Clean Water Act: Nine States' Experience With the Clean Water State
Revolving Fund (Stmnt. for the Rec., 04/23/97, GAO/T-RCED-97-152).

GAO discussed selected states' experience with the Environmental
Protection Agency's (EPA) Clean Water State Revolving Fund program,
focusing on: (1) the amount of funds lent and the percentage of
available funds lent, as of the end of each state's fiscal year 1996;
and (2) information on factors at the federal and state levels that
constrained the amount and percentage of funds lent.

GAO noted that: (1) the nine states increased the total amount of funds
they lent from $3.3 billion in 1995 to $4.0 billion in 1996; (2) all
nine states increased the amount they lent by 15 percent or more, and
three states achieved increases of 30 percent or more; (3) in addition,
seven of the nine states increased the percentage of available funds
they lent; (4) of these seven, three states increased this proportion by
17 percentage points or more; (5) nevertheless, the percentage of funds
lent as of the end of 1996 varied substantially among the nine states;
(6) specifically, five states had lent 80 percent or more of their
available funds, three states had lent between 70 and 79 percent, and
one state had lent 60 percent; (7) in eight of the nine states,
officials identified the expiration of the authorizing legislation, as
well as federal requirements, as affecting the amount and percentage of
funds lent; (8) for example, officials in seven states said the
legislation's expiration created uncertainty about the loan conditions
that might apply in the future and caused some communities to postpone
seeking or accepting loans; (9) also, officials in seven states said
that other federal requirements, such as a prevailing-wage provision,
discouraged some communities from seeking loans; and (10) finally, in
two states, officials said that state program decisions constrained
lending.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  T-RCED-97-152
     TITLE:  Clean Water Act: Nine States' Experience With the Clean 
             Water State Revolving Fund
      DATE:  04/23/97
   SUBJECT:  Grants to states
             Loans to localities
             State-administered programs
             Revolving funds
             Wastewater treatment
             Intergovernmental fiscal relations
             Water pollution control
             Funds management
             State/local relations
IDENTIFIER:  EPA Clean Water State Revolving Fund Program
             EPA Construction Grants Program
             Arizona
             Florida
             Illinois
             Louisiana
             Maryland
             Missouri
             Oregon
             Pennsylvania
             Texas
             
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Cover
================================================================ COVER


Before the Subcommittee on Water Resources and Environment, Committee
on Transportation and Infrastructure, House of Representatives

For Release
on Delivery
Expected at
2 p.m.  EDT
Wednesday
April 23, 1997

CLEAN WATER ACT - NINE STATES'
EXPERIENCE WITH THE CLEAN WATER
STATE REVOLVING FUND

Statement for the Record by
Stanley J.  Czerwinski, Associate Director,
Environmental Protection Issues,
Resources, Community, and Economic
Development Division

GAO/T-RCED-97-152

GAO/RCED-97-152T


(160397)


Abbreviations
=============================================================== ABBREV

  EPA -
  SRF -

============================================================ Chapter 0

Mr.  Chairman and Members of the Subcommittee: 

We appreciate the opportunity to present this statement for the
record, which discusses selected states' experience with the
Environmental Protection Agency's (EPA) Clean Water State Revolving
Fund (SRF) Program.  In 1987, the Congress authorized the creation of
state revolving funds to help local governments and others construct
projects to improve water quality and thereby help safeguard public
health and the environment.\1 All 50 states and Puerto Rico have
established such revolving funds, and through fiscal year 1996, the
Congress provided more than $11 billion to them. 

Through this program, the federal government provides annual grants
to the states as "seed money" to help capitalize their revolving loan
funds.  The states use their revolving funds to make loans to local
governments and others; as the loans are repaid, the funds are
replenished, and additional loans can be made.  In December 1996, we
issued a report on nine states' use of their revolving funds,
including (1) the amount of funds lent and the percentage of
available funds lent, as of the end of each state's fiscal year 1996
and (2) information on factors at the federal and state levels that
constrained the amount and percentage of funds lent.\2

This statement is based on that report. 

