United States
. Environmental Protection
Office of
Washington-DC 20460
                  September 1992
                   Fund  \,  ;.: ^'"  >,
 Practical AppfQaches to Improving Pace
                                   Hands  On
                                   Xji:f f o a G he

| ^M0>7 |                      WASHINGTON, D.C. 20460
                                                                         OFFICE OF
Tb the SRF Community                                   *

   The Clean Water State Revolving Fund (CWSRF) was established to provide a highly
effective means for funding the long term water infrastructure needs of the country.  Ultimately,
the success of the CWSRF will be judged by the environmental results it helps to achieve. In
order to achieve these results, the program must recycle loan repayment streams from current
projects into new loans for future water quality projects. The rate at which the program is
revolving and applying financial resources to achieve environmental results hasr become known
as the pace of the program. This brochure describes how states have developed practical and
innovative approaches to improving the pace of loan activity in their CWSRF programs.

   Eventually, based on the President's goals for future capitalization, it is expected that the
CWSRF program will generate an estimated $2 billion per year in environmental financing  -
assistance and the new Drinking Water State Revolving Fund (DWSRF) will generate $500 million per
year. Revolving the CWSRF program at $2 billion per year will require States to maintain high
demand and usage of CWSRF funds now and through the future to maximize the benefits of the -
program.  Likewise, as implementation of the Drinking Water program moves forward,
maintaining program pace in the States will ensure that the DWSRF reaches its goal of revolving
at $500 million per year nationally.

   While the pace of loan activity alone is not an adequate measure of a program's success,
it is an effective gauge of how States are maintaining and meeting demand for funding. For a
program to be successful, funding must be directed quickly toward achieving environmental
benefits and meeting the short and long term environmental goals of a State.  Achieving
environmental  benefits has been the focus of our efforts to promote integrated priority setting and  -
linkages to statewide and watershed planning efforts.  Maintaining high pace levels to reach
environmental  goals can help to maximize the benefits and usage of CWSRF funds.

    This brochure presents case studies that highlight approaches States have employed to
improve pace by meeting specific customer, community and environmental needs.  These
effective ideas reflect both the goals and flexibility of the CWSRF by broadening the CWSRF
customer base and expanding the breadth of environmental activities funded.

                   Richard T. Kuhlman
                   Office of Wastewater Management

The Clean Water State
Revolving Fund
Practical Approaches to Improving Pace
Hands  On Approaches

  .1    , I  ,,    ,;  || |.

..-,.„..  V. ^.ซ
                        i -t f| - - I;, ป• -i 1,(jj, j-jf •(- ,;f If"' 1Ji[
                         i;' - 4 H;f :ftM *
                         ..-.!	^aju--ii1.. .... :.--	  -
                                 Since its beginning in the late 1980s,
                                 the Clean Water State Revolving Fund
                                 (CWSRF) program has proven to be a
                                 highly effective environmental fund-
                                 ing approach. All fifty states and
                                 Puerto Rico have well-established
                                 CWSRFs and are now approaching ten
                                 years experience in running their pro-
                                 grams. Continued federal and state
                                 commitment to the CWSRF has result-
                                 ed in $24 billion of available funding
                                 (through fiscal year 1997).

                                 Over 5,000 loans have been made
                                 totaling $20 billion. Today, annual
                                 CWSRF loan principal and interest
                                 repayments alone total approximately
                                 $1 billion. Some of the payments will
                                 go to repay bonds used by CWSRF pro-
                                 grams in leveraging federal capitaliza-
                                 tion funds or to repay revenue bonds
                                 issued to provide state matching funds.
                                 However, much of the $1 billion in
Over 5,OOO loans have been made to date totaling $2O
billion. Today, annual CWSRF loan principal and inter-
est repayments alone total approximately $1  billion.
                                                                             annual repayments now flowing into
                                                                             state CWSRF program accounts will
                                                                             soon be recycled into new loans for
                                                                             critical water pollution control pro-
                                                                             jects. Eventually, based on goals for
                                                                             future federal capitalization, it is
                                                                             expected that CWSRF programs will
                                                                             generate an estimated $2 billion per
                                                                             year in low-interest loans.

                                                                             The CWSRF program funds a wide
                                                                             variety of environmental infrastruc-
                                                                             ture projects.  In addition to funding
                                                                             traditional wastewater treatment pro-
                                                                             jects, many states are now using the
                                                                             CWSRF to fund nonpoint source, wet-
                                                                             lands, or national estuary projects
                                                                             that address problems such as agricul-
                                                                             tural, rural, and urban runoff and
                                                                             contaminated urban stormwater.
                                                                             Some of the nonpoint source and estu-
                                                                             ary protection projects being funded
                                                                             include conservation tillage equip-
                                                                             ment, structural  erosion controls,  agri-
                                                                             cultural waste compost facilities, habi-
                                                                             tat restoration, riparian zone protec-
                                                                             tion, and conservation district
                                                                             stormwater controls.

                                                                             Recognizing the success of the CWSRF
                                                                             program, the U.S. Congress recently
                                                                             established a similar revolving fund
                                                                             program for critical public health and
                                                                             compliance-related projects as part of
                                                                             the Safe Drinking Water Act of 1996.
                                                                             The Drinking Water State Revolving
                                                                             Fund (DWSRF) program is similar in
                                                                             many ways to the CWSRF. States are
                                                                             now in the process of designing and
                                                                             implementing their DWSRF programs
                                                                             and will soon be making low-interest

loans to community water systems for
vitally important drinking water pro-
jects. It is expected that the DWSRF
will eventually provide at least $500
million annually in assistance for .eli-
gible drinking water projects.
                        i it

Pace of CWSRF Loan Activity
State use of available CWSRF resources
was high through the end of state fis-
cal year (SPY) 1997 (June 30, 1997),
demonstrating that states continue to
make significant progress toward
maximizing the benefit of the CWSRF
program.  From fiscal year 1992 to fis-
cal year 1997, cumulative funds com-
mitted to loans increased from 73 per-
cent to 82  percent of cumulative funds
available.  However, the pace within
individual state CWSRF programs
varies according to demand and man-
agement ability.  This report will docu-
ment effective techniques that have
been used  by states to improve or
maintain a high level of demand for
CWSRF funding.

