SUSTAINABILITY AND THE
CLEAN WATER STATE REVOLVING FUND
A BEST PRACTICES GUIDE
f/EPA
Clean Water
State Revolving Fund
JULY 2012
EPA-832-R-12-005
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PREFACE
The Environmental Protection Agency's (EPA) Clean Water and Drinking Water Infrastructure
Sustainability Policy was officially released on October 1, 2010 and was developed with input from a
variety of federal, state, and local officials with the goal of promoting sustainable infrastructure within
the water sector. The policy focuses on promoting planning processes that support sustainability,
promoting community sustainability, and promoting sustainable water and wastewater systems along
with the targeting of Clean Water and Drinking Water State Revolving Fund assistance.
Along with EPA's Sustainability Policy, in 2009 the U.S. Department of Housing and Urban Development
(HUD), the U.S. Department of Transportation (DOT), and the EPA formed the Interagency Partnership
for Sustainable Communities (Partnership) to help improve access to affordable housing, expand
transportation options, and lower transportation costs while protecting the environment in
communities nationwide. Through this partnership, the Clean Water State Revolving Fund (CWSRF)
along with EPA's Office of Sustainable Communities sponsored three pilot projects with New York,
Maryland, and California to provide technical assistance and policy options to explore how their
programs may be improved to encourage more sustainable development and communities.
EPA's Office of Wastewater Management has developed this Best Practices Guide to provide an
overview of a variety of state policies and practices supporting the priorities outlined in the
Sustainability Policy and pilot projects. Currently, many states have unique and effective policies that
directly address these issues whether it be through program requirements and incentives, project
priority system structure, innovative financial mechanisms, technical assistance, or outreach to
communities and potential borrowers. As a significant source of funding for wastewater infrastructure,
CWSRF programs can influence how some communities develop infrastructure projects. This guide is
intended for state programs as they consider policies and initiatives to promote community and water
infrastructure sustainability. While this guide will primarily focus on the CWSRF, some policies used by
the Drinking Water State Revolving Fund (DWSRF) are highlighted, and many CWSRF policies may be
applicable to DWSRF programs.
The information in this guide is drawn primarily from existing state policies, with special thanks to Stacy
Barna of the Texas Water Development Board and the State-EPA SRF Workgroup for providing guidance
and information on the inner-workings of each unique state program. In addition, this guide contains
references to certain documents EPA believes would be helpful to state SRF programs as well as
suggestions for new and innovative practices that are not widespread among the states which could
promote the goals of the sustainability policy and benefit state CWSRF programs.
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STATE POLICIES AND PRACTICES
A. Planning Processes Supporting Sustainability
A primary focus ofEPA's Clean Water and Drinking Water Infrastructure Sustainability Policy is
to promote utility planning processes that support sustainable water infrastructure and
communities. The goal is for a robust planning process to occur during the development phase
of the project, before the infrastructure solution is selected and designed. This will allow the
utility to work with stakeholders in the community to ensure that the utility's goals also support
other relevant community priorities. It will also allow the utility to evaluate a range of
infrastructure options, including, as appropriate, conservation approaches, decentralized
treatment with centralized management, and green infrastructure based on factors such as
public health, water quality, and economic health. In support of more effective planning by
utilities, in February 2012 EPA released Planning for Sustainability: A Handbook for Water and
Wastewater Utilities. Developed after extensive input from utility managers and selected
states, the Handbook describes a series of steps utilities can take to enhance their existing
planning processes and ensure that infrastructure investments are sustainable and support
other relevant community goals. Although not specifically targeted to utilities applying for SRF
funding, the Handbook can provide SRF managers with useful information to help them
evaluate such applications.
1. Alternatives analysis including, as appropriate, green infrastructure and decentralized
options
States should encourage potential CWSRF borrowers to work with their communities to evaluate project
options, including those beyond traditional centralized wastewater solutions. Project options may be
evaluated on the basis of water quality, fiscal and economic Sustainability, and social criteria to
ultimately choose the best solution.
Identify Infrastructure
Needs That Support Utility
and Community Priorities
Identify Options to
Address Needs
Evaluate and Select
Options
Obtain Financing if
Necessary (CWSRF)
Construction
Operations, Maintenance,
and Replacement
Encouraging or assisting communities to undergo a comprehensive alternatives analysis can be an
effective method to expand the type of projects a CWSRF program will fund while potentially providing
communities with savings in life-cycle costs.
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A simple method for promoting sufficient planning processes is to provide funding for these activities.
The Oregon CWSRF program sets aside a $3 million reserve solely dedicated to funding planning
projects, while Texas offers assistance for planning and design separately from construction. In
addition, projects that have completed planning in Texas within three years of a planning loan will
receive priority for construction loans. Initiatives such as these can be especially useful for small and
disadvantaged communities that cannot always afford the upfront costs to undertake a comprehensive
alternatives analysis when determining what type of infrastructure project to pursue. When combined
with technical assistance, planning and design loans can lead these small and disadvantaged
communities to pursue new and innovative infrastructure designs such as green infrastructure, which
may end up saving the community money in the long term.
Failing septic and decentralized systems are a significant
water quality issue in many rural communities. Often, the
chosen solution to such a problem is to connect these
communities to an existing centralized treatment system
or to construct a new treatment plant to serve these
communities. However, new centralized treatment can
lead to unplanned and inefficient development patterns
and the inherent water quality issues it presents due to
increased impervious cover. In Minnesota, in order to
receive CWSRF funding, all unsewered communities must
analyze the alternatives using a Wastewater Treatment
Hierarchy and evaluate the feasibility of replacing failing
individual septic systems or installing a decentralized
cluster system before an expansion-based project such as
new centralized wastewater treatment. While the results
of such an analysis may determine that new centralized
treatment is the best option, this process ensures that all
viable alternatives are closely considered.
Minnesota Wastewater
Treatment Hierarchy
Replace failing septic systems
with new septic systems
Decentralized cluster system
Connect to existing
treatment system
Connect to existing treatment
system requiring an expansion
Construct new collection and
centralized treatment facility
From a financial standpoint, states can use EPA's Financial Alternatives Comparison Tool (FACT) to help
communities identify the most cost-efficient method to obtain financing for a wastewater infrastructure
project. This tool produces a comprehensive analysis that compares various financing options for a
proposed project by incorporating financing, regulatory, and other important costs. Communities can
use this tool to determine the best financing option, including combining funding from multiple sources,
to fund their wastewater infrastructure projects. FACT can also be used as a marketing tool to show
potential borrowers the financial benefits of using the CWSRF.
