SEPA
United States
Environmental Protection
Agency
Review of the Allotment of
the Clean Water State
Revolving Fund (CWSRF)
Report to Congress
EPA-830-R-16-001 | May 2016
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
Contents
Executive Summary iii
Chapter 1: Introduction 1
Background 1
Chapter 2: Review of Current Allotment 5
Analysis 5
Chapter 3: Potential Changes to the Allotment Formula 7
Data Elements 9
Potential Allotment Formulas 10
Option 1 11
Option 2 11
Option 3 11
Analysis 11
Additional Considerations 12
Ability-to-Pay Set-Aside 13
Implementing Changes to the Allotment 14
Appendix A: Original CWSRF Allotment (per the Water Quality Act of 1987) and Current
CWSRF Allotment (FY 2015) A-l
Appendix B: CWSRF Allotments Based on CWNS 2012 and 2010 Population Data
Compared to Current Allotment B-l
Appendix C: Potential CWSRF Allotments Based on Options Presented in Chapters C-l
Appendix D: Example of Possible CWSRF Allotments including an Ability-to-pay Set-Aside D-l
Appendix E: CWNS 2012 Needs Category Definitions E-l
Tables
Table 1. Number of States with Current Allotments that are Adequate and Inadequate Compared to
Potential Allotments Calculated Using 2012 Needs and 2012 Population Data 6
Table 2. Summary of Allotment Formula Options 11
Table 3. Comparison of Potential Allotment to Current Allotment across the Three Options 12
Table 4. Comparison of Potential Allotment to Current Allotment across the Three Options (No Limitation
on Increases and Decreases) 12
Table A-l. Original and Current CWSRF Allotments for States, District of Columbia, and Puerto Rico A-l
Table A-2. Original and Current CWSRF Allotments for Territories A-2
Table B-l. Potential CWSRF Allotments Calculated Using CWNS 2012 Data in Comparison to Current
Allotments in order to Determine the Adequacy of Current Allotment B-l
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Table B-2. Potential CWSRF Allotments Calculated Using Census 2010 Data in Comparison to Current
Allotments in order to Determine the Adequacy of Current Allotment B-3
Table C-l. Potential CWSRF Allotments for States, District of Columbia, and Puerto Rico with Constraints
on Increases or Decreases C-l
Table C-2. Potential CWSRF Allotments for Territories with Constraints on Increases or Decreases C-2
Table C-3. Potential CWSRF Allotments for States, District of Columbia, and Puerto Rico with No Constraints
on Increases or Decreases C-3
Table C-4. Potential CWSRF Allotments for Territories with No Constraints on Increases or Decreases C-4
Table D-l. Example of Potential Allotment Including the Ability-to-Pay Set-Aside D-l
Figures
Figure 1. Percent Difference between Current Allotment and Allotment Based on 2012 Needs Data 6
Figure 2. Percent Difference between Current Allotment and Allotment Based on 2010 Population Data 7
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
Executive Summary
This Report to Congress (Report), Review of the Allotment of the Clean Water State Revolving Fund
(CWSRF), presents the results of the United States Environmental Protection Agency (EPA) review of
the current CWSRF allotment and its adequacy to address the water quality needs of eligible states,
District of Columbia, and U.S. territories (collectively referred to as States). EPA prepared this Report in
accordance with section 5005 of the Water Resources Reform and Development Act (WRRDA) of 2014.
Chapter 1 includes important background information. Section 205(c)(3) of the 1987 Water Quality Act
established the original allotment based on population, needs, and other factors that are complex and
difficult to discern. Over time, the original allotment was adjusted to accommodate small changes in
funding levels for the territories. For this report, the current allotment is defined as the allotment used
to disburse the FY2015 CWSRF appropriation.
Chapter 2 describes EPA's analysis and findings regarding the adequacy of the current allotment.
EPA compared the current allotment to potential allotments using the most recent Clean Watersheds
Needs Survey (CWNS) data and 2010 census population data. For this report, EPA considered the
allotment adequate if it distributed the appropriated funds to most States proportional to their
needs or population. Most States do not currently receive appropriated funds in proportion to their
reported needs or population, which demonstrates the inadequacy of the current allotment.
Chapter 3 provides possible options to update the allotment in the future. To select the data elements
for updated potential State allotments, EPA considered statutory requirements, consistency with past
approaches, reliability and availability of data sets over time, and the ability to measure water quality
and CWSRF program performance. As a result, EPA selected the following data elements:
• CWNS 2012 (2012 needs)
• 2010 Resident Population from the U.S. Census Bureau (2010 population)
• Water Quality Impairment Component Ratio (WQICR) from EPA
• Ratio of CWSRF Assistance to Federal Capitalization 2004-2014 from EPA (CWSRF
assistance ratio)
These data elements can be combined and weighted in a variety of ways to emphasize different
elements and determine the allotments for all States. For illustrative purposes, EPA presents three
options for potential allotments using the various data elements and provides a State-by-State break-
down of these allotments and the percent change from the State's current allotment (see appendix C).
In addition, this report explores ways that Congress could implement policy priorities using a set-aside
within the appropriation, such as the ability to pay set-aside. Congress has used the set-aside concept
in the past to implement funding for Native American Tribes and Alaskan Native Villages. In this
report, EPA illustrates this option using an ability to pay set-aside. A set-aside could be used with any
of the three potential options. Finally, to more adequately reflect changes overtime, EPA recommends
that Congress update the allotment on a regular schedule.
MI
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
IV
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
Chapter 1: Introduction
The US EPA prepared this Review of the Allotment of the Clean Water State Revolving Fund
(CWSRF) Report to Congress, hereinafter referred to as "this Report" in compliance with section
5005 oftheWRRDAof2014:
(a) REVIEW.—The Administrator of the Environmental Protection Agency shall conduct a
review of the allotment formula in effect on the date of enactment of this Act for allocation
of funds authorized under title VI of the Federal Water Pollution Control Act (33 U.S.C.
1381 et seq.) to determine whether that formula adequately addresses the water quality
needs of eligible States, territories, and Indian tribes, based on—
(1) the most recent survey of needs developed by the Administrator under section
516(b) of that Act (33 U.S.C. 1375[b]); and
(2) any other information the Administrator considers appropriate.
(b) REPORT.—Not later than 18 months after the date of enactment of this Act, the
Administrator shall submit to the Committee on Environment and Public Works of
the Senate and the Committee on Transportation and Infrastructure of the House of
Representatives and make publicly available a report on the results of the review under
subsection (a), including any recommendations for changing the allotment formula.
Section 5005 of WRRDA requires that this Report analyze the most recent survey of needs, which
is the CWNS 2012, and other relevant data, such as 2010 census population data, to determine
whether the current CWSRF allotment formula adequately addresses water quality needs nationwide
(Chapter 2). Potential approaches for updating the allotment formula are provided in Chapter 3.
Background
The CWSRF program was established to replace the
Construction Grants program as part of the Water Quality
Act of 1987 (P.L. 100-4). When the program was established,
the allotments for each of the 51 CWSRF programs (in the
50 states plus Puerto Rico) and the grants to the District of
Columbia and the U.S. territories were outlined in section
205(c)(3) of the act (Appendix A). For this report, the
allotments established in the Water Quality Act of 1987 are
referred to as the "original allotment."
The weighting and factors that were used to establish the
formula for the original allotment are not known. According
Key definitions:
Original Allotment: The allotment that was
established in section 205(c)(3) of the
Water Quality Act of 1987.
Current Allotment: The allotment that is in
effect currently and was used to disburse
funds from the FY2015 appropriation.
Potential Allotment: The allotment
calculated for the purposes of this Report
using the most recent data available.
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
to Allocation of Wastewater Treatment Assistance: Formula and Other Changes issued by the
Congressional Research Service (CRS)1:
Nowhere in the legislative history of Congress's final action on the 1987 amendments is
there a clear statement about the weighting or factors that went into the final allocation
formula—it is even difficult to guess. The conference report on the final legislation merely
states: "The conference substitute adopts a new formula for distributing construction grant
funds and the state revolving loan fund capitalization grants among states for fiscal years
1987 through 1990. The allotment formula for FY1986 is the same as under current law."
