Building Better Data for Tribal Communities
Pathways to Better Data
Our recommendations are grounded in our belief that Tribal communities should have access to safe, reliable, and affordable drinking water. At a minimum, this requires fully funding drinking water infrastructure, operations, and maintenance that Tribes have long been owed.
If Tribes are not reflected in the data, they’re not reflected in the solutions. Just as the federal government has a trust responsibility to provide drinking water to Tribal citizens, the federal government has a trust responsibility to provide Tribes with relevant data and analysis tools that are useful, accurate, and consistent with Tribal data sovereignty.
We have identified two desirable outcomes based on our research: Tribes are better equipped to make decisions based on data that reflects their needs; and data users are educated about the limitations of publicly-available Tribal drinking water data. We have identified two pathways and associated key actions that will lead to these outcomes:
Bridging the data gap: We have disparate datasets and tools, and they aren’t meeting Tribal priorities, but through Tribally-led initiatives, we can put the pieces together to bridge the data gap. Our recommendations identify opportunities that rely on data sovereignty frameworks to use existing data, collaborative models, technology, and data sharing to build better Tribal drinking water data.
Knowledge building: Outside of Indian country, the particularities of Tribal governance can get missed in national-scale drinking water research. Data collection systems miss pertinent factors, data descriptions omit the limitations of Tribal data, and, ultimately, research and policy recommendations don’t serve Tribal priorities.
Action to bridge the data gap and build knowledge can mitigate the cascading effects of data limitations and contribute to a more accurate picture of water access gaps, better data analysis tools, and better research.
Choose a pathway to explore more
Bridging the data gap
There is a moral and legal imperative to ensure Tribal communities have access to high-quality data and analysis tools to improve drinking water access. Luckily, we already have the infrastructure, technology, and collaboration models to build high-quality, impactful datasets and tools for Tribal drinking water leaders, advocates, and researchers. Here, we lay out key actions to bridge the data gap and identify helpful reports, frameworks, and case studies to act.
There is a moral and legal imperative to ensure Tribal communities have access to high-quality data and analysis tools to improve drinking water access. Luckily, we already have the infrastructure, technology, and collaboration models to build high-quality, impactful datasets and tools for Tribal drinking water leaders, advocates, and researchers. Here, we lay out key actions to bridge the data gap and identify helpful reports, frameworks, and case studies to act.
Key action #1: Build datasets and tools that meet tribal priorities
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A Tribally-led collaboration could include federal agencies and other partners with Tribal data expertise. The collaboration could link federal data, Tribal data, and could embed the principles of data sovereignty in how the datasets are linked and how data tools are shared with Tribes.
This could offer a pathway for linking confidential IHS data with EPA’s data, and could also help ensure Tribes have access to data they report to federal agencies that is so often inaccessible.
This collaboration would also be a mechanism for answering Tribal drinking water data questions, and for creating data analysis tools that meet Tribal needs. If desired by Tribes, a regional collaboration could be used to understand drinking water access across multiple Tribes.
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Depending on Tribal priorities, these data could be linked for Tribal use, without necessarily being shared back with federal agencies.
Tribes may want to voluntarily share additional data with federal agencies, but are unable to do so because federal agencies are unable to guarantee the protection of that data due to public records laws. Tribally-led collaborations could be designed to include this layer of protection.
With IHS as a partner, IHS STARs is a functional data system which already provides for Tribal data protection, and could be used to house linked databases and associated tools. However, other potential partners, such as Tribal Epidemiology Centers, which already coordinate data collation from federal agencies for the Tribes they serve and may have existing data sovereignty infrastructure to link and share these data with Tribes.
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Regardless of whether data is shared back with federal agencies, linking data can also improve the validity of each source dataset. Live data links between SDWIS, STARS, and Tribal data could be used to alert Tribes and IHS to monitoring and compliance issues and to understand trends. Additionally, if desired by Tribes, IHS HITS data could be used to improve the SABs dataset, and to show where there are gaps in water provision, and where people are served by unregulated water systems.