Well-Designed CWSRF Strategies Help
States To Meet Water Quality Needs
The Clean Water Act provides states
with the flexibility to design a CWSRF
program that best meets their needs.
States have taken advantage of this
flexibility to creatively manage their
CWSRF so that funds are used in a
timely manner.  This is important
because faster-pace loan activity can
 Eventually, based on goals for future federal capital-

 ization, it is expected that the CWSRF will generate an

 estimated $2 billion per year  in low-interest loans.

be one of the ways to achieve a higher
level of environmental protection ben-
efits over time.
Overall, states that have maintained
high levels of loan activity have done
a good job of identifying who their
potential customers are and how best
to overcome any barriers to participa-
tion in the CWSRF program. States
have used a variety of techniques to
increase or maintain loan activity. For
example, states have implemented
targeted marketing programs to reach
out to communities ;:and other cus-
tomers that are hesitant to move for-
ward with a needed prefect.  This
report explores the approaches "that
eight states.use to improve the effec-
           •*^E''   '        *     ' *vฃif
tiveness of their,CWSRf'programs by,':
                                                                     large and small communities.

                                  I j v' .{fl I i > H-ff' f 41!*.' I
South Dakota
structured a
program to fund
small, potentially
meeting specific community and envi-
ronmental needs. These approaches
fall into six categories:

• Expanding the CWSRF Customer
• Marketing the CWSRF Program
• Providing Implementation
• Providing Assistance in Identifying
  the Best Capital Funding Options
• Coordinating with State
  Compliance/Enforcement Efforts
• Coordinating with State Nonpoint
  Source and Estuary Efforts

Expanding the CWSRF Customer Base
The most successful states have done a
good job in identifying who their
potential customers are and have
designed low-interest loan solutions to
address their customers' (e.g., commu-
nities, individuals, nonprofits, etc.)
needs. Several states have expanded
their customer base to address the
needs of small and disadvantaged
communities. Some states have also
taken the initiative to fund high-prior-
ity nonpoint source (contaminated
runoff from urban, agricultural, and
other sources without a discernible
point of discharge) pollution control
and estuary management projects in
addition to more traditional waste-
water projects. Activities that broaden
both a program's customer base and
the breadth of environmental activi-
ties that are funded can include:
Seeking participation of new customers
States have taken steps to identify and
address the needs of targeted customers.

• Many states have implemented spe-
  cial programs targeted at increasing
  small community participation.
  They often provide CWSRF loans
  with interest rates that are even
  lower than the rate offered for larger
  communities.  They also help com-
  munities comply with program
  requirements by providing special-
  ized technical assistance.
• Some larger communities that could
  benefit from the CWSRF are hesitant
  to participate because they are con-
  cerned about CWSRF loan require-
  ments.  These communities may
  need additional attention from the
  state CWSRF to address their ques-
  tions and to clarify how CWSRF
  requirements can be addressed with-
  out significant additional costs.
• Some states use separate state grants
  for facility planning to encourage
  communities to move forward with
  a project.

Broaden eligibilities under the program to fund
nonpoint source and estuary projects.
To continue working toward the goal
of addressing the most serious water
pollution control challenges, many
states have opened their CWSRF pro-
grams to fund nonpoint source and
estuary protection projects.  Projects
funded include agriculture best man-
agement practices, landfill closures,
septic system replacement, and many
others. The number of CWSRF assis-

tance agreements and loan funds pro-
vided for nonpoint source and estuary
projects are:

• Nonpoint source projects: 495 assis-
  tance agreements totaling $528 mil-
• Estuary projects: 7 assistance agree-
  ments totaling $3 million.

Funding of these activities is expected to
increase substantially as the CWSRF's
potential for addressing nonpoint source
and estuarine problems is realized.

Marketing the CWSRF Program
States use a variety of techniques to
market the CWSRF program to potential
borrowers. Marketing usually consists
of outreach (mailing of flyers, brochures,
and pamphlets); presentations at
meetings and workshops; and targeted
presentations to specific municipalities
or other potential customers such as
farmers, homeowners, etc.

• Outreach.  Mailings are periodically
  sent to municipal governments and
  other potential customers informing
  them of the CWSRF program and its
  benefits. The  mailings introduce the
  CWSRF program, encourage partici-
  pation, and provide information on
  low-cost funding that  is available.

• Presentations at scheduled meet-
  ings and workshops.  State person-
  nel often participate in local meetings
  or workshops,  provide CWSRF pro-
  gram information, and determine  the
  level of interest in the CWSRF. For
  example, a state may attend a
  League of Cities or Association of
  Towns and Townships meeting to pro-
  vide CWSRF program information.

• Targeted presentations. Visiting a
  potential customer, such as a munic-
  ipality or conservation district, pro-
  vides an opportunity to communi-
  cate how the CWSRF program can
  address their specific funding needs.  .
  A focused discussion helps  to clarify
  the benefits of the CWSRF program
  and the process for obtaining a loan.

Taken together, these marketing activ-
ities can have a significant impact on
the level of CWSRF loan activity.

Providing Implementation Assistance
Many states offer assistance to those
customers that may have difficulty
understanding the requirements asso-
ciated with CWSRF loans and the steps
in the implementation process. Areas
where a state may assist customers

Understanding roles and responsibilities.
States help facilitate dialogue and  fos-
ter mutual understanding between
Minnesota devised a statewide approach to provide
CWSRF loans for nonpoint source activities.


project implementation.
                       wastewater project stakeholders,

                       • Local representatives - e.g., elected
                         officials, public works/engineering
                         departments, consultants
                       • State representatives - e.g., permit-
                         ting agencies, nonpoint source or
                         estuary program offices,  bond
                         financing authorities

                       Helping with the implementation process.
                       Much of the implementation process
                       occurs at the local level.  However, cus-
                       tomers with limited capabilities often
                       lack technical expertise in facility
                       planning and design, development of
                       user charge systems, and techniques to
                       build public support. To  alleviate com-
                       munity concerns, many states offer:

                       • Grants to procure  implementation
                       • Direct technical assistance from engi-
                         neers or state program specialists
                       • Relevant educational materials
                       • Assistance in meeting federal
                         requirements in the application
Providing Assistance in Identifying the
Best Capital Funding Options
CWSRF programs often serve an impor-
tant role by helping borrowers devise
the best available funding solutions for
their projects. Activities include:

Educating customers about low-interest loans.
Many borrowers are not aware of the
substantial savings that result from
low-interest CWSRF loans. States often
need to demonstrate that low-interest
loans equate to a partial grant and
that annual costs will be substantially
lower when a customer receives a
CWSRF loan.