In summary, we found: 

  -- The nine states increased the total amount of funds they lent
     from $3.3 billion in 1995 to $4.0 billion in 1996.  All nine
     states increased the amount they lent by 15 percent or more, and
     three states achieved increases of 30 percent or more.  In
     addition, seven of the nine states increased the percentage of
     available funds they lent.  Of these seven, three states
     increased this proportion by 17 percentage points or more. 
     Nevertheless, the percentage of funds lent as of the end of 1996
     varied substantially among the nine states.  Specifically, five
     states had lent 80 percent or more of their available funds,
     three states had lent between 70 and 79 percent, and one state
     had lent 60 percent. 

  -- In eight of the nine states, officials identified the expiration
     of the authorizing legislation, as well as federal requirements,
     as affecting the amount and percentage of funds lent.  For
     example, officials in seven states said the legislation's
     expiration created uncertainty about the loan conditions that
     might apply in the future and caused some communities to
     postpone seeking or accepting loans.  Also, officials in seven
     states said that other federal requirements--such as a
     prevailing-wage provision--discouraged some communities from
     seeking loans.  Finally, in two states, officials said that
     state program decisions constrained lending. 


--------------------
\1 The program was established in the 1987 amendments to the Federal
Water Pollution Control Act, also known as the Clean Water Act.  It
was authorized through 1994.  Since then, the Congress has continued
to fund the program with annual appropriations. 

\2 Clean Water Act:  State Revolving Fund Loans to Improve Water
Quality (GAO/RCED-97-19, Dec.  31, 1996). 


   BACKGROUND
---------------------------------------------------------- Chapter 0:1

In 1972, the Congress established the Construction Grants Program to
provide grants to help local governments construct wastewater
treatment facilities.  These federal grants provided most of the
funding for these projects, with the remainder provided by the local
government constructing the project.  In 1987, the Congress began to
phase out that program and authorized the creation of SRFs, which
provide loans to local governments and others. 

The states are required to match SRF capitalization grants at a rate
of at least one state dollar for every five federal dollars.  The
states have the option of increasing the amount of SRF funds
available to lend by issuing bonds guaranteed by the money in the
SRFs.  According to a national survey, as of June 30, 1995 (the
latest data available), the states collectively had $18.9 billion in
their SRF accounts; over one-half of this amount (approximately $11
billion) was provided by federal capitalization grants.\3 (The
appendix provides additional information on the nine states' sources
and uses of funds.)

For the most part, the Congress gave the states flexibility to
develop SRF loan assistance programs that meet their particular
needs.  However, the states must ensure that the projects funded with
loans issued up to the amount of the federal capitalization grants
meet two types of federal requirements.  The first type includes
those contained in the various statutes that apply generally to
federal grant programs.  These requirements--also called
"cross-cutting" authorities--promote national policy goals, such as
equal employment opportunity and participation by minority-owned
businesses.  The second type applies various provisions applicable to
the Construction Grants Program (known as title II requirements
because that program was authorized by title II of the Federal Water
Pollution Control Act Amendments of 1972).\4 These include compliance
with the federal prevailing-wage requirement.\5 The title II
requirements apply only to those projects wholly or partially built
before fiscal year 1995 with funds made directly available by federal
capitalization grants. 

The transfer of federal funds to SRFs begins when the Congress
appropriates funds annually to EPA.  EPA then allots capitalization
grants to the individual states, generally according to percentages
specified in the Clean Water Act.\6 To receive its allotment, a state
has up to 2 years to apply for its capitalization grant.  In order to
apply, a state must, among other things, propose a list of potential
projects to solve water quality problems and receive public comments
on that list.  After completing the list and receiving its
capitalization grant, a state generally has 2 years to receive
payments of the grant amount (via increases in its letter of credit). 
After each such increase, a state has up to 1 year to enter into
binding commitments to fund specific projects.  Next, a binding
commitment is typically converted into a loan agreement. 

We collected detailed information on the use of revolving funds by
nine states with SRF programs--Arizona, Florida, Illinois, Louisiana,
Maryland, Missouri, Oregon, Pennsylvania, and Texas.  We selected
these states because they provide diversity in terms of the size and
complexity of their SRF programs and other factors, such as
geographic location.  However, the conditions in these states are not
necessarily representative of the conditions in all 51 SRFs. 

We used a questionnaire and follow-up discussions to collect
information on SRF activities and finances from program officials
from the nine states.  We also interviewed EPA headquarters and
regional officials who are responsible for the SRF program.  We did
not attempt to independently verify the information collected from
EPA or the states. 