2. Interagency cooperation between funding sources and with other infrastructure agencies
By collaborating with other funding sources for wastewater infrastructure, CWSRF programs can identify
common and complimentary priorities for projects, help communities identify the most beneficial source
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of funding, and reduce the amount of paperwork and requirements for communities. In addition, by
aligning water infrastructure investments with housing and transportation, communities can ensure that
investments support local planning efforts, yield maximum returns for the community, and minimize
rework and disruption.
One method of encouraging coordination among multiple funding sources is to create workshops where
these entities can come together and directly engage communities in need of funding. In Arizona, the
Rural Water Infrastructure Committee (https://rwic.azwifa.gov/) accomplishes this through meetings
conducted throughout the state to discuss assistance options with government and nonprofit programs.
There is a focus on rural communities, and the committee is intended to be a "One Stop" source of
information for funding and technical assistance resources for rural communities seeking assistance with
infrastructure projects. Arizona also has a uniform project information form recognized by multiple
funding agencies allowing for the committee to direct communities to the appropriate funding source.
Similar to Arizona's initiative, The New York State Water and Infrastructure Co-Funding Initiative
(http://www.nycofunding.org/) provides potential borrowers with a central source of information and
single contact for government funding sources. In addition, New York has an online assessment tool
that communities can use to direct them to the appropriate government program to obtain financing.
In Kentucky, the facility plan for a potential project must take into consideration the community housing
and transportation needs in sizing wastewater infrastructure and choosing appropriate interceptor
alignments. Additionally, utilities are required to hold public meetings to discuss these facility plans and
respond to feedback and to identify certain efficiencies, such as replacing a sewer line, in advance of a
planned re-pavement of a street, not after. A simple policy like this can also stimulate dialogue in a
community on how water and wastewater infrastructure can affect the development of housing and
transportation patterns. Bringing together government agencies governing water and wastewater
infrastructure, transportation, and housing can result in better coordination to respond to infrastructure
needs. Without prior consultation and coordination as part of a comprehensive planning effort,
communities often struggle to provide the full range of infrastructure to meet the needs of new
development.
3. Capital Improvement Plans
A well designed Capital Improvement Plan can benefit utility operations by allowing for multiple
potential projects to be evaluated simultaneously to ensure that the most urgent and cost-effective
projects are funded first. A Capital Improvement Plan will also lead to a community planning for future
investments and ideally working with other community groups and departments to integrate these plans
within the community as a whole.
A Capital Improvement Plan in many ways functions as a priority list that a utility uses to determine
which capital projects are to be funded. If given the opportunity to evaluate these plans, CWSRF
programs can determine not just if a proposed project is feasible from an economic and engineering
standpoint, but if the project is being evaluated from a system-wide strategic standpoint. Ideally, a
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Capital Improvement Plan would be the result of a comprehensive alternatives analysis and asset
management plan to inform any decisions about what infrastructure projects a utility should pursue.
Capital Improvement Plans are eligible for CWSRF funding and can also be encouraged through financial
incentives and priority setting systems discussed later, or they can be required through threshold
criteria. For small and disadvantaged communities that do not have a capital improvement plan, CWSRF
programs may look to assist them to develop one either through staff guidance or through a partnership
with a nonprofit or other organization better equipped to meet the needs of these communities.
B. Community Sustainability
Development patterns in communities are greatly influenced by how investments are made in
infrastructure, including wastewater infrastructure. By focusing investments on revitalizing
existing communities and existing infrastructure, communities are less likely to confront
abandoned capacity with an insufficient rate base but instead, make communities more healthy
and livable. New infrastructure investments can be made in a manner to help ensure that any
new development is done in a more sustainable and environmentally friendly approach while
preserving existing open space. State CWSRF programs can work to promote these activities as
well as provide funding to disadvantaged communities that may otherwise have difficulty
obtaining funding.
1. Prioritizing investments in existing communities including the redevelopment of
previously developed communities or limits on infrastructure growth
This investment approach targets resources to support the repair, replacement, and upgrade of existing
infrastructure within the existing service footprint of a water sector utility. Such an approach can help
avoid unsustainable growth patterns where new infrastructure cannot be supported financially by rate
payers added through an extension of centralized treatment, or by existing ratepayers spreading out
over a wider footprint. Instead, this approach can support growth through infill resulting in more rate
payers per infrastructure dollar spent and, therefore, a more financially stable wastewater system.
Limits on how much growth a CWSRF program is willing to fund can be accomplished through a variety
of ways both in CWSRF regulation or state statutes. For example, the Iowa Administrative Code
explicitly prohibits funding projects for the "primary purpose of speculative growth" and states that
projects must serve existing users. In addition, any level of growth in a facility plan must be justified
with credible data. Rhode Island uses a similar approach by not funding infrastructure for growth or
economic development and only provides funding for wastewater projects that serve an environmental
needs area as determined by a local wastewater facilities plan. Both of these policies act to ensure that
wastewater infrastructure projects serve the primary purpose of environmental protection and promote
economic development in areas where public investments in infrastructure have already been made.
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STATE SPOTLIGHT
In Massachusetts, collection system projects are only eligible for funding if at least 85% of the
expected wastewater flow will be for flows in existence as of July 1, 1995. However, the state
CWSRF can fund a project not meeting this criterion if it serves areas designated as city or town
centers, rural village districts, or brownfields redevelopment areas, provided that concentrated
development is encouraged. In these cases, any new growth resulting from a collection system
expansion would likely not contribute to dispersed and inefficient development patterns. This
policy differs from the policies of Iowa and Rhode Island in that it is more inclusive and allows for
some growth in selected areas where it is deemed beneficial from an overall environmental
benefits perspective. This is also a comprehensive policy that leads into other sustainability
initiatives such as sustainable growth and brownfields remediation.