Further, this CRS report explains that the following factors were likely considered when the original
allotment was generated:
• Census population.
• Capital needs for Secondary Wastewater Treatment (category I)2, Advanced Wastewater
Treatment (category II), Infiltration/ Inflow (I/I) Correction (category III-A), and Sewer
Replacement/ Rehabilitation (category III-B) reported by the States in the Clean Water Needs
Survey (the predecessor to the Clean Watersheds Needs Survey).
• A hold harmless provision (to limit the decrease in a State's allotment).
• A minimum allotment.
Until fiscal year (FY) 2000, States received their portion of the CWSRF appropriation based on the
original allotment established in section 205(c)(3) of the Water Quality Act of 1987. Beginning in
FY 2000, the Pacific Trust Territories—which had been receiving 0.1295 percent of available funds—
were no longer eligible for a grant due to a change in their governing status. EPA adjusted the allotment
totals for all other recipients from FY 2000 forward to reflect the change. Starting in FY 2010, every
annual appropriation has increased the total allocation for the territories of American Samoa, Guam,
the Northern Mariana Islands, and the Virgin Islands to 1.5 percent. Prior to FY 2010, the sum total
allotted to these four territories in the original allotment was approximately 0.25 percent.3 The
allotment in effect currently was used to disburse the FY 2015 CWSRF appropriation, and is included
in Appendix A. For the purposes of this report, it is referred to as the "current allotment."
New relevant data has become available since the original allotment was adopted. The U.S. Census
Bureau has updated population estimates in three decennial censuses (i.e., 1990, 2000, and 2010).
EPA and the States have updated the needs estimates seven times (i.e., 1988, 1992, 1996, 2000, 2004,
2008, and 2012). Beginning in 1992, EPA expanded its data collection beyond traditional wastewater
infrastructure needs to include all needs eligible for funding under the CWSRF program. Categories for
1 Claudia Copeland, Allocation of Wastewater Treatment Assistance: Formula and Other Changes, (RL31073 (Washington, DC: U.S.
Congressional Research Service, 2014), http://nationalaglawcenter.org/wp-content/uploads/assets/crs/RL31073.pdf.
2 The names of categories are listed as referenced in CWNS 2012. More detailed definitions of each category are included in Appendix E.
3 The four territories have been eligible to receive up to 1.5 percent of an amount equal to the portion of the appropriation remaining after accounting
for the tribal set-aside. This new total amount was proportionally distributed to the territories based on their historical allotment percentages. It
is important to note that, if this provision is not included in subsequent appropriations, the amounts the territories receive will revert back to the
historical allotments.
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
Stormwater Management (category VI) and Nonpoint Source (NPS) Pollution Control (category VII)4
were first added for CWNS 1992. Beginning with the CWNS 2004 data collection, Recycled Water
Distribution (category X) and Decentralized Wastewater Treatment (category XII)5 were divided
into separate categories. Starting with CWNS 2008, some needs beyond what were eligible for
CWSRF funding—such as needs to fund new decentralized wastewater treatment systems for new
construction—became eligible for CWNS. These changes to CWNS allowed states to enter a broader
set of water quality needs. However, adequately documenting stormwater management, NPS pollution
control, and decentralized wastewater treatment needs was challenging for many states and needs in
these areas are underreported.
In addition, the CWSRF program has changed since its inception in order to provide assistance to a
broader range of wastewater infrastructure projects. The WRRDA of 2014 expanded the number of
eligible project types from 3 to 11. These changes in CWSRF eligibility are not reflected in the most
recent CWNS.
Learn more about:
Clean Water State Revolving Fund (CWSRF) at https://www.epa.gov/cwsrf;
and
Clean Watersheds Needs Survey at http://epa.gov/cwns.
4 NPS pollution control (category VII needs data were not collected for CWNS 2012.
6 For CWNS 2008, NPS pollution control: Individual/Decentralized Sewage Treatment (category VII-L) was renamed and renumbered to be
Decentralized Wastewater Treatment (category XII).
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
Chapter 2: Review of Current Allotment
As required by section 5005(a)1 of WRRDA, EPA reviewed the current allotment of the states,
District of Columbia, and U.S. territories (collectively referred to as States for the remainder of
this Report) as compared to the results of the CWNS 2012, which is the most recent survey of needs
developed by the Administrator under section 516(b) of the Clean Water Act, or CWA (33 U.S.C.
1375[b]). In addition, EPA compared state population as described in the 2010 Census residential
population to the current allotment.
For the purposes of this report, EPA considered the current allotment adequate if it distributed the
appropriated funds to most States proportional to their needs or population. Further, EPA identified a
State's current allotment as adequately reflecting its water quality needs if it is within +/- 10 percent
of its potential allotment. EPA concluded that the current allotment does not adequately reflect the
reported water quality needs or the most recent census population for the majority of States.
Analysis
The current allotment was compared to allotments calculated using (1) 2012 needs (categories I-VI,
X, and XII); and (2) 2010 population data. In both cases, the minimum allotment was 0.5 percent,
consistent with the original and current allotments. In addition, tribal and territory allotments were
calculated in a manner consistent with the current allotment. Tribal needs were addressed via a
statutorily required set-aside of 2 percent. U.S. territory needs were addressed via a 1.5 percent
set-aside (as has been mandated by the annual appropriation since FY 2010) that is distributed to
American Samoa, Guam, the Northern Mariana Islands, and the Virgin Islands proportional to their
2012 needs or 2010 population.
The current allotment adequately reflects the water quality needs for only 17 States when compared
to the potential allotment calculated using 2012 needs data. Nine of the States would have a potential
allotment within +/- 10 percent of their current allotment, and the remaining eight States, which
currently receive the minimum allotment, would continue to receive that allotment. Of the other 39
States, 22 States would be allotted between +/- 10-50 percent of their current allotment and 17 States
would have potential allotments that are greater than +/- 50 percent of their current allotments. See
Table 1, Figure 1, and Appendix B.
The current allotment adequately reflects the water quality needs for only 14 States when compared to
the potential allotment calculated using 2010 population data. Six of these States would have a potential
allotment within +/- 10 percent of their current allotment, and the remaining eight States would
continue to receive the minimum allotment. Twenty-nine States would be allotted between +/- 10-50
percent of their current allotment. Thirteen States would have potential allotments that are greater than
+/- 50 percent compared to their current allotments. See Table 1, Figure 2, and Appendix B.
In summary, most states do not currently receive appropriated funds in proportion to their reported
water quality needs or population, which demonstrates the inadequacy of the current allotment.
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Table 1. Number of States with Current Allotments that are Adequate and Inadequate Compared
to Potential Allotments Calculated Using 2012 Needs and 2012 Population Data
Number of States Based on:
2012 Needs 2010 Population
Adequate Allotments
Within +/- 10% of current allotment
Minimum States that will remain minimum States
9
8
6
8
Inadequate Allotments
Between +/-10-50% compared to current allotment
Greater than +/- 50% compared to current allotment
22
17
29
13
Northern
Mariana
Islands
(!,Salpan
V and
^ Tinian Jl
Legend
^^^^ Minimum states that will remain minimum states
1 Change in allotment within +/-1°%
| | Change in allotment between +/-11-50%
IIIIIIHII Change in allotment greater than +/- 50%
Data Sources: CWNS 2012 data and FY15 CWSRF Allotments
Not to Scale
Figure 1. Percent Difference between Current Allotment and Allotment Based on 2012 Needs Data.
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
Northern
Mariana
Islands
I Saipan
' and
Tinian
Legend
^^^ Minimum states that will remain minimum states
^^ Change in allotment within +/-1°%
[ Change in allotment between +/-11-50%
| | Change in allotment greater than +/- 50%
Data Sources: Census 2010 Population and FY15 CWSRF Allotments
Not to Scale
Figure 2. Percent Difference between Current Allotment and Allotment Based on 2010 Population Data.