The data cited in this statement are as of the end of the applicable
state's fiscal year or the federal fiscal year, as appropriate.  In
seven of the nine states, the state fiscal year ends on June 30; in
Texas, it ends on August 31; and in Florida, it ends on September 30,
which is also the end of the federal fiscal year. 


--------------------
\3 Between 1992 and 1995, the Ohio State Water Development Authority
annually surveyed all 50 states and Puerto Rico on certain aspects of
the SRF program.  See State Revolving Loan Fund Survey - 1995, Ohio
Water Development Authority, Council of Infrastructure Financing
Authorities Monograph No.  8, May 1996. 

\4 For a more detailed description of the cross-cutting and title II
requirements, see Water Pollution:  States' Progress in Developing
State Revolving Loan Fund Programs (GAO/RCED-91-87, Mar.  19, 1991). 

\5 Federal law requires that workers on covered projects be paid the
prevailing wage.  The prevailing wage is defined as the wage paid to
the majority of the workers in the job classification on similar
projects in the same geographic area.  For additional information on
issues related to prevailing-wage rates, see Davis-Bacon Act: 
Process Changes Could Raise Confidence That Wage Rates Are Based on
Accurate Data (GAO/HEHS-96-130, May 31, 1996). 

\6 The 1987 amendments specified percentages for the 50 states, the
District of Columbia, and seven other jurisdictions.  As some of
these other jurisdictions--such as Palau--have gained independence
since 1987, they lost their entitlement to SRF funds.  Their shares
of the funds are allocated among the states and other jurisdictions
that remain eligible for funds. 


   AMOUNT AND PERCENTAGE OF FUNDS
   LENT GENERALLY INCREASED
---------------------------------------------------------- Chapter 0:2

The overall amount of funds lent by the nine states increased between
1995 and 1996, from $3.3 billion to $4.0 billion.  The amount lent by
each state also increased.  During the same time period, seven states
increased their percentage of funds lent, and two states maintained
or decreased their percentage of funds lent.\7

All nine states increased the amount of funds they lent between 1995
and 1996.  Six states increased their amount by 15 to 29 percent. 
For example, Pennsylvania increased the amount lent by 17 percent,
from $267 million to $311 million.  The other three states increased
their amount of funds lent by 30 percent or more.  The largest
change--95 percent--was in Arizona, which increased from $50 million
to $99 million. 

Seven of the nine states increased their percentage of funds lent
between 1995 and 1996.  Three states increased their percentage by 17
percentage points or more.  Four other states increased theirs by 2
to 9 percentage points.  Finally, one state's percentage stayed the
same, and another state's declined by 2 percentage points. 

Among the nine states, the percentage of funds lent at the end of
1996 ranged from 60 to 99 percent.  Specifically, five states lent 80
percent or more of their available funds, another three states lent
70 to 79 percent, and the final state lent 60 percent. 


--------------------
\7 It is possible for the amount of funds lent to increase, while the
percentage of funds lent decreases (or stays the same).  This
situation can occur when the increase in the amount of funds lent is
proportionately smaller than (or equal to) the increase in the
available funds. 


   LACK OF LEGISLATIVE
   REAUTHORIZATION AND OTHER
   FEDERAL-LEVEL FACTORS
   CONSTRAINED LENDING IN EIGHT
   STATES
---------------------------------------------------------- Chapter 0:3

Officials in eight of the nine states cited one or more factors at
the federal level as affecting the amount and percentage of funds
they lent.  In seven states, officials said that uncertainty about
the reauthorization of the SRF program discouraged some potential
borrowers.  Also, in seven states, officials cited a concern about
compliance with federal requirements, including possible increases in
project costs because of a federal prevailing-wage requirement. 
Finally, in three states, officials identified other reasons, such as
federal restrictions on the use of SRF funds. 


      EXPIRATION OF LEGISLATIVE
      AUTHORIZATION DISCOURAGED
      SOME POTENTIAL BORROWERS
-------------------------------------------------------- Chapter 0:3.1

Officials in seven of the nine states said that the lack of
reauthorization of the Clean Water Act limited their success in
lending funds.  Among other things, the lack of reauthorization made
it difficult to assure the communities applying for loans that SRF
funds would be available to finance their projects and created
uncertainty among communities about the terms of their loans. 