2. Encouraging sustainable growth
When water and wastewater infrastructure is extended for new developments, communities should
ensure that any new development results in communities with adequate transportation and housing
options along with a sufficient rate base. Such planned growth can result in more sustainable
development patterns as well as a more stable rate base to fully fund future infrastructure repairs and
upgrades.
In Maryland, the Priority Funding Areas Act of 1997 limited new growth to designated priority growth
areas including previously developed communities as well as enterprise zones and neighborhood
revitalization areas. The Act provides a focus for state investment to help limit development in
previously undisturbed environments. In addition, projects must be consistent with the County Water
and Sewer Plans. Any applicant for CWSRF funds must submit a map showing the project location within
a Priority Funding Area and demonstrate the project's consistency with a local land use plan. Land use
plans are reviewed by the Water Resources Planning Unit, which determines whether or not the
planning documents support the proposed project. While this policy did not originate in the CWSRF
program, it can be a template that state CWSRF programs can use to concentrate funding for projects
within enterprise zones and revitalization areas instead of previously undeveloped environments.
New Jersey has a Smart Growth Financing Program within the state CWSRF program that offers up to
75% of project costs at 0% interest with the rest offered at market rate. Projects eligible for this
program include those that serve Urban Centers and Urban Complexes designated by the State Planning
Commission, brownfields areas, and designated Transit Villages, as well as projects that replace on-site
septic systems in a way that is appropriate to a rural environment and does not result in growth-
inducement. New Jersey also allows funding for reserve capacity costs, such as excess project capacity,
in Smart Growth areas. In addition, through a partnership with the New Jersey Department of
Transportation (NJDOT), NJDOT will fully fund reserve capacity costs for projects that serve Urban
Centers, Urban Complexes, or Transit Villages.
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3. Brownfields redevelopment
The redevelopment of brownfields sites has the benefit of remediating on-site contamination as well as
promoting infill of previously developed land, which is consistent with an investment strategy supporting
existing communities. In some cases, the cost of remediating a brownfields site may be less than the cost
of new infrastructure on undeveloped land leading to an economic benefit in addition to an
environmental benefit. Because of the inherent flexibility of the CWSRF, the state CWSRF programs are
well poised to promote the cleanup and development of these sites and convert them from polluted
areas of urban land into vibrant communities.
Several states have separate brownfields remediation programs that can be effective partners in
redeveloping brownfields areas. Indiana has a separate brownfields Revolving Loan Fund (RLF) program
dedicated to funding brownfields projects. The Indiana RLF, while having a lower funding ability than
the CWSRF, can fund activities that the CWSRF cannot. For example, the CWSRF can only fund activities
directly related to water quality while the RLF can fund other activities such as asbestos and lead-based
paint removal as well as costs associated with the demolition and/or site preparation that are part of
the site cleanup and not directly related to water quality. Situations where one program can fund
activities that another cannot are prime candidates for co-funding projects where each program funds
certain portions of the same project. By doing this, larger projects may be funded by sharing the cost
across multiple funding sources. Coordinating priorities and funding can help both a CWSRF and
brownfields program meet common goals and assist more communities than they could if they worked
separately.
One of the roadblocks to moving brownfields projects forward is a lack of information on what the
condition of a particular site is and what the cost is for remediation. Because each brownfields site is
unique in its needs, the economic benefits of undergoing site remediation are unknown until a thorough
assessment has taken place. Communities that are reluctant to redevelop a brownfields site due to the
impression that it is too expensive may reconsider their options if they have a complete assessment that
shows that remediation is an affordable option and may even be less expensive than extending
infrastructure to land that is currently undeveloped. These types of assessments are eligible for CWSRF
funding provided that there is a reasonable prospect of developing a fundable project as a result. By
funding these studies, CWSRF programs can help communities make better decisions about which
infrastructure projects to fund and can help cultivate brownfields projects that may not have been
pursued without a complete site assessment.
4. Addressing the needs of disadvantaged communities
As stated in the Sustainability Policy, "priority for federal SRF construction financing and related subsidies
will be given to communities that could not otherwise obtain financing." Because many communities do
not have access to the bond market, CWSRF funding can be an important source of financing for needed
infrastructure improvements. In addition, for these disadvantaged communities CWSRF funding, along
with technical assistance and guidance, can provide such communities the financial resources needed for
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the planning and alternatives analyses necessary to support the long-term sustainability of their
wastewater infrastructure.
When determining how to categorize and define disadvantaged communities, most definitions from
CWSRF programs involve a number of socioeconomic factors such as median household income, poverty
rate, and unemployment rate. In addition, the population size of a community is also commonly used as
smaller communities are more likely to lack the technical, managerial, and financial (IMF) capacity to
properly manage wastewater systems compared to larger communities. To assist such communities,
Kansas provides a minimum of 10% of the total "Basic Program" and "Leveraging Program" funds to be
available for municipalities of 5,000 or less. Oregon has a similar policy and reserves 15% of total
available funds for communities of 5,000 or less. CWSRF program policies such as these ensure that a
certain amount of available funds are reserved for disadvantaged communities.
In most cases, CWSRF programs assist disadvantaged communities through longer loan terms, interest
rate reductions and, additional subsidization. Financial assistance for upfront planning and alternatives
analyses can be especially useful for such communities to ensure that the most cost effective
infrastructure solution is chosen to meet the specific needs of a community. For example, Iowa and
New York assist communities in planning for future infrastructure investments by offering 0% interest
loans for planning activities while several other states offer reduced interest rates for short-term loans
that can also be used for planning purposes. In addition, technical assistance, especially for IMF
capacity development, can also be funded by CWSRF activities to assist small and disadvantaged
communities. Interest rates, additional subsidization, and other financial incentives along with technical
assistance initiatives that can benefit small and disadvantaged communities are discussed later.
5. Open space preservation through land acquisition and conservation projects
Aside from traditional grey infrastructure and even new and innovative green infrastructure, open space
preservation can be an integral part of a community's water protection program by protecting natural
watersheds and providing buffers between development and water resources. While these projects may
be difficult to finance due to a lack of repayment sources, many innovative financing mechanisms,
discussed later, can make this possible.