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
Chapter 3: Potential Changes to the Allotment
Formula
Data Elements
This section discusses the four data elements suggested by EPA for consideration in developing a
potential allotment. In selecting these elements, EPA evaluated a number of factors, including:
• consistency with past approaches to developing the allotment formula;
• reliability and availability of the data sets over time; and
• the ability to measure water quality and CWSRF program performance.
As required by WRRDA, EPA includes data from the most recent needs survey, CWNS 2012.
1. CWNS 2012 Needs from EPA (2012 needs)6 from the following categories: Secondary
Wastewater Treatment (category I), Advanced Wastewater Treatment (category II),
Conveyance System Repair (category III), New Conveyance Systems (category IV),
Combined Sewer Overflow (CSO) Correction (category V), Stormwater Management
(category VI), Recycled Water Distribution (category X), and Decentralized Wastewater
Treatment (category XII).
It should be noted that CWNS 2012 underestimates water quality needs. The survey did not
collect needs for NPS Pollution Control (category VII) projects. In addition, needs were not
reported for all States in Stormwater Management (category VI) and Decentralized Wastewater
Treatment (category XII). States continued to report challenges in documenting needs in these
categories, as well as Combined Sewer Overflow Correction (category V) needs.
2. 2010 Resident Population from the U.S. Census Bureau7 (2010 population), which is a
population count of all people who are "usually resident" in a specified geographic area.
Population was a factor for the distribution of wastewater infrastructure funding prior to
1973. It was reintroduced as a factor for the construction grants allocation in 1977 and was
very likely a factor in developing the original CWSRF allotment.
Present resident population for 2010 was selected because counts from the decennial census
generally are regarded as more accurate on a State-by-State basis than population projections.
3. Water Quality Impairment Component Ratio (WQICR) from EPA, which is based on water
quality impairment information States submit to the EPA and is publicly available in the
6 CWNS 2012 data are available at http://www.epa.gov/cwns.
1 Population data for the states and the District of Columbia are from the 2010 population census available at http://quickfacts.census.gov/quickfacts/
table/PST045215/00. Population data for the territories are from International Programs, total population available at
http://www.census.gov/population/international/data/idb/informationGateway.php.
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
ATTAINS database.8 Water quality impairment data is used as part of the Water Pollution
Control Program grants (section 106 of the CWA) allotment formula. Using this data set will
provide a larger portion of the CWSRF appropriation to States with more impaired waters.
The addition of the WQCIR to the CWSRF allotment formula might compensate for the lack of
completeness in CWNS 2012 data in the areas of NPS pollution, stormwater, and decentralized
wastewater treatment. This data element, however, has limitations. Water quality standards set
a threshold that should not be exceeded for a specific pollutant to protect the designated use
for a specific body of water. For the WQICR, all impaired waters are considered equal; the
data do not indicate the extent of the impairment or the number of impairments. In addition,
the current design of the component ratio used by the Water Pollution Control Program might
favor coastal and Great Lakes states with significant shoreline miles.
4. Ratio of CWSRF Assistance to Federal Capitalization (2005-2014) (CWSRF assistance
ratio) from EPA, which represents the amount of CWSRF assistance provided to eligible
recipients per every federal grant dollar awarded to each CWSRF program for the most
recent 10-year period.
Including this ratio in the allotment formula might increase the allotment for States that have
greatly expanded project funding by leveraging their federal capitalization grants, implementing
loan guarantee programs, and taking other similar actions. It likely would not, however, increase
the allotment for a well-managed program that does not participate in those activities. Therefore,
it might encourage States to leverage federal funding even if they have no financial need.
Potential Allotment Formulas
The four data elements can be combined in a variety of ways to emphasize different elements. EPA
proposes three potential options for an allotment formula which are detailed below and summarized
in Table 2. The resulting potential allotments are found in Appendix C. Each of these options was
developed using the following guidelines:
• The District of Columbia and Puerto Rico are treated in the same manner as states.
• Needs are at least 50 percent of the formula.
• Population is at least 30 percent of the formula.
• The minimum allotment for states, the District of Columbia, and Puerto Rico remains
0.5 percent.
• Tribal needs continue to be addressed via a statutorily required set-aside. Starting in 2015,
the WRRDA requires a tribal set-aside of not less than 0.5 percent and not more than
2 percent of funds made available for the CWSRF program. EPA elects to set aside the full
2 percent.
Benita Best-Wong, EPA Office of Wetlands, Oceans, and Watersheds, August 13, 2015, memorandum to water division directors regarding 2016
Clean Water Act sections 303(d), 305(b), and 314 integrated reporting and listing decisions, https://www.epa.gov/sites/production/files/2015-10/
documents/2016-ir-memo-and-cover-memo-8_13_2015.pdf. Data are publicly available at https://www.epa.gov/waterdata/assessment-and-
total-maximum-daily-load-tracking-and-implementation-system-attains.
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
• U.S. territory needs continue to be addressed via a 1.5 percent set-aside (as has been
mandated by the annual appropriation since FY 2010). The set-aside is distributed to
American Samoa, Guam, the Northern Mariana Islands, and the Virgin Islands according to
the same allotment formula developed for the states. Each territory receives no less than 15
percent of the set-aside.
• Allotments cannot decrease more than 25 percent or increase more than 200 percent.
Option 1
Option 1 uses only 2012 needs and 2010 population, the two data elements most likely used to
develop the original allotment of CWSRF funds. By relying heavily on needs data, this option does not
take into consideration the full breadth of water quality issues, particularly stormwater management,
decentralized wastewater treatment, and NPS pollution control needs. It also does not give credit to
States for expanding available funding by leveraging or other means.
Option 2
Option 2 uses three data elements: 2012 needs, 2010 population, and the WQICR. The WQICR
is introduced primarily to compensate for the known weaknesses in needs data in the areas of
stormwater management, decentralized wastewater treatment, and NPS pollution control. However, it
also does not give credit to States for expanding available funding by leveraging or other means.
Option 3
Option 3 uses all four data elements: 2012 needs, 2010 population, the WQICR, and CWSRF
assistance ratio. The addition of the CWSRF assistance ratio introduces a measure of program
management into the allotment formula, and encourages responsible leveraging of funds.
Table 2. Summary of Allotment Formula Options
Option 1
Option 2
Option 3
2012 Needs
70%
50%
50%
Water Quality Impairment Ratio of CWSRF Assistance
2010 Population Component Ratio to Federal Capitalization
30%
30%
30%
20%
10%
10%
Analysis
For the majority of States, the three options yield very similar results. This is due, in part, to limiting
decreases to 25 percent. With that limitation in mind, looking at all options, about one-third of the
States' allotments would increase. Of those States, only two to four States would have a potential
allotment that is more than double its current allotment. About half of the States would have a
potential allotment that is less than their current allotment. Of these States, about 15-17 States would
have their decreases limited to 25 percent. The remaining States currently receive the minimum
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
allotment and would continue to receive that allotment. Table 3 shows the number of States with
potential allotments that increase, decrease, and remain the same in comparison with the current
allotment for each of the three options.
Appendix C provides potential State-by-State allotments and the percentage change from the current
allotment.
Table 3. Comparison of Potential Allotment to Current Allotment across the Three Options
EPA chose to limit the percentage change in order to mitigate the immediate impact of a change in
the allocation formula. Because needs and population have changed dramatically over the past 30
years, adjusting the formula for the first time could result in significant changes for some States. Table 4
presents the results if no constraints are placed on increases or decreases.
Table 4. Comparison of Potential Allotment to Current Allotment across the Three Options (No Limitation on
Increases and Decreases)
mber of States with a Potential Allotment tlr
Option 1
Increases
between
0.1-99.9%
18
Increas
100%or I
13
Decreases
More than 25°/
13
Remains at
Minimum
Allocatioi
8
-62% to 216%
Option 2
17
14
15
-59% to 286%
Option 3
18
15
11
-59% to 231%
For purposes of this analysis, EPA chose to constrain the results in order to minimize the amount of
change any State would experience.
Additional Considerations
EPA suggests using some or all of the four data elements in determining allotments for all States.
