fragmentation of delivery networks

3.2 Details of Recommendations:

4. Water Delivery

4.1 Explanation of Findings & Recommendations

4.2 Costs of current delivery options

4.3 Ways to reduce delivery costs

4.3.1 Road improvements and maintenance:

4.3.2 Home Storage Tank Size:

4.3.3 Water Delivery Coops:

4.4 Demand Reduction

5. Sanitation

5.1 Explanation of Findings & Recommendations

5.1.1 Design Considerations

5.1.2 Service Model

5.2 Design of Sanitation Systems

6. Temporary Water Storage and Distribution System

6.1 Explanation of Findings & Recommendations

6.2 Construction details

6.3 System Cost Details:

7. Health Care

7.1 Medical outreach performed in the project

7.2 Explanation of Findings and Recommendations

7.2.1 Fragmentation of response and Community Outreach:

7.2.2 Training of health care providers

7.2.3. Research on uranium contamination

7.2.4. Programs to address uranium contamination of drinking water

8. Conclusion

Bibliography

Appendix :

Appendix A: Community Mapping Project

Appendix B: Project Partners and Contributors

Appendix C: Water Delivery Costs - Analysis of Data from St Bonaventure Mission

Appendix D: Water Delivery Costs - Analysis of costs to service individual homes in Black Falls

Appendix E: Cost of Supplying Water for Flush Toilets in Black Falls

1. Summary of Findings and Recommendations:

The BlackFalls project brought together technical experts, government stakeholders, and the affected families for a comprehensive and holistic examination of multiple services, including providing safe drinking water, sanitation, and uranium-related health services. The findings and recommendations are organized into five sections. The first examines the service delivery model for providing families with sanitation, drinking water, and uranium-related health services. By working intimately with the families in need of these services, this project provides a unique bottom-up view of the process through which people interface with the federal and tribal agencies providing the services. The remaining sections look at details of individual services. The second section examines how the design of sanitation systems needs to be adjusted for off-grid systems. The third covers strategies for providing cost effective and sustainable water hauling services. The fourth use of the temporary water storage system designed in the project as an immediate and economical way to provide safe drinking water to these families. The final section looks at the need to improve access to health services for families that have been exposed to drinking water containing uranium and other contaminants.

1.1 Community outreach:

BlackFalls may be typical in that the people most in need of services were not integrated into the existing mechanisms for delivering these services. The families had little contact with chapter houses or federal/tribal agencies working on the issues related to drinking water and uranium contamination. Most of the people in the community did not know what assistance was possible or how to go about interfacing with the various programs. The delivery of these services tends to be fragmented and non-transparent.These problems result from a top-down service delivery architecture in which each federal and tribal agency conducts its own outreach program, selects the beneficiaries of its services, and decides what services to provide and when to provide them.

A more effective service delivery model would use a bottom-up approach to assess the needs of each family and then use the various federal and tribal resources to meet these requirements using an integrated and holistic approach. This program would serve as the community point of presence for several related services: supplying water, uranium contamination and compensation programs, sanitation, and health care with respect to drinking water contamination. The program needs to be integrated into the inter-agency planning so that the consumer perspective is integrated into the planning process. It needs to be empowered so as to enforce the required coordination between the agencies providing the various services. It needs to be adequately financed so as to enable the delivery of the required services to all the families in the affected population.

In the Navajo Nation, the chapter houses typically serve as a facilitator for community services. While the chapters could work closely with this program, the program needs to be independently staffed and managed. Operation of the program requires in-depth familiarity with many different agencies and technical issues, and the chapter staffs can not be expected to fill this role. The program forms the centerpiece of an integrated and efficient means of service delivery spanning multiple federal and tribal agencies as well as a way to empower the local communities and chapter houses in the achievement of environmental justice.