Protecting open space and undeveloped land can be an effective method of source water protection by
providing a buffer from pollution sources and resulting in reduced treatment costs. A survey of the
treatment costs and watershed characteristics of 27 drinking water utilities found that for every 10%
increase in forest cover of the source area, chemical and treatment costs decrease by 20%.* The
simplest method that the CWSRF programs can use to protect open space is to encourage the funding of
projects on already developed land, as discussed earlier. However, if a project does include a significant
growth component, a CWSRF program may consider requiring that a portion of undeveloped land of
similar size be preserved to offset the new development in order for the project to receive funding. This
Ernst C. Protecting the Source: Land Conservation and the Future of America's Drinking Water. Trust for Public
Land and the American Water Works Association, Water Protection Series. 2004, 56 pp.
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would be similar to the compensatory mitigation of wetlands that is currently required when projects
cause adverse impacts on existing wetlands.
C. Sustainable Systems
The physical and financial sustainability of a wastewater system is vital to a community to
ensure that financial resources are used wisely to support broader community goals. This can
be accomplished in a variety of ways including decreasing long-term operating costs through
efficiency upgrades, ensuring an adequate revenue stream to fund operations, and having
sufficient staff expertise and experience to effectively manage a wastewater system. The state
CWSRF programs are well positioned to help and encourage communities to ensure the
sustainability of their wastewater systems, especially systems that are in most need and have
the most to benefit from these actions.
1. Water and energy efficiency
Upgrades or other eligible activities that lead to greater water and energy efficiency for wastewater
utility operations can have a dual effect of reducing costs for the utility while reducing the need for
limited natural resources. Because these activities can create significant cost savings, some have the
ability to pay for themselves over time. In addition to the CWSRF programs, many states have separate
agencies and programs dedicated to assisting public entities in identifying potential water and energy
efficiency improvements. The CWSRF programs can collaborate with these agencies and programs to
engage wastewater utilities. EPA is working with states and utilities to promote greater energy
efficiency through the development of energy management programs. The Agency has developed
Ensuring a Sustainable Future: An Energy Management Guidebook for Wastewater and Water Utilities
os the basis for its work with states and utilities. The Guidebook describes a step-by-step process for
utilities to assess their current energy usage, conduct energy audits, and identify actions to improve
energy efficiency.
The Vermont CWSRF has worked with Efficiency Vermont to notify the organization when owners of
water systems or wastewater treatment plants apply for loans to allow Efficiency Vermont to suggest
efficiency upgrades to conserve energy and water. Efficiency Vermont brings additional staff and
specialized expertise to help communities decrease their energy and water needs and bring down costs
to allow their wastewater systems to operate more efficiently. Efficiency Vermont in collaboration with
the state Water Supply Division has also held workshops to encourage the use of water and energy
conservation and to educate utilities on capacity development, long-term planning, rate structures, and
asset management.
The Massachusetts Department of Environmental Protection has partnered with the Massachusetts
Department of Energy Resources and several local utilities to perform energy audits at treatment
facilities and provide recommendations for efficiency upgrades. Their joint goal is to focus state CWSRF
and energy program investments to improve the energy efficiency of treatment facilities. In addition,
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the New York CWSRF program has partnered with the New York State Energy Research and
Development Authority to provide free energy audits on projects receiving American Recovery and
Reinvestment Act (ARRA) funding to identify energy saving measures. These examples showcase the
fact that many states have knowledge and resources within other state programs and agencies that can
be utilized with innovative partnerships.
2. Ensuring adequate revenues to finance, operate, maintain, and replace essential
infrastructure assets
Traditionally, user charges supporting wastewater
infrastructure have not reflected the full costs of the
long-term maintenance and eventual replacement of the
system, which has resulted in delayed maintenance, and
in many cases, increased long-term costs. Utilities with
rate structures covering the full cost of operations will be
in a better position to maintain wastewater systems and
be less dependent on financial subsidies, including those
provided by CWSRF programs.
Kentucky currently has a contract with the Kentucky
Rural Water Association's Utility Optimization Program
to evaluate the user rates for selected utilities to
determine their long-term viability and to help ensure
that revenue is sufficient to cover costs for operations,
maintenance, and the eventual replacement of
infrastructure. This is part of a broad review of the
overall capacity for systems being reviewed. This
contract is funded through the DWSRF set-aside funds
for drinking water systems only; however CWSRF
programs may use similar contracts if funding is
available. Many states have similar trade organizations
or nonprofit entities that specialize in such assistance.
Cooperative partnerships, such as what is occurring in
Kentucky, can be invaluable in cultivating the long-term
financial sustainability that many rural and small utilities
need.
3. Asset management
ENVIRONMENTAL FINANCE CENTERS
EPA provides grant funding to 10
university-based environmental
finance centers (EFC), linked through
their coordinating network. The EFCs
can work with state SRF programs to
provide technical assistance and
guidance on a number of different
issues. Since 2007, Georgia has
worked with the EFC at the University
of North Carolina to complete a survey
of water and sewer systems in the
state to collect information on user
rates as well as rate structures. This
information is organized in a
"dashboard" on the EFC website,
which allows communities to compare
user rates and structures in a chosen
geographic area to evaluate how their
user rates and structures compare
with neighboring communities based
on a number of factors including
number of connections, revenue
generation, and water source.
Information on median household
income is also available to assess the
affordability of varying user rates and
rate structures.
Understanding the basic facts about a wastewater system's assets is paramount for sound management,
both from a financial and an operations standpoint. Basic asset management practices such as
determining the desired level of service, inventorying existing assets, setting replacement schedules
based on risk assessment, and assessing full life-cycle costs can help ensure effective management of
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existing and planned infrastructure investments. Proper asset management is also the foundation for
capital improvement plans, project selection, and can help ensure funding strategies meet long-term
needs.
The New Mexico CWSRF requires all "at risk" utilities (as determined by the state) to provide asset
management plans as a condition to receive funding. Often, the communities in most need of a
comprehensive asset management plan are those in financial risk. Mismanagement of infrastructure
assets or simply not understanding the full extent of a system's assets can lead to financial resources
being targeted in the wrong places and increased costs in the future. Providing financial assistance to
such communities can result in a less than optimal use of available funds and may result in rewarding
systems with subpar management and operations. By directing funding towards facilities with proper
asset management, potential financial issues can be prevented from occurring and the need for a
community to receive future subsidized financial assistance can be reduced.