Identifying other funding sources.
States can make necessary projects
more affordable by identifying other
available funding sources. For
instance, combining a state grant pro-
gram with CWSRF  loans results in a
higher subsidy for borrowers most in
need. Other potential  funding sources

• Supplemental state loans/grants
• Rural Utility Service  loans/grants
• Other USDA funding programs
• Federal Clean Water Hardship Grant
  Program (U.S. EPA)
• Community Block Development
  Grant Program (HUD)
• Local financing (where CWSRF funds
  are  limited)
• Nonpoint Source Grants (U.S.  EPA)

Coordinating with State
Compliance/Enforcement Efforts
Depending on the role of the lead
CWSRF state agency, enforcement may
or may not be a significant factor in
program implementation.  A state
environmental agency that coordi-
nates its enforcement activities with
the CWSRF agency can encourage
communities that are not in compli-
ance with federal regulations to take
advantage of the CWSRF as a financial
solution to their compliance problems.

Coordinate state level enforcement
efforts with CWSRF loans.
Oklahoma has successfully used
enforcement to complement its CWSRF
program. The majority of borrowers
are facing enforcement orders and
often use CWSRF loans to fund needed

Coordinate compliance-related tracking/
monitoring with CWSRF program outreach.
Texas uses its tracking system to deter-
mine which municipalities are near-
ing capacity (reached 75 -  90 percent
of the total load that can be  handled
by their wastewater treatment plant)
and might need financial assistance to
expand their treatment facilities.

Coordinating with State Nonpoint
Source and Estuary Efforts
CWSRF programs play important roles
in some states by working with other
state programs to finance projects
designed to address high priority non-
point source problems and high priority
problems affecting national estuaries.
Develop loan tools for Nonpoint Source
and Estuary Programs.
Minnesota's CWSRF has worked with
the Minnesota Department of
Agriculture and the Minnesota
Department of Trade and Economic
Development to develop CWSRF loan
programs designed to meet the needs
of borrowers. For example, the State
Department of Agriculture, in con-
junction with the CWSRF program,
operates the State's Agriculture Best
Management Practices  Loan Program.

Coordinate Federal Nonpoint Source
Grants and CWSRF loans.
Section 319 of the Clean Water Act           .,,.-,.-,  .:,..,.
provides for nonpoint source pollution
control grants. However, the grant
funds are limited compared to the
funding that is available,through the    ••:;•'
CWSRF program. Coordinated use of    V';.l          ;;/:.,.
grant funds and CWSRF loans can          ;,  :
make critical nonpoint sourt;^.control              ::     •-•••
projects more affordable.     "&•:„.

Provide information/technical support.
State CWSRF programs can 'encourage
the use of loans for nonpoint source
and  estuary management projects by
providing information and participat-
ing in meetings and conferences to
explain the benefits of CWSRF loans
and  how to obtain them.

Oklahoma coordinated enforcement efforts

with CWSRF loan availability to increase

demand for  its loan programs.

                                                              „.	s":	

'	I-	iiii!
                                                              i1:;;;!!	iiaifr:
                                                              "In "ill' T"	I'll
                                              i       i

CWSRF  Assiltaitte:
       The following case studies provide infor-
       mation on the techniques implemented
       by states to maintain or strengthen
       their CWSRF programs. The case stud-
       ies discuss effective CWSRF outreach
       and marketing practices, the role of
       state enforcement, and the way states
       have addressed special needs in small
       communities and broadened loan assis-
       tance to address nonpoint source pollu-
       tion. States highlighted in this docu-
       ment include:

       Overcoming negative community perceptions
       Combining the CWSRF with State funding programs
       Funding a variety of NFS activities through statewide partnerships
       New York
       Meeting the needs of large and small communities
       Partnering with enforcement to maximize demand
       South Dakota
       Targeting small communities for funding
       Providing extensive technical assistance and coordinating with EPA initiatives
       Identifying and meeting community needs through targeted marketing

si i ..... ป:rซ f
 '    '' • '
                   rt ป•, 'ft ซ-*
                  i j'rf 4 '
                  lii i.: 5 •.;••
    Minnesota funds a variety of nonpoint source activities
    through CWSRF-supported state agency partnerships.
                                 Assistance Activity
                                 Minnesota has a very successful and
                                 diverse CWSRF program. Since 1989,
                                 the Minnesota Public Facilities
                                 Authority (MPFA) has provided approx-
                                 imately $560 million in clean water
                                 assistance. MPFA has made 181 loans
                                 totaling $508 million for traditional
                                 wastewater infrastructure projects and
                                 has funded 226 nonpoint source pollu-
                                 tion prevention projects with $49 mil-
                                 lion in loans since 1995. Figure 1 com-
                                 pares Minnesota's investments in waste-
                                 water and nonpoint source projects.
                                 Minnesota was one of the first states to
                                 leverage its CWSRF program. To date,
                                 leveraging has provided over $400
                                 million in funds available for loans.

                                 Over the next five years, over 200
                                 municipalities are planning environ-
                                 mental infrastructure improvements,
                                 with a total cost estimated to exceed
                                                  $616 million. As a
                                                  result of this,
                                                  demand for funding
                                 through Minnesota's CWSRF is strong.
                                 The state estimates that just to main-
                                 tain wastewater treatment systems at
                                 the present level, 30-45 projects total-
                                 ing $65-$ 100 million per year need to
                                                                             be funded. The annual demand for
                                                                             CWSRF wastewater infrastructure
                                                                             loans currently ranges from $100-$ 150
                                                                             million.  The annual demand for
                                                                             CWSRF nonpoint source loans is over
                                                                             $15 million.

                                                                             Maximizing CWSRF Resources
                                                                             The continuing success of Minnesota's
                                                                             CWSRF is due to the State's focus on
                                                                             funding qualifying communities that
                                                                             wish to participate, and expanding
                                                                             the CWSRF to address nonpoint source
                                                                             pollution and coordinating with state
                                                                             enforcement activities.

                                                                             Serving Large and Small Communities
                                                                             Minnesota tailors its interest rates to
                                                                             the financial condition of its munici-
                                                                             pal borrowers. Larger, financially
                                                                             secure cities,  such as Minneapolis/St.
                                                                             Paul, participate in the CWSRF and
                                                                             receive below market financing on
                                                                             their wastewater treatment projects. The
                                                                             participation of Minneapolis/St. Paul
                                                                             actually helps the CWSRF to issue high-
                                                                             er quality bonds at lower interest rates,
                                                                             thus allowing deeper subsidies to
                                                                             smaller, disadvantaged communities.