Your tools for change
We highlighted ideas that came up during our interviews and literature review for opportunities for Tribally-led data initiatives. See here.
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After struggling for decades against limitations on their sovereignty, the Passamaquoddy Tribe won a fight to govern Tribal drinking water, with the help of a Tribally-led community monitoring initiative.
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California Water Board worked with California Tribes to identify their water data needs and to develop the Tribal Water Data Map, which “includes curated data layers that have been requested by California Native American Tribes and tribal partners doing environmental or water related work.”
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While preparing a statewide needs assessment, the state of California sought to address the tribal water system data gap through a partnership “with US EPA, Indian Health Services, Rural Community Assistance Corporation, and the Department of Water Resources to host a series of workshops to build stronger partnerships with tribes.”
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After facing barriers to fundraising due to a lack of water quality data acceptable to grantors, leaders of the Apsaálooke Water and Wastewater Authority (AWWWA) worked with academic partners to identify challenges and opportunities to address drinking water disparities on the Crow Reservation and followed community-based participatory research (CBPR) framework to ensure the Tribal community would own the research effort, while also building a collaboration to access the capacity necessary to carry it out in the long term.
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Urban Indian Health Institute is a Tribal Epidemiology Center, and collated data to create data dashboards to help data users understand health trends among urban Native communities.
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An evaluation of Tribal population data and the problems that arise from external ownership of Tribal data.
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This Council of State and Territorial Epidemiologists toolkit is a useful guide for data sharing between Tribal health authorities and states and includes mechanisms and case studies.
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The Washington State American Indian Health Commission published a data sharing agreement checklist for state agencies to use, which may be helpful for other states as well.
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Tribal Epidemiology Centers (TECs) are public health authorities, “and may be granted access to public health information held by the HHS for public health activities like surveillance, investigations, and interventions.” Twelve TECs serve Tribes regionally nationwide to support the public health needs of individual Tribes. Initiatives taken on by individual TECs are driven by Tribal need, and the capacity and focus of each is different. TECs provide technical support to Tribes, coordinate with federal agencies to fill Tribal data requests, and support Tribes through the development of data analysis tools.
HHS published a policy to improve data sharing with Tribes and Tribal Epidemiology Centers, which included provisions for improving IHS data validity and for more efficiently responding to Tribal requests for data.
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The Tribal Exchange Network (TXG) is a USEPA Tribal Partnership Group that provides free services to Tribes to support “tribal management, analysis, and sharing of environmental data.”
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“The National Tribal Water Council (NTWC) is a technical and scientific body created to assist the EPA; federally recognized Indian tribes, including Alaska Native Tribes; and their associated tribal communities and tribal organizations with research and information for decision-making regarding water issues and water-related concerns that affect Indian and Alaska Native tribal members, as well as other residents of Alaska Native Villages and Indian country in the United States.”
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The Global Indigenous Data Alliance recommends that data management and stewardship in research with Indigenous communities adheres to the CARE and FAIR principles, outlined here.
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The Collaboratory for Indigenous Data Governance includes helpful resources to guide the development of data sharing models that are aligned with the principles of Tribal data sovereignty.
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In 2024, the Census Bureau and Osage Nation entered into an agreement to share data to improve Census data for the Tribe. More details can be found here, and though the agreement is not public, it could be a model for data sharing between Tribal Nations and federal agencies.
Existing federal datasets could be improved by linking EPA and IHS data to improve data validity and make datasets more robust. Recognizing that EPA and IHS already collaborate with each other, improved data links could be developed explicitly for the benefit of Tribal data users (Tribal staff and leaders). Considerations for such an effort include:
Key action #2: Link IHS and EPA datasets for Tribally-led research
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Depending on the direction in which data is shared and on the level of specificity, data sharing could offer benefits for EPA and/or IHS, and for Tribes.