Congress could choose a different combination of data elements, different weights for those data
elements, and different or no constraints to the percentage change in order to best serve their policy
goals.
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
In addition, Congress could decide to create a set-aside within the appropriation. A set-aside could be
used with any of the three options. The set-aside described below is one example.
Ability-to-Pay Set-Aside
One aspect of public financing for wastewater infrastructure that has traditionally affected resource
allocation decisions has been the ability of individual communities to pay for needed capital
investments through rate increases. The above options do not take into consideration the differences
in communities' ability to pay. The "ability to pay" could be included by developing a set-aside of the
annual appropriation to be distributed to a small number of States to assist them in closing the gap
between need and ability to pay. The set-aside could be distributed to eligible States in proportion to
their allotments. The States could be identified using one or a combination of the following factors:
• Median Household Income (MHI) from the U.S. Census Bureau's American Community
Survey, which includes the income of the householder and all other individuals 15 years
of age and older in the household, regardless of their relationship to the householder. The
median divides income distribution into two equal parts: one-half of the cases falling below
the median income and one-half of the cases falling above the median. Income is self-
reported by respondents via a questionnaire.
For example, states with an MHI that is 80 percent or less of the national average could be
eligible to receive a portion of the set-aside.
• Personal Income Per Capita (IPC) from the Bureau of Economic Analysis (BEA) is calculated
as the personal income of the residents of a given area divided by the resident population
of the area. In computing per capita personal income, BEA uses the Census Bureau's annual
midyear population estimates. Income is based on administrative records data.
For example, states with an IPC that is 80 percent or less of the national average could be
eligible to receive a portion of the set-aside.
• Percent of Population in Poverty from the U.S. Census Bureau, Small Area Income and
Poverty Estimates (Poverty) is calculated by identifying the number of people in poverty
and dividing by the total population. Poverty is defined by family. If total family income is
less than the established poverty threshold, then the entire family is considered in poverty.
Income is modeled using survey data, population estimates, and administrative records.
For example, states with a poverty rate that is 120 percent or more of the national average
could be eligible to receive a portion of the set-aside.
As an example, Appendix D outlines the results of implementing an ability-to-pay set-aside that is 2
percent of the appropriation. Starting with option 1 (calculating the allotment based on 70 percent
2012 needs data and 30 percent 2010 population data), states eligible for the set-aside are identified
based on a combination of MHI, IPC, and poverty data. In this example, any State that meets the
thresholds outlined above for one of these factors is eligible for a share of the set-aside. The result of
13
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
this example is to increase each eligible state's allotment by approximately 20 percent. Therefore, the
set aside is distributed to each eligible state proportional to their potential allotment.
This approach has limitations. Since the determination for the ability to pay set aside is determined
at the state level, it does not take into account the variation in ability to pay within a state (i.e. high
income communities v. low income communities). Additional guidance would be required to ensure
that the set- aside is achieving its intended purpose.
Implementing Changes to the Allotment
The current allotment was developed almost 30 years ago and has changed only slightly due to
small changes in funding levels for the territories (as discussed previously in Chapter 1). It does not
accurately reflect today's water quality needs or population in most States (as discussed in Chapter 2).
As discussed above, updating the allotment after three decades would likely result in large shifts to
States' allotments. To more adequately reflect changes over time, EPA recommends that Congress
update the allotment on a regular schedule.
A regular allotment calculation process could be achieved in a variety of ways. The allotment could
be updated in the fiscal year following the public issuance of a new CWNS Report to Congress and
its associated data (approximately every four years), similar to the Drinking Water State Revolving
Fund allotment process. Alternatively, the allotment could be updated after a set number of years.
During this update, the calculation would be populated with any new data made publicly available
since the previous update. Because the individual data elements are each updated at different time
intervals, new data might not be available for all data elements for every update. For example, the
ratio of CWSRF assistance to federal capitalization is updated annually and census population data are
updated every 10 years.
14
-------
Appendix A: Original CWSRF Allotment
(per the Water Quality Act of 1987) and Current
CWSRF Allotment (FY 2015)
Table A-1. Original and Current CWSRF Allotments for States, District of Columbia, and Puerto Rico
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Original Allotment
0.011309
0.006053
0.006831
0.006616
0.072333
0.008090
0.012390
0.004965
0.004965
0.034139
0.017100
0.007833
0.004965
0.045741
0.024374
0.013688
0.009129
0.012872
0.011118
0.007829
0.024461
0.034338
0.043487
0.018589
0.009112
0.028037
0.004965
0.005173
0.004965
Current Allotment
(FY2015)
0.011352
0.006076
0.006857
0.006641
0.072610
0.008121
0.012437
0.004984
0.004984
0.034270
0.017165
0.007863
0.004984
0.045916
0.024467
0.013740
0.009164
0.012921
0.011161
0.007859
0.024555
0.034469
0.043653
0.018660
0.009147
0.028144
0.004984
0.005193
0.004984
A-1
-------
Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Appendix A: Original CWSRF Allotment (per the Water Quality Act of 1987) and Current CWSRF Allotment (FY 2015)
Table A-1. Original and Current CWSRF Allotments for States, District of Columbia, and Puerto Rico
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Origina,A,,otment
0.010107
0.041329
0.004965
0.111632
0.018253
0.004965
0.056936
0.008171
0.011425
0.040062
0.013191
0.006791
0.010361
0.004965
0.014692
0.046226
0.005329
0.004965
0.020698
0.017588
0.015766
0.027342
0.004965
Current
0.010146
0.041487
0.004984
0.112059
0.018323
0.004984
0.057154
0.008202
0.011469
0.040215
0.013241
0.006817
0.010401
0.004984
0.014748
0.046403
0.005349
0.004984
0.020777
0.017655
0.015826
0.027447
0.004984
Table A-2. Original and Current CWSRF Allotments for Territories
Territory
American Samoa
Guam
Northern Mariana Islands
Pacific Trust Territories3
Virgin Islands
Original Allotment
0.000908
0.000657
0.000422
0.001295
0.000527
Current Allotment (FY 2015)
0.005418
0.003920
0.002518
0.000000
0.003144
Note:
a Beginning in FY 2000, the Pacific Trust Territories were no longer eligible to receive CWSRF funding.