Addressing Nonpoint Source
Pollution Control
Since 1995, Minnesota has imple-
mented five nonpoint source loan pro-
grams that fund a variety of water
quality protection projects. The loan
programs and the agencies that oper-
ate them include: 1) Clean Water
Partnership Loan Program, Minnesota
                                             Figure 1. DWSRF Projects Funded
                                                      in Minnesota
Pollution Control Agency (MPCA); 2)
Agriculture Best Management
Practices Loan Program, Department
of Agriculture; 3)  Tourism Loan
Program, Department of Trade and
Economic Development; 4) Small
Cities Development Program,
Department of Trade and Economic
Development; and 5) Stormwater Loan
                                                                                            - Broadening the Minnesota
                                                                                           CWSRF Program Customer Base
Agriculture Best Management
Practices Loan Program
Minnesota Department of Agriculture
What is eligible?
Water quality improvement projects that
mitigate or prevent nonpoint source pollu-
tion in rural areas
Who is eligible?
Farmers, rural landowners, and agribusiness
Interest rate?
3 percent

Clean Water Partnership
Loan Program
Minnesota Pollution Control Agency
What is eligible?
Most best management practices addressing
nonpoint source pollution
Who is eligible?
Local units of government and watershed
districts participating in a watershed man-
agement project
Interest rate?
2 percent

Tourism Loan Program
Minnesota Department of
Trade and Economic Development
What is eligible?
Septic system upgrades or replacements for
non-compliant systems
Who is eligible?
Corporations, sole proprietorships, or part-
nerships engaged in water-based tourism
related business
Interest rate?
50-50 loan program/ 2 percent for tourism
program and market rate from local bank

             ' MM'H IS
Jeff Freeman
 Minnesota Public Facilities Authority
 500 Metro Square, 121 7th Place East
 St Paul, MN 55101

Marge Velky
 Minnesota Pollution Control Agency
 Clean Water Partnership Program
 520 Lafayette Road
 St. Paul, MN 55155

Paul Burns
 Mirmesot* Department of Agriculture
 Agriculture Be$! Management Practices
 toon Program
 n Wซt Plato Blvd.
 St, Paul, MN 55107

Bob Ahllrt
 Dept of Trade and Economic Development
 Tourism loan Program
 500 Metro Square, 121 7th Place East
 St. Paul, MN 55101

Anita Gallentine
 Dc-pt of Trade and Economic Development
 Small Cities Development Program
 500 Metro Square, 121 7th Place East

Pete Skwlra
 Minnesota Pollution Control Agency
 Stormwater Loan Program
 520 Lafayette Road
 St. Paul, MN 55155
                                       Program, MPCA/MPFA. According to
                                       state officials, the pace of the CWSRF
                                       nonpoint source programs varies from
                                       program to program, but the overall
                                       demand for funding exceeds the funds
                                       targeted for nonpoint source projects.

                                        Coordinating Enforcement
                                        and Funding Activities
                                       In Minnesota, projects in non-compli-
                                       ance or those facing enforcement
                                       actions often use the CWSRF to fund
                                       the necessary infrastructure improve-
ments.  To avoid enforcement action,
some borrowers use CWSRF assistance
to maintain compliance. For exam-
ple, two small unsewered communities
(one with a population of approxi-
mately 500, the other less than 50)
that have failing septic systems drain-
ing to rivers recently received low-
interest CWSRF loans combined with
federal  grant money to correct these

Assistance Activity
Tennessee's CWSRF is an example of a
program that has worked especially
hard to meet the needs of communi-
ties within the state.  Tennessee is also
a good example of a state that pro-
vides technical assistance and funding
for local planning to help communi-
ties develop the capacity they need to
receive CWSRF funding.

As a complement to the CWSRF, the
state provides funding in the form of
loans from the Tennessee Local
Development Authority (TLDA). TLDA
provides loans to local governments
for the construction of water, waste-
water, and solid waste projects. It
offers a repayment period up to 30
years and interest rates tailored to a
community's ability to pay (rates are
locked at the bond rate). The presence
of the TLDA program frees up more
money in the CWSRF to meet other
needs in the state.

Tennessee has  made significant
progress in funding wastewater pro-
jects since the  CWSRF initiated opera-
tions in 1989.  The state has provided
$278 million in assistance (as shown
in Figure 1) to  communities of all
sizes.  Of the 83 loans that have been
disbursed, 47 have been for communi-
ties with populations below 10,000.
To ensure that loans from the CWSRF
are affordable  to all communities, the
state offers a fixed interest rate that is
based on a community's financial
capability.  Economically weak com-
munities characterized by lower
income levels, tax revenue, and prop-
erty values receive lower interest rates
on CWSRF loans. The result is that a
community's user fee burden (mea-        -.,:
sured as a percentage of household      '
income) is reduced.

Maximizing CWSRF Resources
Coordinating Assistance to Increase Water     _
Pollution Control Activities    ,         „  „!! _
Tennessee participates in a humbefbf-
                             f^Zr, •        *
EPA initiatives to support and irhp'rove    ,ฃ-
local governments' technical and    *
managerial capabilities and to      —
increase interest in CWSRF funding.
These include Municipal Wastewater
Pollution Prevention (MWPP), Small
Communities Outreach and Education
(SCORE), and the Small Town
Environment Program (STEP).
                    As of SFY96, Tennessee had provided 99 percent in
                    assistance of the cumulative funds available, making it
                    one of the top CWSRF pace-setters in the country.

 * "in iif   "111'  "" ป''|JIL"  T 1.1  ""ป""" *' ''" * '!"'f ir' T i '"iff "JT * ^i WซM. ini ayiir r 7 ™ hj :,. * rs',fe- injf^v/j IE ซ"•'!• -a'. |i,.5, 'Ai'varsiS'uj |i5|iifif JtlTi.'jj'f-'i
      Jim Poff
      Dept, of Environment and Conservation
      Division of Construction Grants and Loans
      8th Floor, L&C Tower
      401 Church Street
      Mjshviilc, TN 37243

      Hme address as above
• The MWPP initiative is a two-year,
 $50,000 grant from EPA for the pur-
 pose of developing a pollution pre-
 vention program. The goal is to
 encourage better planning of waste-
 water treatment facilities through
 financial and technical assistance.
 With proper implementation, the
 program should increase the quality
 and pace of project activities.