IHS STARS is an incredibly accurate and specific dataset, capturing drinking water access data at the household level, within and outside of Tribal lands. STARS can be linked with EPA SDWIS data and, if improved, EPA SABs data, using PWSIDs to generate a body of data that is incredibly comprehensive, granular, and accurate.
If desired by Tribes, SABs data could be improved (see Key action #3) and could then be used to identify and fix discrepancies in SDWIS data for systems serving Tribes and could be used to support Tribes in understanding well use on Tribal lands.
SDWIS, SABs, and STARS data could all be linked using PWSIDs to improve IHS STARS data and identify water access gaps. Many homes included in IHS STARS are likely not (in reality or in the data) associated with any PWSID because they lack piped water–linking these data can capture these gaps. Additionally, linking IHS data systems to SDWIS to generate live updates could more quickly alert IHS to sanitation deficiencies and help decisionmakers accurately prioritize projects.
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It’s important to consider the fact that IHS sanitation data is private and confidential, and that sharing data externally will be subject to data confidentiality and may only be possible at the aggregate level. New datasets could be generated to maintain this confidentiality by relying on existing IHS infrastructure. Analysis tools using a comprehensive dataset generated from IHS and EPA data could better capture Tribal access needs and be used to inform Tribal decision making.
Key action #3: Link IHS and EPA data collection efforts
IHS and EPA already collect a large amount of data, which some past assessments have identified as duplicative. Improved data linkages between IHS and EPA–where consistent with Tribal data sovereignty and protection principles–could reduce duplicative data collection efforts, limiting burden for agency and Tribal staff alike. EPA and IHS could collaborate to develop a standard survey and evaluation instrument to ensure that data collected by IHS to to develop Community Deficiency Profiles could inform the EPA sanitary survey process and vice versa. EPA sanitary surveys are conducted every 3-5 years for every water system under its implementation and enforcement authority. Tribally-led collaborations between Tribes, EPA, and IHS also provide an opportunity for agencies to refine data collection efforts to ensure that data collections systems and processes are able to capture the reality of Tribal drinking water data and limit burden for Tribal staff.
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In 2024, IHS and the Bureau of Reclamation signed an MOU to collaborate to improve the provision of safe drinking water for Indian homes and communities. The MOU included a stipulation for IHS data sharing to support Bureau of Reclamation service provision.
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The Federal Infrastructure Task Force (ITF) was established in 2007 to “develop and coordinate federal activities in delivering water infrastructure, wastewater infrastructure and solid waste management services to tribal communities.” The current MOU, approved in 2022, is applicable to USDA, HUD, HHS, DOI, and EPA and governs a cooperative system to share data.
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In 2016, the ITF produced a report on improving open dump data on Indian lands, which assessed data quality and outlined proposals to improve IHS and EPA data coordination processes.
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This 2018 study by the Government Accountability Office includes crucial context and recommendations for improving federal agency coordination for Tribal drinking water and wastewater infrastructure projects (many of which have since been implemented).
Your tools for change
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This 2008 report by the ITF describes strategies for addressing barriers to Tribal drinking water access. It is outdated, but provides useful context.
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This 2011 EPA report identifies pathways and barriers to linking EPA and IHS data.
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The IHS SDS Guide includes descriptions of how the SDS works and is useful for identifying data entry challenges and understanding how SDS works.
Key action #4: Improve IHS processes to improve the STARS database
IHS maintains the most comprehensive and accurate national-scale Tribal drinking water data. Considerations include:
Limits in IHS funding mean that there are still inaccuracies and that not all projects get added–particularly those that are not as far along in the planning process.
Other researchers have recommended that “IHS should continue to identify additional eligible AI/AN homes that may have existing deficiencies to include in HITS and ensure that HITS accurately reports the current deficiency level of an identified home. The IHS database could also be improved by revising data collection to include metrics related to affordability and water system financial capacity.”