A-2
-------
Appendix B: CWSRF Allotments Based on
CWNS 2012 and 2010 Population Data
Compared to Current Allotment
Table B-1. Potential CWSRF Allotments Calculated Using CWNS 2012 Data in Comparison to Current
Allotments in order to Determine the Adequacy of Current Allotment
iKvffi|nMfi ^^j ^^H
Arizona
Florida
Guam
Colorado
Nevada
District of Columbia
Maryland
Nebraska
Kentucky
Virginia
New Jersey
% Allotment ($) Change from
Current Allotment Potential Allotment Current Allotment
0.006857
0.034270
0.003920
0.008121
0.004984
0.004984
0.024555
0.005193
0.012921
0.020777
0.041487
0.022143
0.078374
0.008250
0.016397
0.010042
0.009133
0.040296
0.008383
0.020396
0.032469
0.063783
222.9%
128.7%
110.5%
101.9%
101.5%
83.2%
64.1%
61.4%
57.9%
56.3%
53.7%
Potential Allotment with Increase between 10-50%
Kansas
Louisiana
Connecticut
Missouri
California
Oregon
0.009164
0.011161
0.012437
0.028144
0.072610
0.011469
Potential Allotment within V-10%
Indiana
Delaware
Idaho
Montana
New Mexico
North Dakota
South Dakota
Vermont
Wyoming
0.024467
0.004984
0.004984
0.004984
0.004984
0.004984
0.004984
0.004984
0.004984
0.012297
0.014837
0.015753
0.033848
0.085651
0.012692
0.024835
0.005000
0.005000
0.005000
0.005000
0.005000
0.005000
0.005000
0.005000
34.2%
32.9%
26.7%
20.3%
18.0%
10.7%
1.5%
0.3%
0.3%
0.3%
0.3%
0.3%
0.3%
0.3%
0.3%
B-1
-------
Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Appendix B: CWSRF Allotments Based on CWNS 2012 and 2010 Population Data Compared to Current Allotment
Table B-1. Potential CWSRF Allotments Calculated Using CWNS 2012 Data in Comparison to Current
Allotments in order to Determine the Adequacy of Current Allotment
Oklahoma
Ohio
North Carolina
Washington
Utah
New York
Rhode Island
Hawaii
Current Allotment
0.008202
0.057154
0.018323
0.017655
0.005349
0.112059
0.006817
0.007863
Potential Allotment
0.007869
0.054189
0.017299
0.016554
0.005000
0.104332
0.006290
0.007074
Potential Allotment with Decrease between 10-50%
Northern Mariana Islands
Alabama
Massachusetts
Texas
Alaska
Maine
Mississippi
Arkansas
Wisconsin
West Virginia
Puerto Rico
Virgin Islands
New Hampshire
Iowa
Pennsylvania
Georgia
0.002518
0.011352
0.034469
0.046403
0.006076
0.007859
0.009147
0.006641
0.027447
0.015826
0.013241
0.003144
0.010146
0.013740
0.040215
0.017165
0.002250
0.010097
0.028967
0.038652
0.005000
0.006337
0.007348
0.005000
0.020662
0.011797
0.009863
0.002250
0.006458
0.007961
0.022999
0.008877
Potential Allotment with Decrease Greater than 50%
South Carolina
Illinois
Minnesota
American Samoa
Tennessee
Michigan
0.010401
0.045916
0.018660
0.005418
0.014748
0.043653
0.005000
0.021341
0.007799
0.002250
0.005656
0.010249
% Allotment ($) Change from
Current Allotment
-5.2%
-5.6%
-6.2%
-6.5%
-6.9%
-7.7%
-10.0%
-10.6%
-11.1%
-16.0%
-16.7%
-17.7%
-19.4%
-19.7%
-24.7%
-24.7%
-25.5%
-25.5%
-28.4%
-36.3%
-42.1%
-42.8%
-48.3%
-51.9%
-53.5%
-58.2%
-58.5%
-61.7%
-76.5%
B-2
-------
Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
Appendix B: CWSRF Allotments Based on CWNS 2012 and 2010 Population Data Compared to Current Allotment
Table B-2. Potential CWSRF Allotments Calculated Using Census 2010 Data in Comparison to Current
Allotments in order to Determine the Adequacy of Current Allotment
Current Allotment
Potential Allotment
i Allotment ($) Change from
Current Allotment
Potential Allotment with Increase Greater than 50%
Arizona
Colorado
Georgia
Florida
Texas
Nevada
North Carolina
Utah
Guam
California
Potential Allotment with Increase beti
0.006857
0.008121
0.017165
0.034270
0.046403
0.004984
0.018323
0.005349
0.003920
0.072610
0.019948
0.015706
0.030222
0.058649
0.078539
0.008411
0.029740
0.008631
0.006301
0.116152
1 n cno/
190.9%
93.4%
76.1%
71.1%
69.3%
68.7%
62.3%
61.4%
60.7%
60.0%
Oklahoma
South Carolina
Arkansas
Tennessee
Virgin Islands
Alabama
New Mexico
Louisiana
Virginia
Washington
0.008202
0.010401
0.006641
0.014748
0.003144
0.011352
0.004984
0.011161
0.020777
0.017655
0.011696
0.014423
0.009091
0.019775
0.004199
0.014889
0.006424
0.014141
0.024967
0.020974
42.6%
38.7%
36.9%
34.1%
33.5%
31.2%
28.9%
26.7%
20.2%
18.8%
Potential Allotment within V-10%
Nebraska
Kentucky
Oregon
Mississippi
Delaware
District of Columbia
Idaho
Montana
North Dakota
South Dakota
Vermont
Wyoming
Pacific Trust Territories
0.005193
0.012921
0.011469
0.009147
0.004984
0.004984
0.004984
0.004984
0.004984
0.004984
0.004984
0.004984
0.000000
0.005693
0.013532
0.011937
0.009242
0.005000
0.005000
0.005000
0.005000
0.005000
0.005000
0.005000
0.005000
0.000000
9.6%
4.7%
4.1%
1.0%
0.3%
0.3%
0.3%
0.3%
0.3%
0.3%
0.3%
0.3%
0.0%
B-3
-------
Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Appendix B: CWSRF Allotments Based on CWNS 2012 and 2010 Population Data Compared to Current Allotment
Table B-2. Potential CWSRF Allotments Calculated Using Census 2010 Data in Comparison to Current
Allotments in order to Determine the Adequacy of Current Allotment
Pennsylvania
Kansas
Current Allotment
0.040215
0.009164
fttoOIMM
0.039544
0.008894
% Allotment ($) Change from
Current Allotment
-2.9%
Potential Allotment with Decrease between 10-50%
Connecticut
Northern Mariana Islands
Minnesota
Puerto Rico
Illinois
Indiana
Alaska
Maryland
Rhode Island
Michigan
Iowa
Missouri
New Jersey
Wisconsin
Hawaii
Maine
Ohio
Massachusetts
New York
0.012437
0.002518
0.018660
0.013241
0.045916
0.024467
0.006076
0.024555
0.006817
0.043653
0.013740
0.028144
0.041487
0.027447
0.007863
0.007859
0.057154
0.034469
0.112059
0.011135
0.002250
0.016521
0.011577
0.039946
0.020191
0.005000
0.018007
0.005000
0.030726
0.009489
0.018654
0.027388
0.017699
0.005000
0.005000
0.035901
0.020421
0.060356
-10.5%
-10.6%
-11.5%
-12.6%
-13.0%
-17.5%
-17.7%
-26.7%
-26.7%
-29.6%
-30.9%
-33.7%
-34.0%
-35.5%
-36.4%
-36.4%
-37.2%
-40.8%
-46.1%
Potential Allotment with Decrease Greater than 50%
New Hampshire
American Samoa
West Virginia
0.010146
0.005418
0.015826
0.005000
0.002250
0.005768
-50.7%
-58.5%
-63.6%
B-4
-------
Appendix C: Potential CWSRF Allotments Based
on Options Presented in Chapter 3
Table C-1. Potential CWSRF Allotments for States, District of Columbia, and Puerto Rico with Constraints on
Increases or Decreases
% Change % Change % Change
State Current Allotment Option la from Current Option 2b from Current Option 3° from Current
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
0.011352
0.006076
0.006857
0.006641
0.072610
0.008121
0.012437
0.004984
0.004984
0.034270
0.017165
0.007863
0.004984
0.045916
0.024467
0.013740
0.009164
0.012921
0.011161
0.007859
0.024555
0.034469
0.043653
0.018660
0.009147
0.028144
0.004984
0.005193
0.004984
0.010146
0.041487
0.011033
0.005000
0.020320
0.005000
0.090717
0.015515
0.013785
0.005000
0.006695
0.069502
0.014559
0.005975
0.005000
0.034437
0.022479
0.010305
0.010818
0.017597
0.014019
0.005894
0.032290
0.025852
0.032740
0.013995
0.007578
0.028123
0.005000
0.007270
0.009159
0.007609
0.050794
-2.8%
-17.7%
196.3%
-24.7%
24.9%
91.1%
10.8%
0.3%
34.3%
102.8%
-15.2%
-24.0%
0.3%
-25.0%
-8.1%
-25.0%
18.0%
36.2%
25.6%
-25.0%
31.5%
-25.0%
-25.0%
-25.0%
-17.2%
-0.1%
0.3%
40.0%
83.8%
-25.0%
22.4%
0.010697
0.005000
0.016651
0.005000
0.085481
0.013329
0.011613
0.005000
0.005001
0.091324
0.013990
0.005897
0.006140
0.034437
0.019873
0.010305
0.010519
0.014435
0.033232
0.005894
0.029054
0.025852
0.039307
0.017899
0.006992
0.022532
0.005000
0.006313
0.008674
0.007609
0.041644
-5.8%
-17.7%
142.8%
-24.7%
17.7%
64.1%
-6.6%
0.3%
0.3%
166.5%
-18.5%
-25.0%
23.2%
-25.0%
-18.8%
-25.0%