Officials from the seven states generally agreed that the amount and
timing of federal funding became more uncertain after the SRF
program's authorization expired at the end of September 1994.  These
officials said that, prior to 1994, they used the amounts in the
authorizing legislation to help determine how much money they would
have to lend each year.  According to these officials, these amounts
also helped reassure the communities that federal funding would be
available for projects.  These officials said that the uncertainty
created by the lack of reauthorization made it difficult for states
to schedule projects and assure the communities applying for loans
that construction money would be available when needed. 

In addition, Pennsylvania officials said that the lack of
reauthorization caused some communities to delay accepting SRF loans
because they hoped for more favorable loan terms after the act was
reauthorized.  Specifically, the Congress has considered a proposal
to extend the maximum term for an SRF loan, in certain cases, from 20
years to as much as 40 years and to provide lower interest rates. 
The state officials said that the communities were interested in both
longer repayment periods and lower interest rates.\8

According to a Pennsylvania official, several communities in the
state had a loan approved by the state but had not formally accepted
the loan.  In three cases, local officials told us that they were
delaying further action pending the act's reauthorization; the total
dollar value of the loans was about $15 million.  The Pennsylvania
official told us that small, low-income communities in particular
would benefit from the proposal to lengthen the repayment period. 
For example, in March 1995 Pennsylvania approved a $3 million loan
for Burrell Township, which has approximately 3,000 people.  However,
as of October 1996, the community had not accepted the loan on the
chance that a reauthorized act would provide for a longer loan term
and thus lower annual repayments. 


--------------------
\8 In January 1992, we reported that the 20-year maximum term for SRF
loans posed particular problems for small communities.  We reported
that low-technology solutions, such as filtration ponds and lagoons,
which are often appropriate in small communities, generally have
design lives extending far beyond 20 years.  Limiting the loan term
increases the annual debt service payments, and hence user charges,
in communities that may not be able to afford higher charges.  See
Water Pollution:  State Revolving Funds Insufficient to Meet
Wastewater Treatment Needs (GAO/RCED-92-35, Jan.  27, 1992). 


      THE FEDERAL PREVAILING-WAGE
      AND RELATED REQUIREMENTS
      DISCOURAGED POTENTIAL
      BORROWERS
-------------------------------------------------------- Chapter 0:3.2

Officials in seven of the nine states said that compliance with the
federal requirements made financing projects with SRF funds less
attractive and, in some cases, caused communities to turn down SRF
loans.  In particular, five states raised concerns that a federal
prevailing-wage requirement could make SRF-financed projects more
expensive to construct than projects constructed with other funds. 
While the title II requirements--which include the federal
prevailing-wage requirement--ceased to apply to new projects after
October 1, 1994, state officials said they were concerned that these
requirements would be reinstated in the reauthorization act. 

For example, an Arizona official said that the prevailing-wage
requirement could inflate a project's costs from 5 to 25 percent.  A
Louisiana official said that the community of East Baton Rouge Parish
withdrew its 1990 SRF loan application for a project to serve about
120,000 people when it discovered that the prevailing-wage
requirement would increase the labor cost of the project by more than
$1.1 million--31 percent. 

Louisiana officials said that before the prevailing-wage requirement
expired, the state had experienced difficulties in making loans
largely because local officials perceived the requirement as
increasing project costs.  The officials said that Louisiana's
lending rate increased in part because the wage requirement expired. 
The state's lending rate was 44 percent at the end of 1994, before
the requirement expired; 62 percent at the end of 1995; and 79
percent at the end of 1996. 

EPA officials said they were aware that many states had a concern
about the prevailing-wage requirement.  They noted, however, that the
requirement expired at the end of September 1994 and that the
continued application of the requirement would be a state's
management decision.  They also noted that, even before the
requirement expired, it applied only to projects funded with federal
capitalization grants (as opposed to projects funded solely with
state matching or borrowed funds, for example).  Also, they noted
that some states have chosen to continue requiring projects to comply
with the requirement, even though they are no longer required to do
so; however, they said, both Arizona and Louisiana no longer apply
the requirement to projects they fund. 


      OTHER FEDERAL-LEVEL FACTORS
      ALSO DISCOURAGED POTENTIAL
      BORROWERS
-------------------------------------------------------- Chapter 0:3.3

Officials from three states identified other factors at the federal
level that constrained lending.  These included the awarding of
federal funds directly for selected communities and federal
restrictions on the use of SRF funds. 