Your tools for change
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This report by the Tribal Clean Water Initiative includes recommendations for federal agency reforms and describes how IHS eligibility impacts the data it collects and the communities who miss opportunities for IHS funding.
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This 2008 report by the ITF describes strategies for addressing barriers to Tribal drinking water access, including IHS data limitations. It is outdated, but provides useful context.
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The IHS SDS Guide includes descriptions of how the SDS works and is useful for identifying data entry challenges and understanding how SDS works.
Key action #5: Consider a new EPA SDWIS typology
As it is, EPA’s SDWIS data and Tribal indicators can’t accurately capture the full world of Tribal drinking water access. EPA could consider developing a new classification scheme for SDWIS with the following considerations:
If EPA does this, Tribal consultation must be meaningful and extensive. Tribes have been left behind in environmental regulation for far too long. In this consultation, EPA should work to understand Tribal priorities in data collection, research, and analytics tools and should ensure that any new system is able to meet these needs.
The Drinking Water State-Federal-Tribal Information Exchange System project must include Tribal leadership in its core development teams–meaning someone who works for a Tribal government or has extensive experience working for a Tribal government on drinking water service provision.
This new classification system could allow for disaggregation by Tribal government owner category–which is what researchers attempted to do in this study.
We heard repeatedly that SDWIS data should better capture infrastructure age and operations and maintenance (O&M) Data. While that was outside the scope of our deeper research, this is also something EPA should consider in any redesign.
This is particularly important for Tribal systems, where O&M funding is extremely limited, incentivizing system failure, which will qualify a project for funds more quickly (and at a higher cost) than maintaining a system. Better data would help Tribes and partners better tell this story.
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We tentatively agree with this proposed typology, which would recode the “Native American” owner category as “Tribal entities” under the “Government” category as “Tribal Nation governments.” This category would capture Tribally-operated systems that provide water as a public utility and are “publicly owned” by that government. Systems would be included in this category regardless of whether the Tribe, EPA, or state has primacy. This could solve some of the issues we noted in our analysis of existing research, but EPA should consider a more extensive categorization system for Tribal systems during Tribal consultation.
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Researchers attempted to do novel research to understand how governance impacts SDWA implementation on Tribal lands–research that could help Tribes address real drinking water access barriers, but the Native American owner category in SDWIS does not allow for disaggregation at the needed level.
Your tools for change
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After facing barriers to fundraising due to a lack of water quality data acceptable to grantors, leaders of the Apsaálooke Water and Wastewater Authority (AWWWA) worked with academic partners to identify challenges and opportunities to address drinking water disparities on the Crow Reservation.
Knowledge building
Key action #1: Educating data users and building a shared vocabulary
Data users, particularly non-Tribal data users who hope to research Tribal drinking water or develop policy recommendations should refer to this resource.
Key action #2: Improve data limitation descriptions
Tribes face some of the most complex challenges when it comes to how drinking water data is reported to EPA, and Tribal data should be described accurately to data users.
EPA Service Area Boundaries dataset
EPA should more clearly describe Tribal data limitations in the Service Area Boundaries dataset. This includes edits to the existing descriptions of Tribal data and should be augmented by a more in-depth description of Tribal data and its limitations that could be included in the state-by-state data review document, in the fact sheet, in the EPA Water System Service Area Technical Documentation, or in a new SABs Tribal data caveats document. We recommend this include:
A description of how Tribes were accounted for in the models;
A description of why Tribal data would not typically come from states (see discussions of data sovereignty and primacy), and whether Tribes or EPA (or states) reported any Tribal SABs directly; and
A discussion of the ways in which EPA-identified SABs data limitations likely disproportionately impact Tribal lands.
EPA SDWIS Dataset and Tools
EPA could begin by updating data dictionaries to ensure uniformity, thoroughness, and accuracy, particularly for the multiple Indian country indicator definitions (here, here, and here), the Native American owner category, and the Tribe Name filter.