• SCORE is an established network of
 federal, state, and nonprofit agencies
 who work with small communities
 that lack personnel and expertise to
 address wastewater and drinking
 water needs.  Their goal is to help
 maintain and build water and
 wastewater treatment facilities that
 comply with applicable technology,
 enhance effective financial manage-
 ment and operation, and provide
 pollution prevention and education-
 al efforts.
                                          Cumulative CWSRF Assistance Provided
                                        Figure 1. Cumulative CWSRF Assistance
• STEP is a self-help, loan program
  targeted at small communities and
  is similar to the Rensselaerville
  Institute (New York) Self-Help pro-
  gram.  The program makes three-
  year loans at a maximum of
  $150,000 (interest rates based on
  ability to pay) to correct drinking
  water and wastewater problems and
  to maintain compliance through the
  construction of infrastructure.

The integration of the CWSRF and
these programs along with Tennessee's
customer-oriented approach keeps
funds moving quickly. The State
works with communities during all
stages of the financing process to
avoid any problems that may delay
the issuance of loans. Tennessee rep-
resentatives  provide assistance at
preapplication  meetings across the
state to answer questions and alleviate
community  concerns. They also
attend other workshops and seminars,
and distribute informative brochures
explaining the different types of state
assistance offered.

 Assistance Activity
 Arizona had a slow start; its first pro-
 jects were not funded until 1992.
 However, since then, the state has
 experienced a high level of demand
 for CWSRF funding.  By 1996, the
 Arizona CWSRF had provided nearly
 $100 million in loan assistance. In
 fiscal year 1997, Arizona closed nine
 additional loans for a total of $32
 million and in fiscal year 1998 is
 scheduled to close loans totaling $50
 million. Figure 1 shows the cumula-
 tive funding in Arizona's CWSRF pro-
 jected through fiscal  year 1998.  From
 1992 to 1998, the state's funding will
 have increased by 500 percent.

 Because of the strong need for finan-
 cial assistance, the State has found it
 desirable to leverage its program in
the bond market to increase resources
 available for immediate funding
needs. As of 1996, Arizona had
issued $86 million in leveraging
bonds. Arizona has contributed over
$13 million in state-match funds, with
the federal government providing over
$77 million toward capitalization.
State and federal contributions taken
together, Arizona has over $ 176 mil-
lion invested in its CWSRF.

Arizona's CWSRF provides loans to
meet the needs of all types of commu-
nities in the state. Loans have provid-
ed environmental funding for large
and small communities, communities
that  have only small needs, as well as
those communities that have short-
                                       1992 I I   1994
                                      '••." WiMifehp * I	
                                           Cumulative CWSRF Assistance
                                     Figure 1. Growth in Arizona's CWSRF
                                                                           Arizona has overcome many
                                                                           negative perceptions held by
                                                                           communities across the state.

   Why it Arizona Successful?

Commitment to all communities
To iltewate the concerns of small communi-
tfes, WIFA offers hands-on in-the-field assis-
tant* for the applications process.

Program streamlining
WfFA has simplified the loan application
process and helps inform local governments
of the pertinent information necessary for
compliance with the CWSRF program.

To ensure the success of the CWSRF, the
Wlf A staff communkates regularly with local
government finance and community devel-
opment directors and city and town man-
agers to explore their needs and future
term financing
needs. One-
half of the pro-
jects funded in
1996 were for
with popula-
tions below
10,000. Al-
though the state
has funded only
treatment pro-
jects in the past,
it is considering
nonpoint source
projects for the
future. Arizona currently has over
$2.2 billion in funding needs (estimat-
ed 20 year needs).

Maximizing CWSRF Resources
After reorganizing in 1992, Arizona's
Water Infrastructure Finance
Authority (Wlf A) has worked hard to
increase local community participa-
tion in the CWSRF program.  Initially,
WIFA works to educate communities
so that they understand that low inter-
est CWSRF loans provide a high level
of subsidy that is comparable to a sig-
nificant grant.  Next, since Arizona
law requires that debt-related projects
receive voter  authorization, WIFA staff
constantly work with local govern-
ments to obtain the support necessary
for loan approval.
The state provides continuous support
to communities during the project
planning and loan application
process.  The state has also simplified
the loan application process so that it
is more easily understood by smaller

One effective marketing technique
that Arizona uses is to coordinate state
funding options through its Rural
Infrastructure Committee. The
Committee serves as a single point of
contact for communities that need
help determining what infrastructure
funding options are best for them. As
a component of its services, the
Committee promotes the program
through monthly meetings in commu-
nities throughout the state.  The pur-

pose of the meetings is to allow com-
munities to take advantage of the
funding expertise and technical
resources of state personnel.

WIFA staff members also continuously
make targeted presentations to differ-
ent municipal bodies. The purpose of
these presentations is to gain support
from communities and encourage
them to take advantage of the CWSRF.

Arizona is a good example of how a
state can increase loan assistance pro-
vided by the CWSRF.  By streamlining
the application process, conducting
continuous outreach to educate com-
munities on the availability and bene-
fits of CWSRF loans, and providing
hands-on assistance during the pre-
liminary project planning and loan
application process, the Arizona
CWSRF has helped to assure the abili-
ty of its program  to meet current  and
future environmental needs.
                                                                                 Greg Swartz, Executive Director
                                                                                /•Water Infrastructure Finance''".;..
                                                                                ^Authority of Arizona.,        '%.
                                                                                •^.3033 North Central "V.       ?;
                                                                                 ^Phoenix, A|.85012   >
                                                                                  602,207.4707-,     i-<

                               Assistance Activity
                               Connecticut has a well-funded Clean
                               Water Fund program that combines
                               federal and state funding programs
                               and is aggressive in meeting its waste-
                               water funding needs. To date,
                               Connecticut has funded 120 waste-
                               water projects with $968 million in
                               Clean Water Fund assistance. Part of
                               the State's success stems from combin-
                               ing assistance from a separate state
                               grant and loan program (the State
                               Water Pollution Control Account) with
                               assistance from the CWSRF program.
                               When projects receive both a state
                               grant (20 percent for most projects)
                               and a loan,  the loan interest rate is
                               fixed at 2 percent.  This interest rate
                               and the grant make the financing
                               very attractive to local governments.
             ,                  Because of the strong demand for
             '                  funding, the State decided to leverage
             ^                 its CWSRF. As of SFY97, the State had
                                 ._  ..            obligated $590
Connecticut i experience demonstrates the benefits of       -1
combining the CWSRF with other state funding sources.  mlmOn in leverag-
                                                ing bonds to fund
                               projects. This amount is triple the
                               cumulative federal capitalization
                               grants received for funding projects.
                               As of fiscal year  1997, Connecticut's
grant program had provided $232
million in funding assistance. Figure
1 compares the sources of funding in
the Connecticut Clean Water Fund.