Maryland and Pennsylvania officials said that the earmarking of
federal funds--not from the SRF program--for specific communities
raised the expectation in other communities that if they waited long
enough, they might also receive funds directly.  This expectation
reduced these communities' incentive to apply for an SRF loan. 

For example, a Maryland official said that state SRF lending was
limited by a congressional decision to provide federal funds directly
for a project in Baltimore, which SRF officials had expected to
finance.  He said that the City of Baltimore turned down the SRF loan
because it received $80 million in federal grant funds for the
project in 1993 and 1994.  The state official said that it took time
to find other communities to borrow the money that was originally set
aside for the Baltimore project.  The state increased its percentage
of funds lent from 61 percent at the end of 1995 to 70 percent at the
end of 1996. 

Officials from Missouri said that certain federal restrictions on the
use of SRF funds limit the amount of loans they can make.  For
example, a state official cited restrictions on financing the costs
of acquiring land.  Under the Clean Water Act, SRF loans cannot be
made to purchase land unless the land itself is an integral part of
the waste treatment processes.\9 Thus, wetlands used to filter
wastewater as part of the treatment process are an eligible expense
under the act.  However, other lands, such as the land upon which a
treatment plant would be built, are not eligible.  According to the
official, because purchasing land for a wastewater treatment facility
represents a large portion of the facility's cost but is ineligible
for SRF financing, some communities are discouraged from seeking SRF
loans. 


--------------------
\9 In our January 1992 report (cited in the previous footnote), we
reported that the ineligibility of certain land costs for SRF
assistance posed a financial problem for many communities. 


   STATES' MANAGEMENT DECISIONS
   LIMITED LENDING IN TWO STATES
---------------------------------------------------------- Chapter 0:4

In Pennsylvania and Arizona, the amount of funds lent was limited by
decisions on how to manage the loan fund.  These decisions related to
how to use SRF funds in Pennsylvania and how to publicize the program
in Arizona. 

Pennsylvania established a state-funded program, independent of the
SRF, in March 1988 to help communities finance wastewater and other
projects.\10 In the early years of the SRF program, Pennsylvania
officials decided to finance about $248 million in wastewater
projects with these state funds rather than wait for SRF funding to
become available, according to state officials.  According to these
officials, the state decided to fund these projects as soon as
possible with state funds to reduce public health risks.  For
example, about $30 million was awarded to the City of Johnstown to
upgrade an existing treatment plant and thereby prevent raw sewage
overflows and inadequately treated wastewater from being discharged
into surface waters. 

According to a state official, Pennsylvania's percentage of funds
lent would have been higher if the state had chosen to fund the $248
million in projects with SRF funds.  In that case, he said,
Pennsylvania's total amount of funds lent through the end of 1996
would have been $558 million, instead of $310 million, and the state
would have lent all available funds, instead of 60 percent of those
funds. 

Likewise, in Arizona, state decisions limited the amount of funds
lent.  According to a state official, efforts to inform local
government officials about the SRF program and interest them in
participating were not effective in the program's early years.  This
difficulty was compounded by restrictive provisions of state law that
further limited the amount of SRF funds lent.\11 The state official
said that the outreach effort was refocused in 1995.  He also noted
that the approval of changes in state laws in 1995 and 1996 helped
create a more positive atmosphere for outreach, even before the
changes took effect.  Arizona's percentage of funds lent was 55
percent at the end of 1995 and 81 percent at the end of 1996. 


--------------------
\10 Five of the other eight states also had grant and/or loan
programs, namely, Illinois, Maryland, Missouri, Oregon, and Texas. 
These programs ranged in size.  For example, in 1995 the funding
available through Maryland's program was approximately $1 million,
while the funding available through Illinois' program was about $185
million. 

\11 Several provisions of Arizona State laws restricted some
localities' ability to participate in the SRF by requiring that
voters approve loan agreements and other means.  According to a state
official, largely because of the marketing and legal factors, the
state did not make any loans during 1993 and 1994.  In July 1994, EPA
notified Arizona that it was not in compliance with the program's
regulations because it had not entered into binding commitments to
fund specific projects within a year of receiving its payments.  EPA
required Arizona to take corrective action or face the loss of these
grants.  In response, Arizona developed a corrective action plan,
which EPA approved.  Among other things, the plan recommended several
changes to the laws that limit local participation in the program. 
In 1995 and 1996, the Arizona State legislature approved many of the
recommended changes.  The state resumed making loans in August 1995
and, according to an EPA official, was in compliance with the
program's requirements in April 1996. 