Data caveats related to the SDWA Indian country indicator should be part of a broader effort to ensure that data caveats for Tribal data across datasets are always provided, beyond just the Tribal Lands Data Quality Caveat.
EPA could work to identify where the SDWA Indian country indicator diverges from the Tribal filters of other EPA data systems (like the FRS, the RCRA, etc.) and make corrections where necessary and provide clear data caveats and descriptions where necessary.
Mind the Gap: What Data Users Should Know
Tribal Data Sovereignty
Tribes have the right to own, steward, and govern their data. The data sovereignty movement includes calls for data protection and for the inclusion of Tribal needs and priorities in federal data collection and report-back processes. A growing body of Tribal laws govern data sharing with researchers. With regard to publicly-available data provided by federal agencies, none of the data is necessarily accurate or validated by tribes and researchers should respect Tribal data sovereignty by reproducing data only with Tribal permission.
When seeking data, respect Tribal data sovereignty–Tribes do not need to share their data, and any agreements and research efforts should embed the principles of data sovereignty. For state policymakers, this Fact sheet on State and Tribal data sharing might be helpful.
When reading research, you should know that:
Researchers generally lack a shared definition for “Tribal drinking water systems,” and the definitions may pull from different data sources and capture different populations and lands. Secondary research should be double-checked, as it may inaccurately conflate different definitions. If you are working on policy research, know your terms, and pay attention to how researchers’ definitions pertain to the policy levers available to Tribal governments.
When determining which Tribal drinking water data to use, researchers should:
Do their best to understand datasets and terms in the context of Tribal drinking water jurisdiction, data collection geographies, Tribal boundaries, and ensure that this data is the best dataset to answer their research questions. It’s important to remember that, while Tribal data in SDWIS can seem convenient, it doesn’t necessarily lend itself to broad policy conclusions. Consider whether this research question might better be answered by Tribal data and through direct collaboration with Tribes.
Do their best to understand how accurately this data reflects Tribal priorities. Some helpful questions:
Did Tribes share or consent to sharing this data?
Did Tribes validate this data?
Before using EPA data, you should know that:
EPA Tribal drinking water data in the SDWIS dataset and in the SABs dataset has inaccuracies–it sometimes lacks term definitions and meaningful data caveats, and does not always accurately capture the full world of Tribal drinking water data.
Explore the EPA data yourself, and check out our suggestions for additional Facility Search filters that might capture additional drinking water systems that serve Tribal lands.
Before using IHS data, you should know that:
IHS STARS is considered the best data source to characterize drinking and waste water access in American Indian and Alaska Native communities. However, it is confidential, available only to Tribes, with limited access for other federal agencies. The only publicly-available IHS STARS data is in IHS’ annual report to Congress, reported on aggregate.
Read more about IHS programs and geographies, the IHS data landscape and its implications for Tribes or explore the IHS data yourself.
Before using Census data, you should know that:
Census data has historically undercounted American Indians and Alaska Natives, especially on Tribal lands.
Tribal Priorities in Research
Consider how your data selection and research question will reflect Tribal priorities. This is done best when working in collaboration with Tribal governments. EPA, IHS, and Tribal data all differently reflect Tribal drinking water access. First, with an eye toward political levers, you might think about tribal drinking water data in terms of Tribal jurisdiction under SDWA. But analysis could expand beyond those boundaries, to the watershed, and places where Tribal citizens may live, work, go to school, or ancestral lands that are important for ceremony or treaty rights.
If you find errors in federal datasets:
If you find errors in the U.S. Census Tribal boundary dataset, you can reach out to the Census Bureau to request corrections–find instructions here.
EPA datasets
For the Service Area Boundaries dataset, you can find EPA contact information on the FAQ webpage, under “I see an error in this dataset, who do I contact to correct it?”.
For other EPA data, including errors in SDWA, ECHO, and on Detailed Facility Reports, you can follow the directions here.