14.8%
11.7%
197.8%
-25.0%
18.3%
-25.0%
-10.0%
-4.1%
-23.6%
-19.9%
0.3%
21.6%
74.0%
-25.0%
0.4%
0.011086
0.005000
0.020330
0.005906
0.083277
0.014737
0.013915
0.005000
0.005633
0.076584
0.015508
0.006980
0.006847
0.034437
0.021660
0.010305
0.011434
0.016284
0.027923
0.006106
0.028795
0.025852
0.032740
0.015721
0.008137
0.023628
0.005000
0.007746
0.009668
0.007609
0.043098
-2.3%
-17.7%
196.5%
-11.1%
14.7%
81.5%
11.9%
0.3%
13.0%
123.5%
-9.7%
-11.2%
37.4%
-25.0%
-11.5%
-25.0%
24.8%
26.0%
150.2%
-22.3%
17.3%
-25.0%
-25.0%
-15.8%
-11.0%
-16.0%
0.3%
49.2%
94.0%
-25.0%
3.9%
C-1
-------
Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Appendix C: Potential CWSRF Allotments Based on Options Presented in Chapter 3
Table C-1. Potential CWSRF Allotments for States, District of Columbia, and Puerto Rico with Constraints on
Increases or Decreases
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
0.004984
0.112059
0.018323
0.004984
0.057154
0.008202
0.011469
0.040215
0.013241
0.006817
0.010401
0.004984
0.014748
0.046403
0.005349
0.004984
0.020777
0.017655
0.015826
0.027447
0.004984
^•JJlljTjJJJj^B
0.005000
0.087498
0.020103
0.005000
0.046736
0.008625
0.011947
0.030161
0.009936
0.005172
0.007800
0.005000
0.011061
0.048346
0.005000
0.005000
0.028984
0.017115
0.011870
0.020585
0.005000
% Change
from Current
0.3%
-21.9%
9.7%
0.3%
-18.2%
5.2%
4.2%
-25.0%
-25.0%
-24.1%
-25.0%
0.3%
-25.0%
4.2%
-6.5%
0.3%
39.5%
-3.1%
-25.0%
-25.0%
0.3%
Option 2b
0.005000
0.084044
0.020203
0.005000
0.042865
0.009182
0.011879
0.030161
0.009931
0.005113
0.007800
0.005000
0.011061
0.047631
0.005000
0.005000
0.027382
0.015596
0.011870
0.020585
0.005000
% Change
from Current Option 3°
0.3%
-25.0%
10.3%
0.3%
-25.0%
11.9%
3.6%
-25.0%
-25.0%
-25.0%
-25.0%
0.3%
-25.0%
2.6%
-6.5%
0.3%
31.8%
-11.7%
-25.0%
-25.0%
0.3%
0.005000
0.084044
0.020791
0.005000
0.042865
0.010660
0.012488
0.030161
0.009931
0.008416
0.007800
0.005000
0.011061
0.047112
0.005326
0.005000
0.028443
0.016498
0.011870
0.020585
0.005000
% Change
from Current
0.3%
-25.0%
13.5%
0.3%
-25.0%
30.0%
8.9%
-25.0%
-25.0%
23.5%
-25.0%
0.3%
-25.0%
1.5%
-0.4%
0.3%
36.9%
-6.6%
-25.0%
-25.0%
0.3%
Notes:
Increases are limited to 200 percent, and decreases are limited to 25 percent.
a Allotment calculated using 70 percent 2012 needs data and 30 percent 2010 population data.
b Allotment calculated using 50 percent 2012 needs data, 30 percent 2010 population data, and 20 percent WQICR data.
c Allotment calculated using 50 percent 2012 needs data, 30 percent 2010 population data, 10 percent WQICR data, and 10 percent ratio of CWSRF assistance
to federal capitalization data.
Table C-2. Potential CWSRF Allotments for Territories with Constraints on Increases or Decreases
US Territory
American Samoa
Guam
Northern Mariana
Islands
Virgin Islands
1% Change % Change % Change
Current Allotment Option la from Current Option 2b from Current Option 3° from Current
0.005418
0.003920
0.002518
0.003144
0.004063
0.006328
0.002250
0.002358
-25.0%
61.4%
-10.6%
-25.0%
0.004063
0.006328
0.002250
0.002358
-25.0%
61.4%
-10.6%
-25.0%
0.004063
0.006328
0.002250
0.002358
-25.0%
61.4%
-10.6%
-25.0%
Notes:
Increases are limited to 200 percent, and decreases are limited to 25 percent.
a Allotment calculated using 70 percent 2012 needs data and 30 percent 2010 population data.
b Allotment calculated using 50 percent 2012 needs data, 30 percent 2010 population data, and 20 percent WQICR data.
c Allotment calculated using 50 percent 2012 needs data, 30 percent 2010 population data, 10 percent WQICR data, and 10 percent ratio of CWSRF assistance
to federal capitalization data.
C-2
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress .
Appendix C: Potential CWSRF Allotments Based on Options Presented in Chapter 3
Table C-3. Potential CWSRF Allotments for States, District of Columbia, and Puerto Rico with No Constraints on
Increases or Decreases
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
% Change
Current Allotment Option la from Current Option 2b
0.011352
0.006076
0.006857
0.006641
0.072610
0.008121
0.012437
0.004984
0.004984
0.034270
0.017165
0.007863
0.004984
0.045916
0.024467
0.013740
0.009164
0.012921
0.011161
0.007859
0.024555
0.034469
0.043653
0.018660
0.009147
0.028144
0.004984
0.005193
0.004984
0.010146
0.041487
0.004984
0.112059
0.018323
0.011610
0.005000
0.021670
0.005000
0.095457
0.016326
0.014505
0.005000
0.007045
0.073134
0.015319
0.006288
0.005000
0.027068
0.023654
0.008483
0.011383
0.018516
0.014752
0.005730
0.033977
0.026656
0.016443
0.010466
0.007974
0.029593
0.005000
0.007649
0.009638
0.005806
0.053448
0.005000
0.092070
0.021153
2.3%
-17.7%
216.0%
-24.7%
31.5%
101.0%
16.6%
0.3%
41.3%
113.4%
-10.8%
-20.0%
0.3%
-41.0%
-3.3%
-38.3%
24.2%
43.3%
32.2%
-27.1%
38.4%
-22.7%
-62.3%
-43.9%
-12.8%
5.1%
0.3%
47.3%
93.4%
-42.8%
28.8%
0.3%
-17.8%
15.5%
0.011197
0.005000
0.017430
0.005000
0.089479
0.013953
0.012156
0.005000
0.005235
0.095595
0.014645
0.005420
0.006428
0.024238
0.020803
0.008112
0.011011
0.015111
0.043106
0.005022
0.030413
0.021594
0.041145
0.018736
0.007319
0.023586
0.005000
0.006609
0.009079
0.006197
0.043591
0.005000
0.077868
0.021148
% Change
from Current
-1.4%
-17.7%
154.2%
-24.7%
23.2%
71.8%
-2.3%
0.3%
5.0%
178.9%
-14.7%
-31.1%
29.0%
-47.2%
-15.0%
-41.0%
20.2%
16.9%
286.2%
-36.1%
23.9%
-37.4%
-5.7%
0.4%
-20.0%
-16.2%
0.3%
27.3%
82.2%
-38.9%
5.1%
0.3%
-30.5%
15.4%
Option 3°
0.011553
0.005000
0.022709
0.006155
0.086784
0.015358
0.014501
0.005000
0.005870
0.079809
0.016161
0.007274
0.007136
0.025669
0.022572
0.010676
0.011915
0.016970
0.029098
0.006363
0.030007
0.024174
0.029777
0.016383
0.008480
0.024623
0.005000
0.008072
0.010076
0.006761
0.044912
0.005000
0.077351
0.021667
% Change
from Current
1.8%
-17.7%
231.2%
-7.3%
19.5%
89.1%
16.6%
0.3%
17.8%
132.9%
-5.9%
-7.5%
43.2%
-44.1%
-7.7%
-22.3%
30.0%
31.3%
160.7%
-19.0%
22.2%
-29.9%
-31.8%
-12.2%
-7.3%
-12.5%
0.3%
55.5%
102.2%
-33.4%
8.3%
0.3%
-31.0%
18.3%
C-3
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Appendix C: Potential CWSRF Allotments Based on Options Presented in Chapter 3
Table C-3. Potential CWSRF Allotments for States, District of Columbia, and Puerto Rico with No Constraints on
Increases or Decreases
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
K^K jT£i]IE
HHHHHBIII^^_
0.004984
0.057154
0.008202
0.011469
0.040215
0.013241
0.006817
0.010401
0.004984
0.014748
0.046403
0.005349
0.004984
0.020777
0.017655
0.015826
0.027447
0.004984
% Change % Change % Change
Option la from Current Option 2b from Current Option 3° from Current
i
0.005000
0.049178
0.009076
0.012571
0.028125
0.010456
0.005443
0.005000
0.005000
0.009916
0.050872
0.005000
0.005000
0.030498
0.018009
0.010095
0.019948
0.005000
0.3%
-14.0%
10.7%
9.6%
-30.1%
-21.0%
-20.2%
-51.9%
0.3%
-32.8%
9.6%
-6.5%
0.3%
46.8%
2.0%
-36.2%
-27.3%
0.3%
0.005000
0.043725
0.009611
0.012434
0.025259
0.009714
0.005000
0.005716
0.005000
0.010075
0.049858
0.005000
0.005000
0.028662
0.016325
0.008478
0.018916
0.005000
0.3%
-23.5%
17.2%
8.4%
-37.2%
-26.6%
-26.7%
-45.0%
0.3%
-31.7%
7.4%
-6.5%
0.3%
38.0%
-7.5%
-46.4%
-31.1%
0.3%
0.005000
0.043849
0.011109
0.013014
0.026094
0.010022
0.008771
0.006958
0.005000
0.011405
0.049096
0.005551
0.005000
0.029641
0.017192
0.009376
0.019067
0.005000
0.3%
-23.3%
35.4%
13.5%
-35.1%
-24.3%
28.7%
-33.1%
0.3%
-22.7%
5.8%
3.8%
0.3%
42.7%
-2.6%
-40.8%
-30.5%
0.3%
Notes:
a Allotment calculated using 70 percent 2012 needs data and 30 percent 2010 population data.