Maximizing CWSRF Resources
States use a variety of techniques to
enhance the pace of financial assis-
tance provided from their CWSRF pro-
grams.  In Connecticut, the state iden-
tified several factors that greatly affect
• The availability of additional subsi-
  dies through state grants
• Attractive low-interest rates on
  CWSRF loans
• A consistent enforcement approach

Combining CWSRF Assistance
with State Grants
Connecticut strategically mixes
CWSRF funding assistance with  fund-
ing from its state grant program.
Depending on the type of project, the
State implements the following assis-
tance formula:  45 - 80 percent of the
funding is provided by the CWSRF and
the remainder (20 - 55 percent)  is con-
tributed by the state grant program.
The State funds four categories of
wastewater projects.  The four cate-
gories include wastewater treatment,

combined sewer overflows
(CSOs), interceptor projects, and
small community projects.
Wastewater treatment projects
get a minimum grant contribu-
tion of 20 percent, while CSO
projects receive grants of 50
percent because of the costly
nature of CSOs. To encourage
the creation of regional author-
ities, the state will increase the
grant portion by 5 percent.
The Connecticut Clean Water Fund,
structured into state grant and federal
loan components, also coordinates
combined funding packages with
other state and federal programs.
These include the Clean Water
Hardship Grant, Rural Utilities Service
Grants and other direct grants provid-
ed by the state legislature.

Low-Interest Rate Loans For Communities
The State believes that the fixed 2 per-
cent interest rate is essential to the
program's continued success. The
rate, coupled with flexible grant par-
ticipation, allows the State to encour-
age priority projects to move forward
and to help make the project afford-
able to the community in question.
Without it, the State believes it would
have difficulty attracting many poten-
tial borrowers.
Figure 1. Clean Water Fund Funding

Consistent Enforcement
Connecticut officials view the CWSRF
and other funding programs available
to the State as complementary to the
State's enforcement program.  When
enforcing federal and state .clean
water requirements, the State uses the
Clean Water Fund to make projects
more affordable.  By strategically com-
bining funding options and enforce-
ment, Connecticut has developed a
highly effective CWSRF program.
   ,  Clean Water Hardship
        Grants Program      \,yj

EPA's newly implemented Clean Water
Hardship Grants Program is the most recent
addition to the grant resources of the State.
The Hardship Grants Program for Rural
Communities targets its assistance to rural,
impoverished communities of 3,000 or
fewer. Funds are available for the design and
construction of treatment facilities or for
technical assistance.
                                  •;  -/^Contact'
                                          'Robert Norwood  ^*_J    •  ;  '
                                          Oepartmeritottnvirontrieritat Protection
                                          n Elm Street; ~      -;--,   2 _
                                          Hartfor^ CTW106
                                          860.424.3746    :"    -V
                                           •m  '" -
                                           ?*-. "* J~ '"•    fr-
                                           • ,gฎr .
                                          ,  +a**>.


Sip '
Assistance Activity
Although not a formally leveraged
program, Oklahoma's CWSRF is oper-
ated in partnership with a state bond
program to achieve higher funding
levels.  The state bond/loan program
dates back to the time of the Federal
Construction Grants program. Started
in 1982, loans from the bond program
provided funding for project costs not
covered by the Construction Grant pro-
gram.  Today, the State uses the bond
program to provide loans that are used
in combination with the CWSRF loans.
The State provides interim construc-
tion financing as well as long-term
financing through the CWSRF and
state bond program.
direct loan to the local community.
The loan has an interest rate of 4.25
percent with an annual 0.5 percent
administration fee and its term does
not usually extend beyond two years
after the construction completion date.

For long-term loans, the OWRB com-
bines state bond proceeds at market
rate with below market funding from
the CWSRF. The result is a low-interest
long-term loan that can be used to
finance projects or refinance interim

As of SFY96, 52 wastewater projects
received $217 million in assistance.
Total assistance provided has
increased by 500 percent since 1992.
As shown in Figure 1, assistance pro-
vided is a combination of CWSRF
loans and state bond funds.
                                     The Oklahoma Water
                                     Resources Board (OWRB) pro-
                                     vides short-term construction
                                     financing in the form of a
      Oklahoma operates a successful CWSRF program that
      If predominately enforcement driven.
                                                                          Figure 1. Cumulative Project Funding
                                                                                  (as of SFY96)

Maximizing CWSRF Resources
The Positive Use of Enforcement
increases CWSRF Customers
Oklahoma increases the pace of fund-
ing with its successful enforcement-
driven CWSRF. Because the Oklahoma
Department of Environmental Quality
(ODEOJ provides the OWRB with
information on enforcement activities,
the OWRB is aware of the systems
that may be in need of assistance to
maintain compliance. The OWRB
effectively promotes the CWSRF to
those communities. As a result, com-
munities that have been cited for non-
compliance or those that must upgrade
their infrastructure to avoid future
compliance problems are most often the
customers of the CWSRF. Oklahoma is
a good example of how a state can
coordinate enforcement efforts with
low cost funding through the CWSRF
program to make projects more
affordable and ready to move forward
quickly. The enforcement program
keeps the demand for CWSRF dollars
                   high. For
                   instance, 50 of
                   the 57 loans ap-
                   proved for SFY97
                   have pending en-
                   forcement orders
                   and total over
                   $200 million.

                   Loans Attract Small
                   Communities to
                   the CWSRF
                   Oklahoma has
                   indicated that, in
the past, small communities were not
attracted to the CWSRF program.
These communities were reluctant to
participate due to concerns regarding
federal and state requirements associ-
ated with loan programs. Therefore,
Oklahoma's initial strategy was to
attract large communities to the
CWSRF, fund large projects, and use
the loan repayments for second-round
loans to small communities (popula-
tion less than 10,000).  The funds for
second-round loans come primarily
from principal and interest repay-
ments on first-round loans and carry
fewer project requirements (e.g.,
exemption from most federal cross-
cutting laws and authorities).
                                                                               Paul Hodge, Assistant Chief
                                                                               Financial Assistance Division
                                                                               OklahomrWater Resources Board
                                                                               3800 NorWCIa^fiO Boulevard    _3&k

South Dakota has demonstrated excellence
in funding small communities.
Assistance Activity
South Dakota has devised a successful
program that meets the needs of local
communities. Because most of the
communities in the state are small,
the CWSRF has targeted their needs.
As a result, more than two-thirds of
the 83 loans have been made to com-
munities below 10,000 in population.
Figure 1 shows the number of loans
made to communities with popula-
tions under 10,000 as of SFY96.