The Maine DWSRF program has required asset management training for selected community officials as
a requirement for receiving any disadvantaged community assistance. The goal of this training is to
produce an asset management plan that the community can use in the future. With this approach,
CWSRF assistance can be used as a method or incentive to introduce communities to the benefits and
necessity of a proper asset management plan. Although this is currently a policy of Maine's DWSRF
program, it could easily be applied to a CWSRF program as a requirement for any community receiving
additional subsidization or for financial assistance in general.
4. Partnering or restructuring of wastewater operations
Small communities with proportionally small wastewater systems often have trouble finding the
resources to operate and maintain their systems. One potential solution to this problem is to partner
with other systems or consolidate the management and administrative tasks from a number of nearby
small systems into a larger regional system that can share resources and decrease operational costs.
The partnering or restructuring of a wastewater system can mean two or more communities sharing
management staff and selected maintenance activities, connecting to a common system, or sharing
portions of a system. These types of arrangements should be considered as viable alternatives to
constructing redundant treatment systems or continuing financial assistance to communities that could
increase efficiency through the restructuring of operations. There are varying degrees in which
partnering arrangements can be made from sharing equipment or staff to creating a regional
wastewater utility. The degree to which a community might consider such an arrangement will depend
on its unique needs, but in many cases partnering or restructuring some portion of operations can
eliminate unnecessary duplication of resources and result in significant savings. State CWSRF programs
can encourage partnering or restructuring through its inclusion in the alternatives analysis that a
community undergoes when it is considering what type of project to pursue. In addition, many small
communities may benefit from technical assistance from either their CWSRF program or from various
nonprofit or trade organizations that have the necessary technical expertise to determine the most
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viable solution from an economic and technological standpoint. The following table shows various ways
that wastewater utilities can partner or restructure to increase efficiency and achieve desired
environmental results.
PARTNERING & RESTRUCTURING CONTINUUM
Increasing Transfer of Responsibility
INFORMAL COOPERATION
Work with other systems
but without contractual
obligations
Examples:
• Sharing equipment
• Bulk supply purchases
• Mutual aid
agreements
CONTRACTUAL ASSISTANCE
Requires a contract, but
contract is under system's
control
Examples:
Contracting
operations &
management
Outsourcing
engineering services
JOINT POWERS AGENCY
Creation of a new entity
by several systems that
continue to exist as
independent entities (e.
Regional Water System)
Examples:
• Sharing system
management
• Sharing operators
OWNERSHIP TRANSFER
Transfer of ownership to
existing or newly created
entity
Examples:
• Acquisition with or
without physical
interconnection
• One system
transferring
ownership to become
a larger system or a
new entity
Adapted from 2007 EPA report, "Restructuring and Consolidation of Small Drinking Water Systems - A Compendium of State
Authorities, Statutes, and Regulations"
5. Building technical, managerial, and financial (TMF) capacity to support sustainable
systems
Some systems face a combination of technical, managerial, and/or financial (TMF) challenges that may
inhibit their ability to become sustainable and provide services. Appropriate training and sufficient
knowledge is necessary for a fully functional utility operation, and many states currently have programs
that provide training opportunities to assist communities, particularly small communities. Sufficient TMF
capacity can ensure proper management of a system, making loans less risky and ultimately making the
community less reliant on CWSRFsubsidies in the long term.
In Minnesota, when a decentralized cluster system is proposed, it is required that a community produce
a centralized management plan detailing a responsible party for the maintenance and upkeep of the
system. In addition, the community must produce a financing plan with dedicated revenues for
operations and maintenance and debt service, as well as a management plan with a schedule for
inspections, pumping, and repair/replacement. This type of requirement can ensure that a
decentralized system will have an identified responsible entity for the maintenance and upkeep of the
system along with the necessary revenues for long-term maintenance. Without proper maintenance,
decentralized systems can fall into disrepair necessitating future expenditures for replacement or
eventually a connection to centralized treatment.
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The California DWSRF program has developed a web-based tool called the IMF TuneUp
(http://neien.des.ucdavis.edu/tmf/) that utilities can use to measure their IMF capacity. There are a
variety of topics covered in the tool including the age of infrastructure, staffing issues, financial issues,
and general knowledge of the water system. As a result of this assessment, systems with low scores can
receive a training plan that can help them plan for infrastructure replacement as well as improve the
management and maintenance of the existing infrastructure. Such a tool can be especially useful for
small and disadvantaged communities that may not be aware of an issue in their IMF capacity or the
training opportunities that they can utilize. Washington also has a similar tool targeted at small
communities (http://www.doh.wa.gov/ehp/dw/Programs/capacity2.htm).
STATE SPOTLIGHT
An effective way to address concerns of utility system sustainability with potential borrowers is to
work with nonprofits or other organizations that specialize in working with small and rural
communities. Idaho currently has a contract with the Rural Community Assistance Corporation to
assist small communities with capacity development. Organizations such as this may have more
experience working with disadvantaged communities and may be able to provide more effective
assistance than the CWSRF or other state programs. Partnerships like this can be used to engage
communities on a number of system sustainability issues, including assistance with rate structures
and the development of an asset management plan. Additionally, CWSRF programs may not have
the resources to provide continued guidance once financial assistance is provided. Issues
surrounding technical, managerial, and financial capacity do not end when loans are approved, and
providing continued guidance after the issuance of loans can greatly improve the long-term
viability of a system. By doing this, problems down the road, such as the deterioration of
infrastructure and service, may be avoided and these small and disadvantaged communities may
become less reliant on state assistance to meet their needs.
FINANCIAL INCENTIVES AND MECHANISMS
The inherent financial flexibility allowed in the CWSRF programs has been vital to their success.
This flexibility has allowed the states to tailor their funding strategies to provide assistance to
communities while maintaining the long-term viability of the fund. Financial incentives such as
interest rate reductions have long been used in pursuing certain funding priorities such as
disadvantaged communities; while additional subsidization in many cases has been used for
green projects. However, many states utilize the full flexibility of the program using more
innovative funding mechanisms, many of which can be used to target projects meeting the goals
of the sustainability policy.