b Allotment calculated using 50 percent 2012 needs data, 30 percent 2010 population data, and 20 percent WQICR data.
c Allotment calculated using 50 percent 2012 needs data, 30 percent 2010 population data, 10 percent WQICR data, and 10 percent ratio of CWSRF assistance
to federal capitalization data.
Table C-4. Potential CWSRF Allotments for Territories with No Constraints on Increases or Decreases
% Change % Change % Change
US Territory Current Allotment Option la from Current Option 2b from Current Option 3° from Current
American Samoa
Guam
Northern Mariana
Islands
Virgin Islands
0.005418
0.003920
0.002518
0.003144
0.002250
0.008250
0.002250
0.002250
-58.5%
110.5%
-10.6%
-28.4%
0.002250
0.007788
0.002250
0.002712
-58.5%
98.7%
-10.6%
-13.8%
0.002250
0.008172
0.002250
0.002328
-58.5%
108.5%
-10.6%
-26.0%
Notes:
a Allotment calculated using 70 percent 2012 needs data and 30 percent 2010 population data.
b Allotment calculated using 50 percent 2012 needs data, 30 percent 2010 population data, and 20 percent WQICR data.
c Allotment calculated using 50 percent 2012 needs data, 30 percent 2010 population data, 10 percent WQICR data, and 10 percent ratio of CWSRF assistance
to federal capitalization data.
C-4
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Appendix D: Example of Possible CWSRF
Allotments including an Ability-to-Pay Set-Aside
Table D-1 is an example of how the ability-to-pay set-aside, described on pages 13-14, could be
implemented. To clearly illustrate the results, the allotment is calculated both as a decimal and in
dollars. The allotment calculation is based on option 1-70 percent 2012 needs and 30 percent 2010
population. Seven States are identified as being eligible for the set-aside based on meeting the example
threshold for one or more of these factors: MHI, I PC, and poverty level. The calculated potential
allotment in dollars is based on the FY 2015 appropriation, which was a total of $1.45 billion. The
allotments for the U.S. territories of American Samoa, Guam, Northern Mariana Islands, and Virgin
Islands are capped at 1.5 percent by the appropriation process. Therefore, they are not eligible for
additional funding through this set-aside and are not included in this table.
Table D-1. Example of Potential Allotment Including the Ability-to-pay Set-Aside
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Eligible for Additional
Potential Allotment Potential Allotment ($) Ability-to-pay Set-Aside
0.011033
0.005000
0.020320
0.005000
0.090717
0.015515
0.013785
0.005000
0.006695
0.069502
0.014559
0.005975
0.005000
0.034437
0.022479
0.010305
0.010818
0.017597
0.014019
0.005894
0.032290
$15,071,000
$6,830,000
$27,757,000
$6,830,000
$123,921,000
$21,194,000
$18,830,000
$6,830,000
$9,145,000
$94,941,000
$19,887,000
$8,162,000
$6,830,000
$47,041,000
$30,707,000
$14,077,000
$14,777,000
$24,037,000
$19,151,000
$8,052,000
$44,108,000
$0
$0
$0
$2,132,000
$0
$0
$0
$0
$0
$0
$6,208,000
$0
$0
$0
$0
$0
$0
$0
$5,978,000
$0
$0
Total Potential
Allotment ($)
$15,071,000
$6,830,000
$27,757,000
$8,962,000
$123,921,000
$21,194,000
$18,830,000
$6,830,000
$9,145,000
$94,941,000
$26,095,000
$8,162,000
$6,830,000
$47,041,000
$30,707,000
$14,077,000
$14,777,000
$24,037,000
$25,129,000
$8,052,000
$44,108,000
D-1
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Appendix D: Example of Possible CWSRF Allotments including an Ability-to-Pay Set-Aside
Table D-1. Example of Potential Allotment Including the Ability-to-pay Set-Aside
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Potential Allotment Potential Allotment ($) Ability-to-pay Set-Aside Allotment ($)
0.025852
0.032740
0.013995
0.007578
0.028123
0.005000
0.007270
0.009159
0.007609
0.050794
0.005000
0.087498
0.020103
0.005000
0.046736
0.008625
0.011947
0.030161
0.009936
0.005172
0.007800
0.005000
0.011061
0.048346
0.005000
0.005000
0.028984
0.017115
0.011870
0.020585
0.005000
$35,314,000
$44,723,000
$19,117,000
$10,351,000
$38,417,000
$6,830,000
$9,930,000
$12,512,000
$10,394,000
$69,385,000
$6,830,000
$119,522,000
$27,461,000
$6,830,000
$63,842,000
$11,782,000
$16,320,000
$41,201,000
$13,573,000
$7,066,000
$10,656,000
$6,830,000
$15,110,000
$66,041,000
$6,830,000
$6,830,000
$39,592,000
$23,379,000
$16,214,000
$28,119,000
$6,830,000
$0
$0
$0
$3,231,000
$0
$0
$0
$0
$0
$0
$2,132,000
$0
$0
$0
$0
$0
$0
$0
$4,237,000
$0
$0
$0
$0
$0
$0
$0
$0
$0
$5,061,000
$0
$0
$35,314,000
$44,723,000
$19,117,000
$13,582,000
$38,417,000
$6,830,000
$9,930,000
$12,512,000
$10,394,000
$69,385,000
$8,962,000
$119,522,000
$27,461,000
$6,830,000
$63,842,000
$11,782,000
$16,320,000
$41,201,000
$17,810,000
$7,066,000
$10,656,000
$6,830,000
$15,110,000
$66,041,000
$6,830,000
$6,830,000
$39,592,000
$23,379,000
$21,275,000
$28,119,000
$6,830,000
D-2
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Appendix E: CWNS 2012 Needs Category
Definitions
Category I. Secondary Wastewater Treatment
This category includes needs and costs necessary to meet the minimum level of treatment that must
be maintained by all treatment facilities, except those facilities granted waivers of secondary treatment
for marine discharges under section 301(h) of the CWA. Secondary treatment typically requires
a treatment level that produces an effluent quality of 30 mg/l of both 5-day biochemical oxygen
demand (BOD5) and total suspended solids. (Secondary treatment levels required for some lagoon
systems could be less stringent.) In addition, the secondary treatment must remove 85 percent of
BOD5 and total suspended solids from the influent wastewater.