1.2 Water delivery:

The recent grant from the EPA to the Navajo Department of Water Resources to support a pilot water delivery program is a positive step toward providing assistance to families that will never be able to be connected to pipelines because of their remote location. A program to deliver water using 2000+ gallon tankers may be able to solve the problem for families in close proximity to the maintained roads. The more remote families face additional challenges. Many of these homes can not be reached by tanker trucks unless road repairs are performed and ongoing road maintenance is provided. For one home in BlackFalls, the access is currently so difficult that it can not be reached using a pickup truck carrying more than 100 gallons of water.

Recommended approaches for addressing the needs of the more remote homes include:

  • Develop sustainable strategies for maintaining access roads to remote homes.
  • Install the temporary home storage systems described in section 6, as the savings in delivery costs from the increased storage capacity can pay for the system cost within a year.
  • Demand reduction strategies - the amount of water that needs to be hauled can be reduced by appropriate design of sanitation systems and off-loading consumption to more accessible locations such as micro-small washeterias with showers and other facilities.
  • Explore alternative delivery approaches that can reduce delivery costs, such as the use of coops to reduce labor costs.

The community outreach program discussed in section 3 would enhance the effectiveness of the water hauling service by providing monitoring and evaluation of the program, as well as cost-effective outreach and integration with other services.

1.3 Sanitation:

The experience at BlackFalls identified two problems with respect to the deployment of sanitation systems in communities similar to BlackFalls. The first issue is that the current designs are poorly suited for families that have to haul water. For example, the cost of hauling water for a flush toilet in some extreme cases can exceed $5000/year, and neither the families nor the Navajo Nation have the resources to sustain this cost on a long term basis. Local U.S. Indian Health Service (IHS) engineers have to work within requirements defined by the national office which did not take these challenges into consideration.

To solve the first issue, the national IHS should provide funding and support for innovative designs that can provide sustainable and healthy solutions at reasonable costs for water haulers. A program should deploy test installations to evaluate the costs, operation, and sustainability for multiple competing designs. Furthermore, the sanitation designs for each family need to be worked out using an integrated strategy that looks at the short and long term options for water delivery .

The second issue is that the service delivery network for sanitation is fragmented and non-transparent. Families have to interface separately with multiple agencies for different components such as plumbing, infrastructure, and funding. The point of contact and process for each agency is not advertised, and once they have applied for services a family receives little feedback about the status of their case. The proposed community outreach program would help address these issues.

1.4 Temporary water storage system:

During the BlackFalls water project, local residents designed and deployed a temporary water storage system using an elevated external water storage tank and kitchen sink. The tank provides high-capacity storage as needed to support efficient water delivery services and replaces the unsafe system of buckets currently in widespread use. The system can provide an immediate and low cost means to provide safe access to drinking water to a large population. Minimal training is needed to perform the on-site work, so that rapid up-scaling can be achieved using local labor. Deployment of the systems links the people into the provider network for health care, water delivery, and other related services. The system design is well suited for deployment via a community cooperative approach, which can reduce cost, improve sustainability, and further enhance the integration of families into the service provider network.

1.5Health care:

The BlackFalls project identified several problems in the health care services provided to families where the drinking water may be affected by uranium and other contaminants:

  • Fragmentation of the response: research, treatment, training of health care providers, and community outreach tend to be provided by separate agencies without adequate integration
  • Training of local health care providers training has begun, but is at an early stage and lacks fundingas well as monitoring and evaluation.
  • Research on the impact of drinking uranium contaminated drinking water is incomplete, and little has been done on issues such as consumption of contaminated livestock.
  • No programprovides compensation and treatment for uranium contamination of drinking water in the same way as programs for down-winders and miners.
  • Little community outreach has been done. For example, prior to the project, none of the families in BlackFalls had ever been screened for uranium issues or asked by a physician about their water supply.

Recommendations include providing more funding for these programs and using the funding to create a higher level of service integration. In particular, the community outreach needs to be increased and a unified point of presence established for these services.