The most common method in which states use financial incentives to promote certain practices is
through interest rate reductions. Many states base their interest rates largely on the financial status of
the community, with lower rates available for disadvantaged communities. Other states target their
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interest rates more narrowly. For example, as previously mentioned New Jersey offers 75% interest-
free loans for projects with a "smart growth" designation while states like Colorado and South Dakota
offer reduced interest rates for nonpoint source projects. Iowa and New York assist communities in
planning for future infrastructure investments by offering 0% interest loans for planning activities while
several other states offer reduced interest rates for short-term loans that can also be used for planning
purposes. In addition to interest rate reductions, another more nontraditional way of reducing annual
repayment costs for a community is through extended term financing that allows for financing terms of
up to 30 years through purchases of local debt to spread the cost of repayment over a longer period of
time. This type of financing option is most commonly provided to disadvantaged communities.
Since the implementation of the American Recovery and Reinvestment Act in 2009, states have had the
option of providing additional subsidization to communities in the form of principle forgiveness, grants,
or negative interest loans. While Congress provided this authority to benefit communities unable to
otherwise afford a loan, some states further restrict the use of this authority to avoid its use to subsidize
unsustainable infrastructure. For example, Texas will not provide additional subsidization to
disadvantaged communities for projects that expand centralized treatment for growth, while South
Carolina will only provide additional subsidization to communities with sufficient technical, managerial,
and financial (TMF) capacity. These are examples of policies that ensure that any additional
subsidization is used wisely and not provided for growth-centric projects or to systems that do not have
the capability of managing and maintaining their proposed infrastructure project. In addition, South
Carolina offers additional subsidization to communities that take ownership of non-viable wastewater
systems as a way to incentivize the partnering or restructuring of operations.
PASS-THROUGH LOANS
CWSRF receives
loan repayment
Aside from traditional financing mechanisms for assisting certain communities or promoting certain
types of projects, there are a number of innovative financing mechanisms that can attract new types of
borrowers as well as promote more innovative
projects. One of the roadblocks to funding nonpoint
source projects and many green projects is that it is
frequently difficult for potential borrowers to secure a
dedicated source of repayment. However, conduit
lending mechanisms such as pass-through and linked
deposit loans allow for these types of projects to be
funded. For pass-through loans, a CWSRF program
makes a loan to another government agency that then
provides funding to private borrowers for projects.
Assistance can be provided to borrowers in the form
of loans or even grants. Linked deposit loans are
similar except the CWSRF works with a bank by
purchasing a certificate of deposit (CD) at a reduced
rate in exchange for the bank providing below market
rate loans to borrowers. In both of these scenarios,
the risk and management for the loans are placed
CWSRF provides
funding to local
or state agency
o
T
•
Government Agency
Low-interest
loan or grant to
borrower
I
Borrower
repays agency
for any loans
Borrower
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LINKED DEPOSIT LOANS
CWSRF
purchases CD at
reduced rate
o
CWSRF receives
low interest
return
with the government partner or bank that can allow
for a number of smaller projects to be funded that
may be too cumbersome in number to be effectively
managed by a CWSRF program. For traditional CWSRF
assistance, the borrower (e.g. the entity managing
project construction) must have a dedicated source of
repayment for the loan, but in these mechanisms it is
the bank or government agency that must secure a
source of repayment. Additionally, some smaller
borrowers such as homeowners or farms may be
more comfortable working with local banks or local
government agencies than the state CWSRF program.
Another innovative approach to providing financial
assistance to communities is through portfolio
financing. In this type of agreement, the CWSRF
program agrees to fund multiple projects or project
phases that are part of a larger infrastructure plan. This type of agreement can be very effective when it
is linked to a capital improvement plan detailing proposed infrastructure projects and how they
integrate with the community as a whole. While assistance agreements would only be made once each
individual project or phase is ready for construction, there would be an agreement to fund the rest of
the project portfolio as each project is ready to proceed. This would have benefits for the CWSRF
program in that it introduces multiple projects into the pipeline and would benefit the participating
community in that it would give assurance that financing is available for multiple projects to assist with
long-term planning.
Low-interest
loan provided to
borrower
©
J
4
©
Borrower
repays loan to
bank
1 Borrower
STATE SPOTLIGHT
For a number of years, Ohio has run very successful sponsorship and linked deposit programs to
fund a variety of projects. From 2000 through 2010, Ohio's Water Resource Restoration Sponsor
Program has provided over $121M in funding for 82 projects. In this program, a Publicly Owned
Treatment Works (POTW) agrees to add the cost of a nonpoint source project to their loan in return
for a reduced interest rate. This arrangement can work best when the complete project costs the
POTW the same or slightly less as a combined project than it would have as a traditional treatment
works project at normal CWSRF interest rates. This also removes the repayment responsibility from
the nonpoint source project and can result in more nonpoint source projects being funded. In
addition, Ohio's Linked Deposit program has provided over $75.5M in funding for 1,955 projects
from 1993 through August 2011. While the sponsorship program has primarily focused on wetlands
and other restoration projects, Ohio's Linked Deposit program has mostly funded projects
supporting agricultural best management practices. However, the linked deposit program has also
funded 93 projects addressing home sewage treatment systems illustrating how a wide variety of
project types can be funded using this type of financing mechanism.
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PROJECT PRIORITY SYSTEM CRITERIA
The most common method that states use to set priorities for the types of projects to be funded
are the priority setting systems used to rank and evaluate projects. The criteria used for these
systems vary widely from state to state but generally include categories such as water quality
benefits, public health considerations, compliance with state and federal regulations, and the
financial need of the community. In addition, most states have criteria tailored to the individual
priorities for their state to further refine the ranking of projects beyond the most important
factors. States generally fund projects in the order they are ranked with bypass provisions
related to readiness to proceed to ensure that CWSRFfunds are utilized in a timely manner.
The topics related to the Clean Water and Drinking Water Sustainability Policy are already commonly
addressed in the priority setting systems of many states. While criteria addressing these issues often
have a small value compared to categories related to water quality, including sustainability measures in
a priority setting system can have an effect on how projects are ranked if the system is properly
designed. For example if a priority setting system has 500 available points and sustainability criteria
accounts for only 10 of these points, it is unlikely that a project qualifying for these points will change in
ranking. However, a system with 100 available points and 10 points from sustainability is more likely to
result in a change in ranking for projects that include these elements. When considering revisions to the
project priority system it is important to ensure that sustainability criteria have a noticeable effect on
project ranking while preserving the importance of priorities relating to water quality and public health
that the CWSRF program is intended to address.