SOURCES OF FUNDING AND AMOUNT OF
FUNDS LENT, BY STATE
=========================================================== Appendix I

Under the Clean Water State Revolving Fund (SRF) Program, the states
use funds from six primary sources to make loans for wastewater
treatment and related projects.  These are: 

  -- federal grants,

  -- state matching funds,

  -- borrowed funds,

  -- unused funds from the Construction Grants Program,

  -- repayments of loans, and

  -- earnings on invested funds. 

All nine states received federal grants and provided state matching
funds.  These two sources generally accounted for most of the money
in the nine states' revolving funds.  Four of the nine states
borrowed money for their revolving funds.  Five states transferred
unused funds from the old Construction Grants Program.  All nine
states received some loan repayments.  Finally, eight states had
investment earnings on loan repayments. 

Table I.1 shows the amount and sources of funding for the nine states
we reviewed through each state's fiscal year 1996. 



                                    Table I.1
                     
                       Sources of Funding for Nine States,
                             Through Fiscal Year 1996

                              (Dollars in thousands)

                                        Transfer
                                          s from
                                        Construc
                                           t ion      Loan  Investme
Stat  SRF grants     State    Borrowed    Grants  repaymen        nt
e        awarded     match       funds   Program        ts  earnings       Total
----  ----------  --------  ----------  --------  --------  --------  ==========
Ariz     $82,214   $12,559     $25,338         0      $475      $444    $121,030
 ona
Flor     376,183   102,010           0   $67,558    47,591    57,946   656,441\a
 ida
Illi     478,098    92,520           0    24,900    77,610    10,200     683,328
 nois
Loui     134,389    28,063           0         0     4,126         0     166,578
 sia
 na
Mary     239,892    49,566     143,046         0    12,717     9,052     454,273
 land
Miss     298,550    59,710     216,072       681    79,340    11,026     665,379
 ouri
Oreg     124,033    20,399           0         0    16,400     2,600     163,432
 on
Penn     390,178    83,276           0     1,255    43,866     2,514     521,088
 syl
 van
 ia
Texa     528,078   144,284     554,352   197,502    86,871    21,988   1,533,075
 s
================================================================================
Tota  $2,651,615  $592,387    $938,808  $291,896  $368,996  $115,770  $4,964,624
 l
--------------------------------------------------------------------------------
\a Total includes $5,153,000 in administrative funds that did not fit
in any of the categories. 

To determine the percentage of funds lent by each state as of the end
of 1995 and 1996, we divided the total amount of funds lent by the
total funds available to lend, as defined above, both as of the end
of the year.  This method was based on the approach used by the Ohio
Water Development Authority in conducting annual SRF surveys during
1992 through 1995. 

Table I.2 shows the amount and percentage of funds lent for the nine
states for each state's fiscal year 1995 and 1996. 



                               Table I.2
                
                  Amount and Percentage of Funds Lent,
                        1995 and 1996, by State

                         Amount of funds lent    Percentage of funds
                        (thousands of dollars)           lent
                        ----------------------  ----------------------
State                         1995        1996        1995        1996
----------------------  ----------  ----------  ----------  ----------
Arizona                    $50,500     $98,555          55          81
Florida                    538,896     651,595          99          99
Illinois                   529,000     614,000          86          90
Louisiana                   91,173     131,983          62          79
Maryland                   268,889     318,889          61          70
Missouri                   461,973     531,368          82          80
Oregon                      82,900     122,900          57          75
Pennsylvania               266,575     310,787          53          60
Texas                    1,023,788   1,267,548          81          83
======================================================================
Total                   $3,313,694  $4,042,207        62\a        80\a
----------------------------------------------------------------------
\a The percentage shown is the median of the nine states' individual
percentages.  We believe this is a better way to measure the various
states' experience than to calculate the cumulative average for the
nine states, which would give greater weight to the states with large
programs. 

Source:  GAO's analysis of data provided by the states. 


*** End of document. ***