Category II. Advanced Wastewater Treatment
This category includes needs and costs necessary to attain a level of treatment that is more stringent
than secondary treatment or produces a significant reduction in nonconventional or toxic pollutants
present in the wastewater treated by a facility. A facility is considered to have advanced wastewater
treatment if its permit includes one or more of the following: BOD less than 20 mg/l, nitrogen
removal, phosphorus removal, ammonia removal, metal removal, and synthetic organic removal.
Category III-A. Conveyance System Repair: Infiltration / Inflow (II) Correction
This category includes needs and costs for correction of sewer system with infiltration/inflow
problems. Infiltration includes controlling the penetration of water into a sanitary or combined
sewer system from the ground through defective pipes or manholes. Inflow includes controlling the
penetration of water into the system from drains, storm sewers, and other improper entries. It also
includes costs for preliminary sewer system analysis and detailed sewer system evaluation surveys.
Category III-B. Conveyance System Repair: Sewer Replacement/Rehabilitation
This category includes needs and costs for the maintenance, reinforcement, or reconstruction of
structurally deteriorating sanitary or combined sewers. The corrective actions must be necessary to
maintain the structural integrity of the system.
Category IV-A. New Conveyance Systems: New Collector Sewers and
Appurtenances
This category includes the costs of new pipes used to collect and carry wastewater from a sanitary or
industrial wastewater source to an interceptor sewer that will convey the wastewater to a treatment
facility.
Category IV-B. New Conveyance Systems: New Interceptor Sewers and
Appurtenances
This category includes needs and costs for constructing new interceptor sewers and pumping stations
to convey wastewater from collection sewer systems to a treatment facility or to another interceptor
sewer. Needs and costs for relief sewers are included in this category.
E-1
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Appendix E: OWNS 2012 Needs Category Definitions
Category V-A. Combined Sewer Overflow (CSO) Correction—Traditional
Infrastructure9
This category includes needs and costs to prevent or control the periodic discharges of mixed
stormwater and untreated wastewater (CSOs) that occur when the capacity of a sewer system is
exceeded during a wet weather event. This category includes traditional CSO control infrastructure
such as collection, storage, and treatment technologies. This category does not include needs and
costs for overflow control allocated to flood control, drainage improvement, or the treatment or
control of stormwater in separate storm systems.
Category V-B. Combined Sewer Overflow (CSO) Correction —Green Infrastructure
This category includes needs and costs to prevent or control the periodic discharges of mixed
stormwater and untreated wastewater (CSOs) that occur when the capacity of a sewer system is
exceeded during a wet weather event. This category includes green infrastructure CSO control
infrastructure such as upland runoff control techniques. It does not include needs and costs for
overflow control allocated to flood control, drainage improvement, or the treatment or control of
stormwater in separate storm systems.
Category VI. Stormwater Management Program (pre-2008 needs only)10
This category includes the needs and costs to plan and implement structural and nonstructural
measures to control the runoff water resulting from precipitation (stormwater). It includes controlling
stormwater pollution from diffuse sources by (1) reducing pollutants from runoff from commercial and
residential areas served by the storm sewer, (2) detecting and removing illicit discharges and improper
disposal into storm sewers, (3) monitoring pollutants in runoff from industrial facilities that flow into
municipal separate storm sewer systems (MS4s), and (4) reducing pollutants in construction site runoff
discharged to municipal separate storm sewers.
Needs and costs can be reported for phase I, phase II, and nontraditional (e.g., universities, prisons,
school districts) MS4s. Unregulated communities can also report needs and costs in this category.
Only pre-2008 needs and costs are in category VI. Beginning in 2008, stormwater management
program needs and costs are reported in subcategories VI-A to VI-D.
Category VI-A. Stormwater Management Program: Stormwater Conveyance
Infrastructure
This category includes the needs and costs to address the stormwater management program activities
associated with the planning, design, and construction of conveying stormwater via pipes, inlets,
roadside ditches, and other similar mechanisms.
9 Prior to CWNS 2012, categories V-A and V-B were combined into a single category: Combined Sewer Overflow Correction (category V).
10 From CWNS 1992 to CWNS 2004, all stormwater management program needs were captured in category VI. Beginning with CWNS 2008,
stormwater management program needs were divided among the four listed subcategories.
E-2
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Appendix E: OWNS 2012 Needs Category Definitions
Category VI-B. Stormwater Management Program: Stormwater Treatment Systems
This category includes the needs and costs to address the Stormwater management program activities
associated with the planning, design, and construction of treating Stormwater with wet ponds, dry
ponds, manufactured devices, and other similar means.
Category VI-C. Stormwater Management Program: Green Infrastructure
This category includes the needs and costs to address the Stormwater management program activities
associated with the planning, design, and construction of low impact development and green
infrastructure (e.g., bioretention, constructed wetlands, permeable pavement, rain gardens, green
roofs, cisterns, rain barrels, vegetated swales, restoration of riparian buffers and flood plains). Projects
in this category can be both publicly and privately owned.
Category VI-D. Stormwater Management Program: General Stormwater
Management
This category includes the needs and costs to address the Stormwater management program activities
associated with the planning, design, and construction of treating Stormwater with wet ponds, dry
ponds, manufactured devices, and other similar means. This category includes the needs and costs
to address the activities associated with implementing a Stormwater management program, including
geographic information systems and tracking systems, equipment (e.g., street sweepers, vacuum
trucks), Stormwater education program startup costs (e.g., setting up a Stormwater public education
center, building a traveling Stormwater education display), and Stormwater management plan
development.
Category X. Recycled Water Distribution11
This category includes the needs and costs associated with conveyance of treated wastewater that is
being reused (i.e., recycled water), including associated rehabilitation/replacement needs. Examples
are pipes to convey treated water from the wastewater facility to the drinking water distribution system
or the drinking water treatment facility and equipment for application of effluent on publicly owned
land. Needs and costs associated with additional unit processes to increase the level of treatment to
potable or less than potable but greater than normally associated with surface discharge needs are
reported in category II.
Category XII. Decentralized Wastewater Treatment Systems12
This category includes needs and costs associated with the rehabilitation or replacement of on-site
wastewater treatment systems (OWTS) or clustered (community) systems. It also includes the
treatment portion of other decentralized sewage disposal technologies. Costs related to developing
and implementing on-site management districts are included (but not the costs of ongoing operations
of such districts). Costs could also include the limited collection systems associated with the
decentralized system. Public ownership is not required for decentralized systems.
11 Recycled Water Distribution (category X) was added as a category beginning in CWNS 2004.
12 Until CWNS 2000, needs for Decentralized Wastewater Treatment were captured as Secondary Wastewater Treatment (category I) needs. For CWNS
2004, these needs were reported as NFS control: Individual/Decentralized Sewage Treatment (category VII-L). Beginning in CWNS 2008, the
category was renamed and renumbered to Decentralized Wastewater Treatment System (category XII) needs.
E-3
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Review of the Allotment of the Clean Water State Revolving Fund (CWSRF) Report to Congress
Appendix E: OWNS 2012 Needs Category Definitions
This category does not include the needs and costs to change a service area from decentralized
wastewater treatment to a publicly owned centralized treatment system. Needs to construct a publicly
owned centralized collection and treatment system should be reported in secondary wastewater
treatment (category I) and/or advanced wastewater treatment (category II). Needs to install sewers to
connect the service area to an existing collection system are reported in new collector sewers and
appurtenances (category IV-A) and new interceptor sewers and appurtenances (category IV-B).
E-4
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