It is inevitable that project priority system criteria will have to be revised periodically to conform to
changing state and programmatic priorities. However, it will likely take several years for a revised
project priority system to have a measurable effect on the type of projects being funded, as
communities may be slow to adapt to changing priorities. Therefore, while criteria may still be slightly
adjusted on an annual basis to make it clearer and more effective, initiating major changes to setting
priority systems on an annual or semi-annual basis will likely create confusion for potential borrowers
and dissuade them from trying to adjust to changing priorities. Instead, whenever a major change is
made to a priority system it is likely best that the effects of such a change are closely monitored and
evaluated for several years before attempting any additional major changes.
One of the most effective ways to effectively communicate a state's unique wastewater infrastructure
priorities is through its project priority system. States should present their priority system in a clear and
readily understandable way and include it in their Intended Use Plan and marketing materials such as
brochures. In several states, priority systems are only accessible through state code or regulations and
in many cases can be difficult to find and understand. Unless state priorities are readily available and
easy to understand, potential borrowers will have little incentive or ability to submit projects that meet
these priorities. For example, states such as Alabama have a well organized, readily available, and easily
understandable project priority setting system included in their pre-application form ensuring that
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applicants are aware of the state's priorities before submitting a final funding application. By engaging
potential borrowers with information on a state's priorities relating to sustainability, communities will
have greater awareness of the benefits of sustainable practices and will have greater incentive to
include design elements supporting sustainability knowing that they are more likely to receive financial
assistance.
LOOKING FORWARD
As this Best Practices Guide illustrates, there are numerous examples policies and practices that state
CWSRF programs are already implementing that follow the principles outlined in EPA's Clean Water and
Drinking Water Infrastructure Sustainability Policy. EPA encourages states to explore these principles
further and continue to work with local communities to ensure the long-term environmental and
financial sustainability of their wastewater facilities and natural environments. Although the CWSRF
program only encompasses a portion of the total funding for wastewater infrastructure, the inherent
financial subsidy can be used as an effective mechanism for promoting activities such as asset
management and water and energy efficiency that have an upfront cost, but achieve long-term savings.
As state policies and practices continue to evolve, EPA will continue to provide a forum for states to
share new ideas and work together to promote sustainable wastewater systems.
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MATRIX OF PROJECT PRIORITY SYSTEM CRITERIA
Alternatives analysis including green
infrastructure and decentralized options
Interagency cooperation between funding
sources and with other infrastructure agencies
Capital Improvement Plans
Maryland has a cost efficiency criterion
that calculates the cost of a project in
comparison to either the pounds of
nutrient reduction, number of
households, drainage acres, or feet of
stream or shoreline restoration
(whichever is most applicable). While this
calculation is done by the CWSRF and not
the community, it can be used to ensure
that the most cost-effective projects are
funded.
Indiana provides points to projects that
have undergone a complete life-cycle cost
analysis used in an alternative selection
process. This provision incentivizes
communities to consider alternative
project options.
Florida has a cost-to-benefit index
provision that adjusts a project's score
based on the total cost of the project to
its priority score (benefit). Vermont also
has a similar provision.
Mississippi has a cost efficiency category
based on the number of residences
served.
Maine provides priority points to projects
that utilize grant or loan money from
other sources such as USDA, CDBG, or
even the Maine Department of
Transportation.
Alaska and Maryland also have similar
provisions.
Idaho, Missouri, and Georgia provide
priority points for the submission of a
Capital Improvement Plan.
Several states including Texas, Alabama,
Kentucky, New Jersey, Utah, Tennessee,
and Rhode Island provide priority points
for a variety of facility plans, regional
plans, watershed management plans, and
growth plans. The submission of such
plans demonstrates that the community
has considered the broader effect of
wastewater infrastructure.
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MATRIX OF PROJECT PRIORITY SYSTEM CRITERIA
Prioritizing investments in existing communities
Encouraging sustainable growth
Alabama provides points to projects that do not contain a
"significant growth component". Growth is defined as new
centralized treatment, new or expanded collection systems,
treatment plant upgrades where the purpose is to increase the
design flow, or any publicly owned treatment works project to
serve future growth. There is a substantial number of points in
this ranking category that significantly discourages growth-
oriented projects.
In South Carolina, if the majority of the cost for a proposed project
is for growth, the project will not receive any priority points and
will rank last in order of priority. The project will not be scored on
any of the other criteria in the priority system.
Texas provides priority points for projects serving an unserved
area of an existing developed community. This is a way of
encouraging the expansion of a system to serve infill development.
Indiana provides a small number of points for rehabilitating a
facility that was constructed over 20 years ago in comparison to
newer facilities and provides fewer points to new interceptors
than to other needs categories.
New Jersey and Virginia both provide more points for system
rehabilitation than for new systems.
Maryland offers priority points to projects that provide for
"sustainable development," which refers to the growth in capacity
or new development in a "sustainable community" (e.g. proximity
to transit, brownfields, or Department of Housing and Community
Development designated Community Legacy Area)
New Jersey provides priority points to projects that serve
municipalities designated by the State Planning Commission to
encourage sustainable growth. These communities are generally
urban centers or other areas of dense development.
Connecticut provides a small number of points for projects
located within a Development Designation Community in
coordination with the Connecticut Housing Partnership Program.
Utah provides priority points to projects serving a Quality Growth
Community. A Quality Growth Community must enact plans and
ordinances regarding planning and land use decisions and
encouraging efficient use of infrastructure and water and energy
resources.
Ohio awards points to project applications that include a
sustainable growth plan, provided that the project is located in an
area covered by the plan, the plan identifies preferred
development areas, any new growth is located in those
development areas, and a variety of other criteria associated with
sustainable growth principles are met.
Rhode Island provides points to projects that prevent water
pollution within a growth center.
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MATRIX OF PROJECT PRIORITY SYSTEM CRITERIA
Brownfields redevelopment
Addressing the needs of
disadvantaged communities
Open space preservation
Indiana provides priority points if a
project involves the remediation or
redevelopment of a brownfields site in
conjunction with the Indiana Brownfields
Program. This provision has the benefit of
not only promoting brownfields
remediation, but also promoting
coordination between two different
funding programs.