2. Overview of the BlackFalls Water Project

The project was part of an effort to provide safe drinking water to communities in the former Bennett Freeze area on the Navajo Reservation. Over 90% of the homes in this area do not have access to piped water, so that the families must haul their water from other locations (HR5168, 2004). While health risks exist in the storage and transportation methods, the main concerns are the sources being used. While some regulated sources are available, thousands of unregulated water sources (EPA01) are also used on the reservation. These are subject to a variety of chemical and bacteriological contaminants, but most attention was focused on uranium contamination. While this can occur from natural sources, the major threat was contamination arising from the legacy of uranium mining in the region. Resolving that specific threat required a comprehensive solution to providing safe water supply systems for the communities, and this in turn was complicated by the other developmental issues affecting the communities, such as inadequate housing, roads, and poverty. Because the environmental harm was impacting minority communities, the developmental problems were treated as an Environmental Justice issue by the federal government.

While initially funded as a planning grant, the project expanded using additional private donations to include the construction of water storage and distribution systems for 10 homes, creation of a community water hauling service, and working with both the EPA and Indian Health Service (IHS) to design sanitation systems for the homes. A map of the community showing the locations of homes, water sources, and abandoned uranium mines is provided in Appendix A. The interactive map is available on-line at

A more detailed key to the map can be accessed at:

The completion of the construction and launching of the water hauling service was celebrated in a ribbon-cutting ceremony on February 24, 2009 attended by representatives of the partner agencies as well as representatives of the Navajo Nation. In June, 2009, the project received an Environmental Excellence award from the Navajo Nation EPA.

2.1 Participants in the Project

The Black Falls Water Project was a collaboration between government, grassroots, and academic partners:

Forgotten People Community Development Corporation (FP CDC) is a grassroots organization representing communities in the western half of the Navajo Nation. The communities are spread over almost 2 million acres of remote desert terrain in the northeast of Arizona. From 1966 through 2007, the communities were subject to the Bennett Freeze, which was issued by Bureau of Indian Affairs Commissioner Robert Bennett and prevented constructing or repairing homes, water supplies, roads, and other facilities on land that was subject to a land dispute with the Hopi Tribe. President Obama signed a law officially lifting the Bennett Freeze on May 8, 2009.

The EPA is involved in a major effort to improve access to safe water on the Navajo Nation as a result of two pressures. The first is a commitment made by the EPA at the 2002 United Nations World Summit on Sustainable Development held in Johannesburg, South Africa, in which the US pledged to reduce the number of its citizens lacking access to safe drinking water and sanitation by 50% by 2015 (US 01, 2002). The largest concentration of such people was on the Navajo Nation, especially in the communities served by FP CDC. The second is pressure by Congress for the EPA to redress problems resulting from the legacy of uranium mining in the 1950s and 60s. The EPA has identified 520 abandoned uranium mines and the leeching of uranium from the slag piles into drinking water supplies is damaging water supplies (McSwain, 2007). In Congressional hearings, Chairman Henry Waxman, D-Calif., decried the lack of work on restoring the land on the Navajo reservation.

If a fraction of the deadly contamination the Navajos live with every day had been in Beverly Hills or any wealthy community, it would have been cleaned up immediately. But there's a different standard applied to the Navajo land... To one of the Chairman's questions, your answer was, we need time. I can understand that, but while time passes, Mr. Nastri, people get sick, people die, people develop kidney disease, children, babies are born with birth defects, bone cancer develops and gets worse, lung cancer, leukemia, while we wait (Waxman, 2008, 65).

The project manager was from the Capacity Development Initiative from the HellerSchool for Social Policy at BrandeisUniversity. The HellerSchool teaches a participatory "bottom-up" model for community development in which the directly affected people play a central role in every aspect of a development project from the initial needs assessment through the final monitoring and evaluation. This approach was used for the project. In weekly meetings, the families developed their strategy, designed the home water system, and developed relationships with partners based on finding solutions to achieving shared objectives. This model was new to the federal and tribal partners, and an analysis of the approach can be found in "Assisting The Water Haulers: Using Grassroots Driven Development to Secure Environmental Justice" available at