Small communities may be viewed as
posing a credit risk to CWSRF pro-
grams. Smaller communities often
have lower household income levels
and less diversity of employment
opportunities, making them more sus-
ceptible to economic downturns. To
date, however, the State has had no
        default or repayment prob-
        lems, even though more than
        one-half of all loans have
been made to communities with popu-
lations below 3,500. In addition, the
State has been able to leverage  its
CWSRF program by using small com-
munity repayments as security  for the
CWSRF leverage bonds.
To further meet the needs of its com-
munities, the South Dakota CWSRF
funds nonpoint source projects in
addition to traditional wastewater pro-
jects. South Dakota has funded 4
nonpoint source projects totaling over
$2 million.

As an added incentive for participa-
tion, South Dakota offers different
fixed interest rates, depending on the
loan term and whether the loan is
from leveraged funds or disbursed
directly from CWSRF capitalization
funds. Loans from the CWSRF have
10-, 15-, or 20-year terms with interest
rates of 4.5 percent, 5 percent, and
5.25 percent respectively. The lever-
aged loans have 10-,  15-, or 20-year
terms with one interest rate of 6.25
percent. Like many other states,
South Dakota has a state grant pro-
gram that provides additional assis-
tance to CWSRF projects.
As shown in Figure 2, the federal gov-
ernment has provided $60 million in
capitalization funding. Along with
state match funds of $24 million and
leveraging funds of $4 million, South
Dakota has $88 million invested in its
CWSRF. The projects funded to date
have received $69 million in CWSRF

Maximizing CWSRF Resources
Structuring the CWSRF to
Meet Community Needs
The population of South Dakota
is 700,000,  and the vast majority of
communities are small and rural.
Recognizing its customer base, the State
has maintained the objective of fund-
ing communities with funding needs,
regardless of population size.

The State has worked to fine-tune the
CWSRF assistance provided to meet
the needs of the small communities
that comprise the vast majority of
potential loan customers.  The State
offers flexible interest rates and repay-
ment terms, and it combines state
grants with CWSRF  loans to assure a
very high level of subsidy for deserv-
ing communities.

Protecting CWSRF Funds
The State considers loans made to
small towns and nonpoint source pro-
jects as having higher risk compared
to loans for larger communities. To
                    Population Size
       Figure 1. Small Community Loans

       counter any problems associated with
       these potential borrowers, the state
       may require that the loans be "double
       barreled."  Double barreling requires a
       community to pledge a second rev-
       enue  source to repay the loan in the
       event that the first source is not suffi-
       cient. A common example would be a
       community pledging wastewater rev-
       enues to repay its loan and pledging
       revenues from its sales tax/und as a
       backup.  In addition,- the  state exam-
       ines certain criteria" for all its appli-
                                                                                       ,ป- . Factors to Consider
                                                                                              High-Risk Loans
• "double barreling" the loan - provide sec-
 ond revenue source for security
• other outstanding debts
• how the borrower will meet a CWSRF
 annual loan debt service "coverage
 requirement" of 110 percent
• increase/decrease in user population, rate
 increase history
• local support for the project
• revenue sources for the project


James Feeney
South Dakota Department of Environment
and Natural Resources
523 East Capitol
Pierre, SO 57501
                                                State Match
                           Fed. Cap. Grants
                                  Figure 2. Total CWSRF Investment
                                           (S millions)
Reaching Out to Customers
South Dakota is active in reaching out
to customers and marketing its CWSRF
and other state grant and loan pro-
grams.  The targeted groups are
municipal leagues, wastewater confer-
ences, and regional planning districts.
The state makes presentations to these
groups to inform them about CWSRF
funding availability, what projects are
eligible, what loan terms are avail-
able, and how the loan application
and funding process works.  State offi-
cials are accessible to assist communi-
ties with any potential problems dur-
ing the application process. The pres-
ence of state officials encourages more
communities to participate in the
CWSRF program. South Dakota also
distributes brochures and sends corre-
spondence to potential borrowers on a
regular basis to build awareness of
CWSRF funding availability.  Potential
borrowers are identified on an on-
going basis, and information on the
funding programs and state water
planning  process is provided to and
through the state rural water associa-
tion, planning districts, water develop-
ment districts, and other associations.

Assistance Activity
Since 1990, New York has funded 611
projects (including 44 nonpoint source
projects) as shown in Figure 1. New
York has provided $3.5 billion in assis-
tance for all projects, including  $300
million in loans for nonpoint source
projects. The State also implements a
successful leveraging program. Since
its inception, New'York has leveraged
almost $3 billion dollars as additional
funds for projects.

As a large program,  New York strives
to address the needs of all municipal
loan applicants.  Almost one-third of
the loans were made to communities
with populations below 3,500. The
CWSRF in New York  is attractive to
borrowers because of low interest rates
on two types of loans, short-term and
long-term financing. Short-term
financing consists of interest-free
short-term loans that allow munici-
palities to design and initiate con-
struction on water quality pro-
jects.  The loans are available for
up to three years. Long-term
financing is the bulk of assis-
tance provided at below market
rates (one-half to two-thirds of
market rate with interest-free
direct loans available depending
on financial hardship).  The
below-market rate offers substan-
tial savings for communities.   For
example, a million dollar project,
financed with a subsidized 2.96
      percent interest rate as compared to a
      typical market rate (5.92 percent),
      would provide a savings of approxi-
      mately $393,036 over the 20 year life
      of the loan as shown in Figure 2.