New Mexico has a brownfields
redevelopment component that considers
both redevelopment potential and water
quality preservation. Redevelopment
potential is based on a number of factors,
including whether or not there are
potential investors, there is support from
the municipality, and its location relative
to transportation or commercial districts.
Idaho provides priority points for a project
that uses a brownfields site for facility
construction
Colorado provides priority points based
on both a ratio of sewer cost per family
and median household income (MHI) and
a ratio of total project cost per tap.
Idaho and New Hampshire both base
economic hardship on the ratio of the
monthly user charge to MHI, while
Indiana uses a ratio of the annual
wastewater user charge to MHI.
Nebraska uses a similar but more
incremental approach by taking a ratio of
the annual loan costs per person to MHI.
Illinois, Missouri, and New York all have
economic hardship criteria based solely
on MHI.
Alabama provides priority points for
projects that include components for
open space preservation.
Tennessee provides priority points for
projects with zoning regulations that
demonstrate preservation of green space.
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MATRIX OF PROJECT PRIORITY SYSTEM CRITERIA
Water and energy efficiency
Ensuring adequate revenues
Georgia provides priority system points for water and energy
efficiency upgrades, including leak detection and metering, along
with water reuse and recycling as part of separate green project
ranking criteria.
Massachusetts provides priority points for projects that include
energy efficiency upgrades. However, if the upgrades were
recommended by a third party audit, assessment, or feasibility
study, more points are available. This type of policy provides an
incentive not just to improve energy efficiency but also to ensure
that upgrades are undertaken as part of a comprehensive energy
audit.
In addition to water reuse, Florida provides priority system points
for residuals reuse.
Many other states including Texas, New Hampshire, Montana,
and Hawaii, provide some number of priority system points for
energy or water efficiency.
Florida provides priority system points for systems that have
developed appropriate rate structures and pricing to build,
operate, and maintain systems as well as for systems that have
explicitly allocated funds for the rehabilitation or replacement of
aging infrastructure.
In addition to awarding points to sewer systems with a full-cost
pricing user charge, Maryland also provides points to non-
sewerage projects with a dedicated fee system. This goes beyond
having a dedicated source of repayment for these projects to also
having a revenue stream that can be used for maintenance and
replacement.
Missouri, Georgia, and Alabama also have provisions in their
priority setting systems providing points to systems that utilize
some form of full-cost pricing.
Asset management
Partnering or restructuring of operations
Technical, managerial, and financial capacity
Texas provides priority points for the
inclusion of an asset management plan.
However, the number of points awarded can
vary based on the amount of information
and level of detail included in the plan.
Alabama, Georgia, Maryland, North
Carolina, and Idaho all provide priority
points for the submission of an asset
management plan.
South Carolina uses a sliding scale for
awarding points for restructuring with points
awarded for activities ranging from systems
taking ownership of another to cooperative
actions between systems.
Kentucky provides priority points for the
consolidation of wastewater systems as well
as the consolidation of septic systems into
clustered decentralized systems.
Several states including Missouri, North
Carolina, Indiana, and Georgia provide
priority points for the regionalization or
consolidation of system operations.
Illinois has a rating category for
operational excellence that awards
points based on an evaluation of the
operations of existing facilities.
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TOOLS AND RESOURCES
EPA, Clean Water State Revolving Fund Program - includes information on up to date program guidance
and requirements, contact information, and other available resources
http://www.epa.gov/cleanwatersrf
EPA, "Planning for Sustainability: A Handbook for Water and Wastewater Utilities":
http://water.epa.gov/infrastructure/sustain/upload/EPA-s-Planning-for-Sustainability-Handbook.pdf
EPA, Financing Alternatives Comparison Tool (FACT) - financial analysis tool to help compare the costs of
various financing tools for infrastructure projects
http://water.epa.gov/grants funding/cwsrf/fact.cfm
EPA, Check Up Program for Small Systems (CUPSS) - asset management tool for small water and
wastewater utilities for inventorying assets, maintenance, and associated costs:
http://water.epa.gov/infrastructure/drinkingwater/pws/cupss/index.cfm
EPA, State Revolving Fund Financial Planning Model -tool for state Clean Water and Drinking Water SRF
programs to plan future funding policies including bond issuances and additional subsidization
Available from EPA by request
Center for Neighborhood Technologies (CNT), Green Values Stormwater Management Calculator - assesses
cost-effectiveness and environmental benefits of green infrastructure options:
http://logan.cnt.org/calculator/calculator.php
EPA, "Ensuring a Sustainable Future: An Energy Management Guidebook for Wastewater and Water
Utilities": http://water.epa.gov/infrastructure/sustain/upload/Final-Energy-Management-Guidebook.pdf
EPA, Energy Use Assessment Tool for small and medium water and wastewater utilities - Allows a utility to
conduct a utility bill analysis to assess baseline energy use and costs prior to a full-scale energy audit
Available from EPA by request - EnergyUseTool@epa.gov
Energy Star/Portfolio Manager for water and wastewater utilities - tool for utility managers to manage
energy use and cost to compare performance against similar facilities:
http://www.energystar.gov/index.cfm?c=water.wastewater drinking water
EPA, "Asset Management: A Best Practices Guide":
http://www.epa.gov/ogwdw/smallsystems/pdfs/guide smallsystems assetmanagement bestpractices.pdf
EPA, "Asset Management: A Handbook for Small Water Systems":
http://www.epa.gov/ogwdw/smallsystems/pdfs/guide smallsystems asset mgmnt.pdf
EPA, "Setting Small Drinking Water Rates for a Sustainable Future - rate setting guide for small utilizes to
assess annual costs, revenue needs, reserve requirements, and setting user rates:
http://www.epa.gov/ogwdw/smallsystems/pdfs/guide smallsystems final ratesetting guide.pdf
EPA Environmental Finance Center Network: http://www.epa.gov/envirofinance/efcn.html
The following nonprofit organizations work closely with rural utilities on a variety of issues:
• Rural Community Assistance Partnership: http://www.rcap.org/
• Rural Community Assistance Corporation: http://www.rcac.org/
• National Rural Water Association: http://www.nrwa.org/
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