      As shown in Figure 3, New York has
      $4 billion invested in its CWSRF. The
      federal government has provided $1
      billion toward capitalization, the state
      has provided $255 million in match-
      ing funds and obtained leveraging
      funds of approximately $3 billion.
New York has the largest
CWSRF in the country. As of
SFY96, New York had provided
S3 billion in CWSRF assistance
and expects to see this total
grow to S4 billion in loans by
the year 2OOO.
    ฃj| Annual Projects     ฃ Cumulative Projects

     Figure 1. New York's CWSRF Projects


                                           PROJECT COSTS
                            CWSRF Loan
Robert E. Davis, P.E.
Director ol Engineering and
Program Management
New York Slate Environmental
Facilities Corporation
                                                   Typical Loan
Atomy, NY 12205-2603
        23% Cost Reduction
Figure 2. New York CWSRF Loan Savings

Maximizing CWSRF Resources
New York's success in implementing its
CWSRF program is partially due to the
substantial wastewater funding needs
of the state. Total needs are estimated
             to be $16 billion for the
             next 20 years.  The state
             has also done a good
             job in designing and
             implementing a CWSRF
             that meets the needs of
             its communities.
                 State Match
   Figure 3. Total CWSRF Investment
           (S millions)
             Self-Help for Small
             Communities Interested
             in the CWSRF
             New York's CWSRF
             serves loan recipients
             that range in size from
             New York City to very
             small municipalities in
            the rural parts of the
            state. Small and rural
communities in New York have docu-
mented wastewater needs of $710 mil-
                                             lion. The state has also estimated
                                             $654 million in additional needs for
                                             small and rural communities.  To bet-
                                             ter assist small communities, New
                                             York, with the assistance of The
                                             Rensselaerville Institute, established
                                             the Self-Help Support System in 1985.
                                             The system provides help to small
                                             communities to address their water
                                             and wastewater challenges. The pro-
                                             gram encourages local citizens to take
                                             responsibility for meeting project
                                             requirements. The types of assistance
                                             available under the Self-Help program
                                             to help lessen costs associated with
                                             project implementation include tech-
                                             nical advice (engineering and finan-
                                             cial), and how-to materials.

                                             Effective Marketing and Outreach Efforts
                                             The state has an effective marketing
                                             program that fosters communities'
                                             interest in CWSRF loans.  State repre-
                                             sentatives regularly attend and partic-
                                             ipate in various workshops, seminars,
                                             and conferences. The New York State
                                             Environmental Facilities Corporation
                                             has two field representatives for rural
                                             and other small communities.  Each
                                             representative travels to different
                                             small municipalities and provides
                                             information on the CWSRF, including
                                             assistance on application procedures
                                             and how to comply with program
Fed. Cap. Grants

Assistance Activity
Texas is a good example of a state
that has continuous, strong demand
for CWSRF funding.  Even though
CWSRF loan interest rates are set only
0.7 or 1.2 percent below the prevailing
market rate, the state experiences
strong  demand for CWSRF loan fund-
ing from new and repeat customers.

Texas also leverages its program and
receives additional state contributions
("advanced match") beyond the
required 20 percent state match to
provide additional funding for loans.
By combining federal capitalization
grants  with state match and advanced
match funds, leveraging bond pro-
ceeds, and loan repayments,  the
Texas CWSRF has a current annual
loan volume of about $250 million.
The financial structure Texas has
established for the CWSRF has worked
well for its communities.  Over one-
half of the projects funded have been
for communities below 10,000 in pop-
ulation. Also, the size of each project
loan has decreased from an average
of $18 million in 1990 to an average
of just over $7 million per project in
1996, indicating a willingness to serve
customers of varying size.
 increased from $122 million in 1989
 to $1.3 billion in 1996 which demon-
 strates an annual growth rate of near-
 ly 40 percent (Figure 2).

 Maximizing CWSRF Resources
 Overall, Texas has a fast-moving pro-
 gram. Because Texas is a populous
 state with significant wastewater con-
 struction needs, demand for CWSRF
 funds has always been strong.  The
 state also identified targeted market-
 ing and enforcement efforts as impor-
 tant factors that increase demand.
As shown in Figure 1, the federal gov-
ernment has provided $703 million in
capitalization funding. Along with
state match of $269 million and $554
million of funds from leveraging,
Texas has $1.5 billion invested in its
CWSRF. The cumulative assistance
provided in the CWSRF funding

                                        Over one-half of the projects
                                        funded have been for communi-
                                        ties below 10,000 in population.
               State Match
Fed. Cap. Grants
Figure 1.  Total CWSRF Investment
         (S millions)

                  fc'^fl i n*fsiii ip *|''
      T*xaป Is Sensitive to
      --  •ซป    ป      .- -.," - „ -;^ra
    CWSRF Customer Needs
ซFirst come/first serve funding allows appli-
 cants to proceed at their own schedules.

* Customers nave a funding option that
 atews them to fix interest rates and
 receive funds qukkly. Especially helpful for
 smaller communities that may not have
 the financial capability to pay for planning
 costs up-front.

• Funding continuous capital improvements
 in cities. For example, Houston received
 CWSRF money to remove all sanitary sewer
 overflows (SSOs) from its system.
 Mirk Hall
 Texas Water Development Board
 1700 North Congress Avenue
 AmtimTX 78711
Targeted Marketing Increased
Interest in Loan Funding
The Texas Water Development Board
(TWDB) coordinates with other state
agencies on various marketing efforts
for the CWSRF.  Financial and engi-
neering consultants also market the
CWSRF at workshops and conferences.
Texas is well aware of the needs of the
communities and tailors its program
to meet those needs. An example of
targeted marketing includes a
Memorandum of Understanding with
the Texas Soil and Water Conservation
Board to pursue and fund agri-
culture nonpoint source projects.
TWDB also participates with the
Texas Natural Resource
Conservation Commission in
seminars regarding nonpoint
source project funding. Texas
also remains aware of customer
needs through regular customer
polls, focus groups, customer sur-
veys, and day-to-day interaction.
These marketing efforts, in con-
junction with the size and popu-
larity of the  CWSRF program, are
responsible for its success.
    Texas Natural Resources Conservation
    Commission's 75/90 Rule and CWSRF Funding
    As the state regulatory agency, the
    Texas Natural Resources Conservation
    Commission (TNRCC) tracks the status
    of wastewater treatment facilities with
    the "75/90 rule."  The 75/90 rule is a
    preventative measure that keeps
    municipalities from violating their
    wastewater discharge permits. When
    a facility reaches 75 percent of its
    capacity, the municipality is notified
    in writing that it should begin plan-
    ning for a plant expansion. When the
    plant reaches 90 percent of its capaci-
    ty, the city must begin or should be
    ready to begin the design and con-
    struction phase of the plant expan-
    sion. The TWDB contacts those enti-
    ties who have received 75/90 notices
    and often provides CWSRF funding to
    improve their wastewater treatment
                                                                               Cumulative CWSRF Assistance Provided

                                                                              Figure 2. Growth in CWSRF Funding


United States
Environmental Protection Agency
Washington, DC 20460
Penalty tot Piivas* Usa